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Privacy Policy

1. Our Commitment to Your Privacy
BTM Vendor (“BTM Vendor”, “we” or “us”) recognizes the importance of data privacy in today’s digital economy. We believe that privacy is a matter of trust, and we are committed to managing personal data lawfully, fairly, and transparently. We want our website visitors, customers, and business partners (collectively, “you” or “your”) to understand the ways we collect and use personal data about you.

This Privacy Policy describes:

  • Ways we collect your personal data
  • Ways we use your personal data
  • Ways we share your personal data
  • Ways we retain and safeguard your personal data
  • Your rights and choices about how we collect, use, and share your personal data

2. Policy Scope
This Privacy Policy applies to our business operations to the website btmvendor.com, and its subdomains (collectively and hereafter, the “Site”), which are all hosted in the United States and United Kingdom.

3. Ways We Collect Your Personal Data

3.1. In General
We collect only personal data that you provide to us voluntarily and with your consent. BTM Vendor takes measures to ensure that we collect personal data for specified, explicit, and legitimate reasons only – namely, to provide services to you and meet our legal obligations. We also take steps to limit the personal data we collect to only the minimum necessary to carry out our mission. We may collect your personal data when you:

  • Communicate with us via e-mail or other channels;
  • Create an account; or
  • Sign up for an event

In these instances, we may collect personal data such as your name, e-mail address, postal address, phone and fax number, company name, job title.

If you request materials or invest in our projects, we may also collect personal data such as your birthdate, bank account, and optional demographics (occupation, location, etc.).

3.2. Log Files
We use log files to record data about each user’s visit to our Site. When you visit the Site, we collect the IP (Internet Protocol) address connected to your computer (or the proxy server you use to access the World Wide Web), your computer operating system, the type of browser you are using, mobile device operating system (if you are accessing the Site using a mobile device), as well as the name of your ISP (“Internet Service Provider”) or your mobile carrier. We use this information to analyze overall trends to help improve the Site. We do not share log data with third parties unless required by law to do so.

3.3. Cookies
We use cookies, which track user behavior, to inform enhancements to the overall user experience on our Site. A cookie is a piece of data stored on your device, containing information about your online activity. We do not use cookies to record personal data about you. Once you close your browser, the cookie simply terminates. If you reject the cookie, you may still use our Site. If you reject a cookie, Site functionality may be limited in areas. We use cookies to simplify data entry on the following areas of our Site:

  • Email when logging in; and
  • Name and email when updating registration

3.4. Third-Party Use of Cookies and Other Tracking Technologies
We use Google Analytics and Hotjar to understand Site users’ needs and to optimize the Site’s service and experience. Google Analytics and Hotjar track usage information on the Site, including top webpages, what links users click, time spent on the Site, visitor demographics, and sources of traffic to the Site. Google Analytics and Hotjar use cookies and other technologies to collect data on users’ behavior and their devices (in particular devices’ IP address captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and preferred language used to display on the Site.

We do not use Google Analytics or Hotjar to track, collect or upload any data that personally identifies an individual (such as a name, email address, or billing information), or other data which can be reasonably linked to such information by Google Analytics or Hotjar. Refer to the Google Analytics Terms of Service and Hotjar’s Privacy Policy for more information.

We do not control these third parties’ tracking technologies or how they may be used.

3.5. Surveys
From time to time, we may collect information from you via an online survey. Participation in these surveys is completely voluntary. Information requested may include personal and demographic information. Survey information will be used for purposes of monitoring and improving the Site and/or BTM Vendor products and services.

3.6. Your Consent to Our Collection and Subsequent Use
By using this Site or otherwise communicating with BTM Vendor electronically, you consent to our collection and subsequent use of your personal data for our legitimate business uses. If you do not consent to such collection or subsequent use of your personal data, please do not use this Site or communicate with BTM Vendor.

4. Ways We Use Your Personal Data
We may use your personal data to communicate with you and provide you with investment services. For example, we may use your personal data to:

  • Send you Report or our monthly email update;
  • Send you invitations to events and conferences;
  • Answer questions you submit to us;
  • Maintain our contact list;
  • Administer our investment services; and
  • Comply with our legal and contractual obligations

If you are an investor, we may also use your personal data to process your investment application, maintain your account, and provide updates related to the Investment.

If you wish to request that BTM Vendor refrains from using your personal data to communicate with you, please submit your request to BTM Vendor by using the contact information below.

5. Ways We Share Your Personal Data

5.1. In General
We have not and will not sell or lease your personal data to third parties. In the context of the uses of personal data mentioned in the section above, we may share your personal data with third parties we engage to help provide services to you. These third parties include, but are not limited to, organizations that provide:

  • Payment processing for our Community Investment Notes;
  • Customer relationship management (CRM) platform;
  • Business resilience and disaster recovery;
  • User authentication tools and services;
  • Auditing platforms and services;
  • Correspondence regarding investments; and
  • Email and direct marketing tools and services

Our third-party service providers maintain their own Privacy Policies. We encourage you to visit their websites to learn more.

5.2. Special Circumstances
We may also share your personal data in special circumstances, such as:

  • As required by law or in response to a subpoena or other government information request;
  • If we believe that the disclosure is in the interest of your security or the security of BTM Vendor (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
  • If we merge with or are acquired by another company.

5.3. Sharing Aggregate Information
When BTM Vendor requests demographic information during an information request or registration, you have the option not to provide this information. We encourage you to do so that we may gain a better understanding of your needs, and so that we may serve you in a more personalized manner.

In certain instances, we may share aggregate information with strategic partners. For example, we may tell a partner that X number of individuals visited a certain area on the Site, or that Y number of men and Z number of women filled out our registration form. We do not disclose information that could be used to uniquely identify you.

5.4. Opting-Out of Sharing Your Personal Data
You have choices regarding the ways we share your personal data with third parties. If you wish to opt-out, please contact us.

6. Personal Data Retention
We retain your personal data for as long as you are a business contact to us or as needed to provide you services. Though you may have the right to request that we delete your personal data under GDPR, BTM Vendor will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

7. Individual’s Rights Under the General Data Protection Regulation (GDPR)
If you are a resident in the European Union (EU), you have certain data privacy rights under the General Data Protection Regulation (GDPR). These rights include:

  • Access: You have the right to access your personal data held by BTM Vendor.
  • Correction, Amendment, and Removal: You have the right to correct or amend your personal data held by BTM Vendor. You also have a right to request that BTM Vendor deletes certain personal data about you.
  • Restriction: You have the right to restrict processing of your personal data held by BTM Vendor if you contest the accuracy of your personal data held by BTM Vendor or the lawfulness of BTM Vendor’s processing of your personal data.
  • Portability: You have the right to receive your personal data held by BTM Vendor in a structured, commonly-used, and machine-readable format. You also have the right to transmit your personal data to another organization without hindrance from BTM Vendor.
  • Objection: You have the right to object, on grounds relating to your particular situation, to BTM Vendor’s processing of personal data about you, unless BTM Vendor demonstrates compelling legitimate grounds for continuing such processing. You also have the right to object to the processing of your personal data for direct marketing purposes.
  • Lodging a Complaint: You have the right to lodge a complaint with a supervisory authority located in the country of your residence.

If you would like to exercise any of the above rights, please contact us.

8. Security and Storage
We use reasonable security measures to protect personal data against unauthorized access and disclosure. However, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

9. Your Consent and Acceptance
By using this Site, you consent to the terms of this Privacy Policy and our processing of personal data for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use our Site.

10. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy from time to time and will publish any changes on the Site. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Site.

11. How to Contact Us
If you have any questions about this Privacy Policy, or if you would like to make a request under the GDPR or other applicable law, you can contact us at:

BTM Vendor, LLC
225-237 N. 9th Street, Boise, ID 83702.
Email: support@btmvendor.com
Phone: +1 208-998-6814

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