PRIVACY POLICY

 

Respecting and protecting our community’s privacy is vital to our business. This Privacy Policy describes how Bullet Point Network, L.P. (together with its subsidiaries and affiliates "BPN", "us", "we" or "our") gathers and uses personal information about you when you visit BPN’s websites that link to this Privacy Policy (including bulletpoint.network, s2s.news, and any sites that are automatically redirected to them, collectively, the "Sites"); how we protect and share this information; and the rights you may have in relation to this information. Please read this Privacy Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of the Sites.

In the event that you have any questions or concerns about this Privacy Policy, or if you object to our uses of your personal information, please contact our Privacy Office at privacy@bulletpoint.network.

A. The Types of Information We Collect

When you visit and browse the Sites, you may provide us with information, and we will collect certain information automatically.

1. Information You Provide to Us

In order to access certain services provided via the Sites or to request certain information from BPN via the Sites, you will be required to provide certain personal information.

This may include your name, postal address, e-mail address, telephone number, facsimile number, investor status, or other information about yourself. In particular, you may be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Sites, which rely on such information (for example, you will not be able to register for e-mail updates if you do not provide us with an e-mail address, and if you choose not to provide a username and password, we will not be able to provide you with services available through an online account).

2. Information We Collect Automatically

We also collect information about you automatically.

For example, when you visit the Sites, we collect your IP address, your browser type, your operating system, the pages you view on the Sites, the duration of your visit, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.

We collect this information using cookies, which are small files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website.

We and other companies use cookies and web beacons for a variety of purposes. For instance, when you return to our Sites after logging in, cookies provide information to the Sites so that the Sites will remember who you are.

We use web beacons and other technologies to analyze the traffic patterns on the Sites, such as the frequency with which our users visit various parts of the Sites.

3. Additional Information Collection Practices 

The Sites may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.

Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.

Some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.

We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.

B. How We Use the Information We Collect

We use information we collect about you primarily to: provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.

C. How We Share the Information We Collect

1. In Connection with Third Party Offers

We will share information about you with third-parties when you engage in certain activities on the Sites that are sponsored by third-parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. When you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.

2. Service Providers

Sometimes we engage companies that act on our behalf in association with the operation of the Sites. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.

Except as otherwise disclosed in this Privacy Policy or as otherwise communicated to you, BPN takes reasonable steps require these companies to collect, store, and use information about you only on our behalf and in accord with this Privacy Policy. We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

3. Analytics Providers

We engage third-party analytics providers to help us understand how users engage with the Sites. These third-parties may use cookies and similar technologies to collect information about your use of the Sites as well as information about your use of other websites over time.

The third-party services we use include, but may not be limited to: Google Analytics and Hubspot, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

4. Additional Sharing Practices

From time to time we share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. From time to time, we partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.

We may disclose information when we believe in good faith that such disclosures:

  • are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency's request;

  • will help to protect our rights or enforce our Terms of Use;

  • will support our detection, prevention, or response to fraud or intellectual property infringement;

  • will help protect your safety or security, including the safety and security of property that belongs to you; and

  • will protect the safety and security of the Sites, databases, and/or third-parties, including the safety and security of tangible and/or intangible property that belongs to us or to third-parties.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.

D. The Security Measures We Take to Safeguard Information

The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

E. Updating Your Contact Information

You may update your contact information and/or modify your communication preferences by sending us an e-mail at privacy@bulletpoint.network. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.

F. Children’s Information

The Sites are intended for use by those over 18, and minors under the age of 13 may not use the Sites.

We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

G. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

Third-parties, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

H. California Privacy Rights

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise those rights, please email us at privacy@bulletpoint.network.

I. Your Choices and Rights

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at privacy@bulletpoint.network or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal information.

J. Where Is Information Processed?

We process information collected via the Sites in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

K. How Long Is Information Retained?

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

L. Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Policy to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

This policy was last updated April 2019.

M. How to Contact Us

If you have any questions regarding this policy or our privacy or data protection practices, please feel free to contact us at privacy@bulletpoint.network.