Last Updated April 19, 2021
We may share and use your Personal Information with our parent, subsidiary and affiliate entities for use in connection with their websites and their services. Unless you opt out, we may share your Personal Information with third parties for their direct marketing purposes as further described in our Information Disclosure and Your Choices/Your Privacy Rights sections below.
Note: This statement applies solely to information collected at or through the Site. However, we may link to other online destinations, so we advise you carefully review their respective privacy policies. Please be aware that BCE is not responsible for the contents and the privacy practices of such other sites.
California Privacy Rights
Section 1798.83 of the California Civil Code provides that residents of California can obtain certain information about their personal information (as defined under Section 1798.83(e)(6) of the California Civil Code) that companies have shared with third parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third parties. Personal information, as defined under the California Civil Code, includes, but is not limited to, data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller. To request a copy of your Personal Information maintained by us, please contact us at [email protected].
CATEGORIES OF INFORMATION COLLECTED
In the last twelve (12) months we may have collected and may in the future collect the following categories of information from you:
- Identifiers (such as contact information, government IDs, cookies, etc.),
- Information protected against security breaches (such as your name and financial account, driver’s license, social security number, user name and password, health/medical information),
- Commercial information,
- Internet/electronic activity, geolocation, audio/video data, professional or employment related information,
- Audio, electronic, visual, thermal, olfactory or similar information,
- Education information, biometrics, and inferences from the foregoing.
- Access to Your Personal Information
At any point while we are in possession of or processing your Personal Information, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to you in a readily usable format.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to Opt-Out – you have the right to opt-out of sales of your Personal Information to third parties.
- Non-Discrimination – You have the right not to be discriminated against by denying goods or services to you, charging a different price or rate for goods or services, providing a different level or quality of goods or services, or suggesting that we will do any of these things based upon your exercise of any CCPA rights.
- Third parties must also give consumers explicit notice and an opportunity to opt out before re-selling personal information that the third party acquired from another business.
- Right to judicial review: in the event that BCE refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your Personal Information.
Exercising Your Rights
To exercise your rights described above, you may submit a verifiable consumer request to us by:
- Calling us at 310-432-5688
- Emailing us at [email protected]
Requests to access Personal Information can only be made twice within a twelve- (12-) month period. We will respond within forty five (45) days of receiving a Personal Information request.
Sharing Personal Information
In the preceding twelve (12) months, we have not sold any Personal Information and we do not currently sell any Personal Information. If you wish to opt-out of the sale of your Personal Information in the future, please contact us at [email protected].
Information You Provide to Us
BCE collects Personal Information through the Site at several points. For instance, we require your e-mail address and zip code. Rest-assured, BCE does not collect any Personal Information that you do not expressly provide and will not sell, rent, or share your Personal Information to any third party for marketing purposes without your consent.
We (or our service providers) collect information from you when you: (1) make an investment on our Sites; (2) create an account or profile with us (the “Account”), or otherwise sign up for a service or feature; (3) upload or otherwise submit materials or work to us; or (4) contact us, or otherwise communicate with us or provide information to us.
When you visit our Site, we also collect anonymous information such as your IP address or domain name to analyze Site traffic, but this information is not personally identifiable. We will use this information to help diagnose problems with our server, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
In some cases, you may provide information to us about another person, such as when you share Site content. In such cases, you represent that you have the authorization of such person to provide us with such information.
We may combine your (and others’) information that we have collected from you (or others) with information we may receive from other sources, such as third-party social media platforms (e.g., when you choose to log in to our Sites through a third-party social media platform, subject to your actions and settings thereon), address update services and co-promotion partners. By accessing our Sites, you signify your consent to the above collection of your Personal Information.
When you are creating an Account for the first time on a Site with an email address that you have previously provided to us in another circumstance (e.g., when signing up for our emails,), we may recognize that email address and, once you have completed the account set-up process, you may be able to see your contact information already included in your new online Account. This is happening because we have recognized your email address and, for your convenience, have added your information to your Account.
If you do not want us to collect your Personal Information through the Site, please do not provide it to us. In addition, you can revoke your consent in accordance with the procedures set forth below.
If you receive an email or other correspondence requesting that you provide any sensitive information (including your Site password) via email or to a web site that does not seem to be affiliated with the Site, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at [email protected].
Site Information & Other Information Collected Automatically
Site Usage Information includes, but is not limited to: (i) your browser type, device type, carrier (if applicable), device address, operating system, operating system address, IP address and the domain name from which you accessed a Site; (ii) information about your region, continent, country, city, zip code, time zone, and general location; and (iii) information about your browsing activities on and through a Site (also known as “Click Stream” data), such as (a) the date and time you visit one of the Sites, (b) the areas or pages of a Site that you visit, (c) the amount of time you spend viewing a Site or specific areas of a Site, (d) the number of times you return to a Site or a specific area of a Site, (e) the web sites or pages you visited prior to visiting a Site, (f) the websites or pages you visit after you leave a Site; (g) searches you have performed on a Site and on other websites that led you to our Sites; (h) social plug-ins with which you have interacted on our Sites; and (j) other similar Site usage data (collectively, the “Site Usage Information”).
If you provide or connect your third-party account credentials to an account with our Site, some content and/or information in those accounts may be transmitted into your account with us. For example, when you connect with Facebook, we receive and collect your name, email address and profile photo.
Cookies and Other Tracking Technologies
We may use Flash cookies and other similar technologies, which allow a website to store certain information locally on an individual’s computer or device and then access and use that information to enhance and facilitate certain Site experiences, processes and functionality. Flash cookies are different from other cookies and may not be removed in the same manner. More information about both kinds of cookies is available at www.allaboutcookies.org.
We also may use web beacons (also known as “clear GIFs” or “pixel tags”) for similar purposes as cookies. These beacons are typically one-pixel images that are embedded in the Site or in a communication, such as an email message. These technologies help us to verify when a certain page of a Site is viewed, when a message is opened and when links or other content in a message are clicked or viewed.
We may use third party web analytics services, such as Google Analytics and Adobe services, to help us track and analyze the use of our Site and to measure the effectiveness of our advertising, Site content, and communications. These service providers’ tools, including, for example, cookies, tags and web beacons, help us to gain this understanding.
Do Not Track
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.
Third Party Advertising
We may use the information we collect from and about you (including both Personal Information and Site Usage Information) for a variety of purposes, including but not limited to the following:
(i) To fulfill your requests for services and to keep you informed about your investment(s); (ii) to provide you with targeted offers and advertising on and at the Sites; (iii) subject to your communications preferences and, where required by applicable law, subject to your consent, to contact you (via postal mail, email and the like) with promotional materials about us, our services and our events, as well as about select partners; (iv) to contact you when necessary or appropriate; where appropriate, for market research and to review and improve our services; (v) to protect the security or integrity of the Sites and our business; (vi) and otherwise, with your permission or as permitted by law.
We (and our service providers) also analyze and use Site Usage Information and information collected through cookies, web beacons and other tracking technologies, alone and in combination with Personal Information, to assess the behavior of our users, to measure the interest in and use of the Sites and communications, and to customize the Sites and our communications with you. We do this both on an individual basis and in the aggregate.
This table shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may disclose information we collect (including Site Usage Information and Personal Information) in the following ways to third parties, to the extent permitted by law:
- To our service providers and suppliers, who collect or use such information for us or on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, and other similar entities that help us to operate the Site and/or provide functionality, content and services);
- The BCE companies and affiliated entities;
- Auditors and professional advisers like bankers, lawyers, accountants and insurers;
- To respond to subpoenas or other judicial processes, or to provide information as requested by law;
- As otherwise, with your permission or as permitted by law.
Content and information that you submit on or through Facebook, Twitter, Instagram, Tumblr and other third-party platforms may appear on the Site through feeds from and other interfaces with those platforms. We are not responsible for the information, content and/or privacy practices of any such third-party platforms.
Your Choices / Your Privacy Right / How To Unsubscribe
If you would like to opt out of receiving promotional emails from us, please follow the unsubscribe instructions located in each such email or contact us at [email protected]. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your Account, relationship, activities, transactions and communications with us.
If you would prefer that we not share your Personal Information with third-party marketers, please contact us at [email protected]. Please understand that if you do request that we stop sharing your Personal Information with third parties for their direct marketing purposes, such request will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from third parties that received your Personal Information prior to that request. In these cases, please opt out from or contact the third party directly.
Where we are asking you for sensitive Personal Information we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting us at [email protected]. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Maintenance Processing of Information in the U.S. and Other Countries
Your personal and other information may be stored, transferred and processed in and to the United States. By providing Personal Information to us, you consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, pursuant to the laws of the United States or such other jurisdictions, which may provide lesser privacy protection than the laws of other countries, and you acknowledge that your information may thus be subject to U.S. laws and accessible to the U.S. government, courts, law enforcement and regulatory agencies.
To provide you with increased security, access to certain Personal Information stored in your Account is protected with your username and password. You are responsible for maintaining the confidentiality of your Account credentials, and we strongly recommend that you do not disclose your account username or password to anyone. We will never ask you for your password in any unsolicited communication. Please notify us immediately of any unauthorized use of your Account credentials or any other suspected breach of security.
The Sites are not directed to children under the age of thirteen (13). If you are under thirteen (13), do not provide your Personal Information on or to the Site. We do not knowingly collect on the Sites any Personal Information from children under thirteen (13). Users outside of the United States who are below the age of eighteen (18) (or the age of the majority in the applicable jurisdiction) should not use the Sites without authorization from a parent or legal guardian. If a parent or guardian becomes aware of his or her child has provided us with Personal Information without their consent, please contact us at [email protected]. Moreover, the CCPA prohibits us from selling any Personal Information of children under the age of sixteen (16) without express consent. Therefore, unless we have such consent, we will not under any circumstances sell such Personal Information.
We will process (collect, store and use) the information you provide in a manner compatible with the CCPA. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. BCE is required to retain information in accordance with the law, such as information needed for income tax, securities laws compliance and audit purposes. Otherwise, we will only process Personal Information for so long as reasonably required to provide the services.
How We Use the Personal Information Collected About You
We will process (collect, store and use) the information you provide in a manner compatible with the GDPR and the CCPA. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. BCE is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices.
How To Find Out Personal Information Held By BCE
BCE, at your request, can confirm what information we hold about you and how it is processed. If BCE does hold Personal Information about you, you can request the following information:
- Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of BCE or a third party, information about those interests.
- The categories of Personal Information collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the Personal Information to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending Personal Information to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Information and the possible consequences of failing to provide such data.
- The source of Personal Information if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
BCE accepts the following forms of ID when information on your personal data is requested: Passport Driver’s License, or other valid photo ID
In the event that you wish to make a complaint about how your Personal Information is being processed by BCE or third parties, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and BCE’s data protection representatives.
To contact our Data Protection Representative:
Email: at [email protected]
Role of Juniper Square.
b. Business Transfer. If Juniper Square, or substantially all of Juniper Square’s assets, are acquired, or in the unlikely event that Juniper Square were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Juniper Square may continue to process your Personal Information as set forth in this Policy (as it may be amended from time to time).