TRUSTe Privacy Policy Certification

Privacy Policy

Effective January 18, 2017

Backstop Solutions Group, LLC ("BSG", "we," "us," or the "Company") is committed to protecting the privacy of your information and will always tell you how it is being used. This privacy policy ("Privacy Policy") describes the data privacy practices of BSG, the types of information we collect about you, and how we use and safeguard it.

By providing BSG with personal information, you expressly consent to the processing and handling of your information in accordance with this Privacy Policy. Personal information may be processed by BSG in the country where it was collected, as well as other countries (including the United States) where laws regarding processing of personal information are less stringent.

Backstop Solutions Group, LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework (“Privacy Shield"). Backstop Solutions Group, LLC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List. [https://www.privacyshield.gov/list]

Backstop Solutions Group, LLC is responsible for the processing of personal data it receives, under Privacy Shield, and for certain purposes may subsequently transfer or provide access to this data to a third party acting as an agent on its behalf. Backstop Solutions Group, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to Privacy Shield, Backstop Solutions Group, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Backstop Solutions Group, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

U.S. – Swiss Safe Harbor Framework

BSG complies with the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from Switzerland. BSG has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Backstop Solutions Group, LLC’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.

Web Sites Covered

BSG maintains a number of web sites ("BSG Web Sites"), as well as two hosted software platforms, (i) Backstop Suite (formerly “Backstop”), and (ii) Backstop Portal (formerly “InvestorBridge”) ("BSG Services"). This Privacy Policy covers the information practices of all BSG Web Sites and BSG Services that link to this Privacy Policy, including http://www.backstopsolutions.com, https://blog.backstopsolutions.com, and any associated sub-domains. The use of information collected through BSG Services shall be limited to the purpose of providing the service for which the client has engaged BSG. From time to time, BSG Web Sites may contain links to other web sites. BSG is not responsible for the information practices or the content of any other web site and encourages you to review the privacy policies of other web sites to understand the privacy practices in effect with respect to these other websites.

Information Collected by BSG

BSG collects information from individuals who visit BSG Web Sites ("Visitors"), and who become users of BSG Services ("Subscribers"), using active and passive methods. Examples of BSG's information collection practices include, but are not limited to, collecting information when Visitors navigate through BSG Web Sites (passive), submit a request for information (active), or become a Subscriber to BSG Services (active).

As Visitors navigate through BSG Web Sites, BSG may passively collect non-personal information through the use of common data-gathering tools, such as cookies. This data may include basic information from a Visitor's web browser (such as browser type), or a Visitor's Internet Protocol ("IP) address. It may also include information about the actions taken on BSG Web Sites (such as the web pages viewed).

Tracking Technologies

Backstop Solutions Group, LLC and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our BSG Websites or BSG Services.

Analytics/Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer BSG Web Sites, to track users’ movements around BSG Web Sites, and to gather demographic information about our user base as a whole.

Behavioral Targeting/Re-Targeting

We use the services of Leadlander, Inc. in connection with BSG Web Sites. When Visitors view BSG Web Sites, a tracking operation retrieves data about the page request. This information is forwarded to the Leadlander, Inc. server via a list of parameters attached to a single-pixel image GIF request, known as a web beacon. The data tracked includes the page viewed, referring page, search-related data, and IP address. This data is then processed and forwarded to BSG. BSG uses the data provided by Leadlander in order to evaluate visits to, and monitor use of, BSG Web Sites.

If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

We also use Google AdWords in connection with BSG Web Sites. Backstop uses the Google AdWords remarketing service to advertise on third-party websites (including Google) to previous visitors to BSG Web Sites. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to our website. Any data collected will be used in accordance with this Privacy Policy and Google's privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page, and you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page. You may also opt out of interest-based advertising entirely by activating the setting on your internet browser that turns off cookie functionality. For more information about cookies, including how to set your internet browser to reject cookies, please visit http://www.allaboutcookies.org.

IP Addresses

When Visitors access BSG Web Sites, or Subscribers access BSG Services, the Company collects IP addresses to track and aggregate non-personal information. For example, BSG uses IP addresses to monitor the regions from which Subscribers and Visitors navigate to BSG Services, and BSG Web Sites, respectively.

When Visitors express interest in obtaining additional information from BSG about BSG Services or educational and thought-leadership resources such as "white papers", BSG requires Visitors to provide personal information such as the Visitor’s name, company name, address, phone number, and email address. Visitors can opt out of providing the Company with this information, by not entering it on BSG Web Sites when such information is requested. It may not be possible for BSG to provide BSG Services to individuals who choose not to provide this personal information. BSG provides notification when personal information is required in order to provide assistance or respond to an inquiry.

Why BSG Collects Information

BSG collects personal information that is needed to provide customer service, offer new products and services to Visitors and Subscribers, or fulfill any legal and/or regulatory requirements associated with the provision of BSG Services. BSG does not intentionally collect sensitive personal information (e.g., personal information pertaining to medical or health conditions, racial or ethnic origin).

BSG will always offer Visitors and Subscribers, including those located in the EU, whose personal information has been transferred to the United States, the opportunity to opt out from: (i) the disclosure of personal information to a non-agent third party for any reason not disclosed in this Privacy Policy; and (ii) BSG's use of a Visitor’s or Subscriber’s personal information for a purpose other than those disclosed in this Privacy Policy, a compatible purpose, or a purpose subsequently authorized by the Subscriber. BSG will provide Subscribers with a reasonable mechanism to exercise their choice to opt out of “(i)” and “(ii)” above, should such circumstances arise.

Disclosure of Personal Information

BSG is not in the business of selling or sharing information with any entity not directly involved in providing BSG Services. BSG will never review, share, distribute, print, reference, or disclose any personal information, including any personal information received from the EU, to any third-party for any purpose that has not been disclosed in this Privacy Policy unless: (i) the Company has provided sufficient notice, and Visitors and Subscribers have had an opportunity to exercise choice, as outlined below, (ii) with respect to such use or disclosure; disclosure of such personal information has been agreed to by Visitors or Subscribers, and BSG, in conjunction with a contractual agreement, or (iii) in such cases where applicable law permits the use or disclosure without requiring that BSG first comply with Privacy Shield’s “Notice” and “Choice” Principles. Unless described in this Privacy Policy, BSG does not share, sell, rent, or trade any information provided by Visitors and Subscribers with third parties for promotional purposes.

BSG may provide your personal information to companies that provide services to help us with our business activities, such as when a user fills out a job application. These companies are authorized to use your personal information only as necessary to provide these services to us.

BSG reserves the right to use or disclose information if required to do so by law; or if BSG reasonably believes that such use or disclosure is necessary to protect BSG's rights, and/or to comply with a judicial proceeding, court order, or legal process.

If BSG is involved in a merger, acquisition, or sale of all or substantially all of its assets or stock, you will be notified via email and/or a prominent notice on BSG Web Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Opt-in, Opt-out Preferences

BSG offers Visitors and Subscribers who provide personal information to BSG a means to choose how such personal information is used. Visitors and Subscribers can manage the receipt of marketing and non-transactional communications by clicking on the "unsubscribe" link located on the bottom of the Company's marketing emails, or by contacting BSG directly at privacy@backstopsolutions.com and requesting to be removed from BSG's lists. Subscribers cannot opt out of receiving transactional emails related to the provision of BSG Services for which they are a Subscriber.

Accessing and Updating Personal Information

Upon request Backstop Solutions Group, LLC will provide you with information about whether we hold any of your personal information. Visitors and Subscribers may review, update, or otherwise make changes to their personal information by contacting privacy@backstopsolutions.com. We will respond to your request within a reasonable timeframe. In order to protect the confidentiality of personal information, BSG reserves the right to use previously obtained information to verify the inquiring party's identity, or take other actions BSG deems appropriate and necessary to provide assistance to an inquiring party.

If your personal information changes, or if you no longer desire our service, you may correct, delete, update, or amend it by emailing us at privacy@backstopsolutions.com, or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request within 30 days.

Backstop Solutions Group, LLC acknowledges that you have the right to access your personal information. Backstop Solutions Group, LLC has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the applicable BSG client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

Backstop Solutions Group, LLC collects information under the direction of its clients when providing BSG Services, and has no direct relationship with the individuals whose personal data it processes when providing BSG Services. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our clients.

We will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. Backstop Solutions Group, LLC will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Subscriber Data

Subscribers provide data and business information to BSG in connection with, or through, Subscribers’ use of BSG Services (“Subscriber Data”), by either directly inputting Subscriber Data into BSG Services, or providing the Subscriber Data to BSG for BSG to input into BSG Services on Subscriber’s behalf, for the purposes set forth in a Subscription, Maintenance & Support Agreement entered into between BSG and the applicable Subscriber (“Subscription Agreement”). BSG will not view, share, distribute, or reference any Subscriber Data except as provided in the Subscription Agreement, or as may otherwise be required by law. In accordance with the Subscription Agreement, BSG may access Subscriber Data only for the purpose of providing BSG Services, preventing or addressing service or technical problems, at a Subscriber's request in connection with support matters, or as required by law.

Data Retention

BSG will retain your Subscriber Data for as long as you are a Subscriber to BSG Services, unless you request that we delete your Subscriber Data from our records. If you wish to discontinue your use of BSG Services, or request that we no longer use your Subscriber Data to provide you other services, please contact us at privacy@backstopsolutions.com. BSG reserves the right to retain and use your Subscriber Data as necessary to comply with our legal obligations, resolve disputes, and enforce the terms of our Subscription Agreement.

Security

The Company hosts BSG Web Sites and BSG Services in a secure environment that utilizes firewalls, intrusion detection systems, and other advanced technologies to prevent interference or access from outside intruders. BSG employs rigorous security measures to protect Subscriber Data from unauthorized access, maintain data accuracy, and otherwise help ensure the proper use of Subscriber Data. When Subscribers connect to BSG Services, all information is transmitted in an encrypted format utilizing the Transport Layer Security (TLS) protocol and 256-bit Advanced Encryption Standard (AES), which is a strengthened version of the 128-bit cryptographic protocol typically utilized for transactions over the web. BSG also offers enhanced security features within the Services that permit Subscribers to configure requirements for password strength, and other Subscriber-controlled security settings, to the level Subscribers deem necessary. Subscribers are responsible for maintaining the security and confidentiality of their BSG usernames and passwords.

The physical security and integrity of Backstop's hosting facility is achieved and maintained by robust construction, comprehensive access controls, video surveillance monitoring, 24x7x365 security personnel, and comprehensive certified policies and procedures. The hosting facility's critical exterior perimeter walls, doors, and windows are constructed of materials that afford UL-rated ballistic protection. Proximity card readers control access into perimeter doors, shipping/receiving areas, storerooms, and other critical areas. Biometric hand print scanners control access into the most critical areas of Backstop’s hosting facility.

BSG utilizes its own BSG Services to maintain information about Visitors and Subscribers. As such, this information is secured in the same manner as described above for Subscriber Data.

BSG uses commercially reasonable means to protect the confidentiality, integrity, and security of any personal information submitted to us, both during transmission and after we have received such personal information, including complying with the requirements of Title V of the Gramm-Leach-Bliley Act and its implementing regulations that are applicable to BSG. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, BSG cannot guarantee the absolute security of personal information. In the event of a data breach involving the personal information of a Subscriber, BSG would report to the Subscriber after BSG became aware of the breach, and would cooperate with Subscriber in taking actions to limit the effect of, and investigate the scope and source of, the security breach. If you have any questions about security on BSG Web Sites, you can contact us at privacy@backstopsolutions.com.

Link to 3rd Party Sites

BSG Websites may contain links to other Web sites whose privacy practices may differ from those of BSG. If you submit personal information to any of those other sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Social Media Widgets

BSG Web Sites contain social media features, such as the Facebook “Like” button. These features may collect your IP address, which page(s) you are visiting on BSG Web Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on BSG Web Sites. Your interactions with these features are governed by the privacy policy of the company that provides them.

Amendments to This Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes to our information practices, however, if we make any material changes to this Privacy Policy, we will notify you by email (sent to the e-mail address we have on file), or by means of a notice on BSG Web Sites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

Please contact the Company with any questions, comments, suggestions, or complaints you have about the practices described in this Privacy Policy. Correspondence should be directed to BSG's privacy team by emailing the Company at privacy@backstopsolutions.com.

Alternatively, you can write to us at:
Backstop Solutions Group, LLC
Attention: Privacy Team
233 S. Wacker Drive, Suite 3960
Chicago, Illinois 60606