Privacy Notice

Information We Collect And How We Use It

We collect personal information about you for the legitimate business purposes described below. The types of personal information we collect for these purposes include:

• Information you provide through our site or as part of the account opening process.This includes information we receive from you on account opening applications or other forms, in particular your name, email, personal or business street address, social security number, assets and income. This also includes client’s organization details and client’s employee contact information that you post, publish through our site or otherwise provide to us. We use this information in order to open your account, for AML checks, know-your-customer reviews, and to provide you with information that you request from us and our services. Where permitted by applicable law, we use this information for our research purposes and in connection with our general sales practices to notify you of opportunities (with your consent, where required by applicable law).
• Information you provide when you apply for a position with BTIG.You may also apply for employment with us, including through the careers portal on our site. In that case, we collect and process personal information for the purposes of considering your application for employment, in particular:
  • Contact and identification information, including first and last name, address, country, phone number, email address, signature, applicant ID, government-issued identification information as required or permitted under applicable law;
  • Application information, including the roles for which you are applying, availability for a potential start date, how you heard about the role, any information in forms we ask you to complete, and information collected during your participation in an interview;
  • Talent management information, including information about your work experience, education information and records, qualifications, languages and skills, desired salary, references, CV and other information if included in your CV (such as your nationality, birthplace, date of birth, photograph, marital status, personal interests), cover letter, professional memberships and files that you submit to us in relation to your application; and
  • Background checks information, including, bank account number, credit report/credit score if applicable, searches in professional social media, and criminal record or sanctions information where permitted by applicable law.

  If you are applying online, we will also request responses to our application questions. Where permitted by applicable law, we collect your voluntary self-identification of gender, ethnicity, veteran status and disability status (which may be considered sensitive data in some jurisdictions and we protect it as such) when you submit your application on our careers portal. In addition to the personal information we collect directly from you, we may obtain certain of the personal information listed above from third-party sources, as permitted by applicable law. This includes recruitment agencies that send us your CV, travel agencies that we engage to make travel arrangements for interview purposes, educational institutions, professional regulatory bodies, publicly accessible directories and sources (for example, for anti-money laundering purposes), credit reference agencies, referrals (such as previous employers) that you indicate in your application for us to contact, and other third-party service providers that capture contact and other publicly available data from the online application form and other uploaded documents.

  We process personal information about job applicants to process job applications, evaluate professional experience and qualifications, and communicate with job applicants. Where permitted by applicable law, we also process job applicant personal information to conduct pre-employment background checks, including financial checks, verification of contact information, residency, employment history and qualifications.

• Information about your transactions with us or others.This includes your transaction history, account balance, payment history, and parties to transactions. We use this information to provide you with the requested service, to complete a transaction, to comply with our legal and regulatory responsibilities and to manage the interactions between BTIG and you. This includes accounting, auditing, billing and collection activities and other internal functions. We also use this information to process claims in connection with our products and services, exercise our rights and remedies and defend against legal claims, protect against, identify and prevent fraud and other criminal activity, claims and other liabilities, and comply with and enforce applicable legal requirements, relevant industry standards and our policies.
• Information you provide regarding marketing data preferences. We use this information in connection with our client support, to perform market research and client surveys, advertise and market our products and services, and to improve our offering of services to you. This includes administering the site, developing new products and services, enhancing, improving and analyzing our products and services, managing our communications, analyzing our client base and site and performing data analytics, as permitted by applicable law.
• Information that we may receive from a consumer reporting agency.This includes information such as your credit worthiness and credit history. We use this information in connection with providing you with credit information and extending credit to you.

We use your personal information for the above purposes because we have a legitimate business interest in providing services to our clients and other interested individuals, while meeting our legal obligations and protecting the firm’s rights and interests. In accordance with applicable law, we take reasonable measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we are happy to explain upon request.

Where we have a contract with you, we process your personal information as necessary to perform our contractual relationship with you, including managing contracts and legal support.

In addition, you may choose to submit personal information to us if you register to a newsletter, obtain our research, attend an event that we or one of our affiliates or partners organize or if you otherwise communicate with us on social media or by sending us electronic messages. Where required by applicable law, we will obtain your consent to send you electronic marketing communications about our products and services launches, offers and promotions, and invitations to events and surveys.

While the personal information you choose to provide is voluntary, certain personal information may be necessary to provide you with the relevant product or service. Each form on our site varies in the information it requests. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information in fields that are not required. If you choose not to provide certain information, this may affect our ability to provide you with certain products or services.

Information We Collect Automatically Through Our Site

When you visit our site, we automatically collect certain information such as the name of your Internet service provider, the public IP address of the computer or device you are using, the device ID, browsing history within our site, the type of browser software and operating system that you use, the date and time you access our site, the Internet address, if any, from which you linked directly to our site, the Internet address, if any, to which you travel from our site and other similar traffic-related information.

This information helps us improve our sites and the services that we provide through them, and we may provide such information to our employees, contractors, agents and designees to the extent necessary to enable them to perform certain site-related services (e.g., web hosting or maintenance services) on the firm’s behalf.

We use cookies and similar technologies to collect information about you as you navigate through our site. The information we collect in this manner includes your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.

Cookies and similar technologies help us to (1) make interactions with our site easier, faster to use and more secure, (2) remember your information and preferences so you do not have to re-enter them, (3) enhance our products and services, and (4) check they are working properly. Other cookies we use are required to verify your identity and secure your access to your account.

If you reject, disable or delete cookies, you can still use our site, but your ability to use some features or areas may be limited. Please note that some features and tools on our site may also be impaired if you block all cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

Third Party Analytics Services.

We may use third-party analytics services on our site, such as Google Analytics. The information we obtain through our site may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Information Sharing And Disclosure

We share personal information about you with our affiliates for the purposes described in this Privacy Notice. In addition, we may share personal information with third parties in certain circumstances, including:

• Where necessary to complete a transaction on your behalf; and
• Where necessary to protect against fraud, comply with a subpoena or other court or regulatory order or as otherwise required or permitted by law.

We share personal information with service providers that perform services on our behalf such as analytics providers, IT hosting providers and payment service providers.

We share job applicant personal information with our headquarters and affiliates as necessary to coordinate our recruitment activities and administer our job applicant databases. This may include your potential future supervisors and their designees, personnel in Human Resources, Information Technology, Compliance, Legal, Finance and Accounting. In addition, we may reasonably share personal information about job applicants with assigned recruiters and authorized third-party service providers such as our career portal hosting provider and other third-party service providers that conduct background checks.

Some of our service providers may be based in the U.S. We require service providers by contract to process personal information only on our behalf and to implement measures to protect the security and confidentiality of personal information. We also share personal information with consultants who need the information in order to provide services in connection with the delivery of services or products, management, administration, or legal responsibilities.

In the event of a company level transaction or similar event, including, but not limited to, a combination, reorganization, dissolution, or liquidation, merger or buyout, we may transfer your information to such combined, new or successor entity.

Data Transfers

We may transfer the personal information that we collect about you to recipients in countries other than the country in which the personal information originally was collected, including to the U.S and other countries where we have offices. Those countries may not have the same data protection laws as the country in which you initially provided the personal information. When we transfer your personal information to recipients in other countries, we will protect that personal information as described in this Notice and implement appropriate safeguards for the transfer as required by applicable law.

We will comply with applicable legal requirements by providing adequate protection for the transfer of personal information to data recipients in countries outside of the European Economic Area (“EEA”), the United Kingdom and Switzerland. To the extent that these data recipients are in countries that have not been recognized by the European Commission or relevant body as providing an adequate level of data protection, we ensure that appropriate safeguards aimed at ensuring such a level of data protection are in place, including by entering into the European Commission’s EU Standard Contractual Clauses (“SCCs”) and, where applicable, the UK Addendum to the EU SCCs, with the data recipients. To obtain a copy of the safeguards we have put in place, please contact us as indicated below.

Data Security

We maintain administrative, technical and physical safeguards designed to protect the personal information we obtain against accidental, unlawful or unauthorized access, destruction, loss, alteration, disclosure or use.

Data Retention

We keep your personal information for the duration of our relationship, plus a reasonable period to comply with the applicable statute of limitations or if otherwise required under applicable law, unless a shorter retention period is required by applicable law.

Your Privacy Rights

Depending on where you are located and subject to applicable law, you may have the following rights in connection with the personal information we process about you:

• The right to access and obtain a copy of your personal information;
• The right to correct inaccuracies in information we have about you;
• The right to object to the processing of your personal information on grounds relating to your particular situation;
• The right to have your personal information “erased” or to restrict the processing of such information; or
• Where you have given us your consent, the right to withdraw consent at any time for future processing of your information.
• The right to request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.

You can tell us at any time not to send you marketing communications by e-mail by clicking on the unsubscribe link within the marketing e-mails you receive from us. You may also request not to be contacted by us in connection with any new services, updates, news, or events by contacting us as described below.

If you wish to exercise any of these rights, email [email protected] and your BTIG representative, and we will respond to your request in a reasonable time. You may have the right to file a complaint with a supervisory authority if you are not satisfied with our response.

If you are a California resident, please see our California Consumer Privacy Statement for more information about your privacy practices and your rights and choices.

Third-Party Websites and Services

Certain third-party services or websites you use or navigate to from our site (such as social media sites) may have separate user terms and privacy policies that are independent from this Notice. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website and/or application prior to using it.

Children’s Privacy

Our services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from anyone under the age of 18, including children under the age of 16. If you believe that a child under the age of 16 may have provided us with personal information, please contact us at [email protected], and we will promptly delete that information from our records.

Changes to this Notice

This Notice was last updated on the date provided at the top of the page. Please note that we review and modify our Notice and other policies from time to time, and that these policies, and our collection and use of your information, are therefore subject to change. Your continued use of the website following the posting of a revised Notice means that you acknowledge and accept the changes. You will receive appropriate notice of substantial changes to our Notice, and you are responsible for periodically visiting this page to check for any changes or updates.

Contact Us

To contact us regarding this Notice and/or our privacy practices, including to make a complaint, you may contact our Data Protection Office by using any of the following:

• Email at [email protected]
• By phone at 1-415-248-5100
• By mail at:
  InfoSec Department
  BTIG, LLC
  600 Montgomery Street, 6^th Floor
  San Francisco, CA 94111

BTIG, LLC is the entity responsible for the processing of personal information in connection with this site. If you are a client, the BTIG entity responsible for the processing of your personal information is the entity with which you have a direct relationship. Please contact your BTIG representative or use the contact details for the relevant entity as described here.

CALIFORNIA CONSUMER PRIVACY STATEMENT

Last Updated: May 31, 2023

This California Consumer Privacy Statement supplements the BTIG Privacy Notice and applies solely to personal information BTIG collects about California consumers, such as BTIG clients, website visitors, job applicants and business partners. This California Consumer Privacy Statement does not apply to personal information collected about BTIG personnel.

This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020), and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information

BTIG may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you:

• Identifiers: identifiers, such as real name, alias, postal address, unique personal identifier (such as device identifier; cookies, beacons, pixel tags, and similar technology; client number, unique pseudonym, user alias/ID, telephone number, and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, state identification card number, education, bank account number, credit card number, debit card number, other financial information;
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status;
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications ;
• Sensory Information: audio, electronic, visual, and similar information;
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information;
• Education Information; and
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

BTIG may use (and may have used during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) your personal information for the purposes described in the BTIG Privacy Notice and for the following business purposes:

• Performing services, including: maintaining or servicing accounts, providing client service, processing or fulfilling orders and transactions, verifying client information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing marketing services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient uses;
• Helping to ensure security and integrity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
• Managing career opportunities with BTIG; and
• Managing our relationships with current or prospective clients, vendors and other business partner personnel.

BTIG does not collect or process sensitive personal information with the purpose of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain your personal information as described in the “Data Retention” section of the Privacy Notice.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, BTIG may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us;
• Your devices, such as when you use our services;
• Our affiliates;
• Service providers, contractors and other vendors who provide services on our behalf;
• Clients or other business partners;
• Data analytics providers;
• Internet service providers (“ISPs”);
• Operating systems and platforms;
• Government entities;
• Social networks;
• Job applicant references; and
• Data brokers, such as credit bureaus, credit reporting service providers and background check services.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, BTIG may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities, job applicant references, and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.

We do not sell or share for cross-context behavioral advertising purposes personal information about California consumers.

California Consumer Privacy Rights

You may have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request.

To submit an access, correction, or deletion request, please email us at [email protected] or call us at (833) 248-2375. To submit a request as an authorized agent on behalf of a California consumer, please email us at [email protected] with the subject line Authorized Agent Request. For questions or concerns about our privacy policies and practices, please contact us as described in the “Contact Us” section of the BTIG Privacy Notice.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. We may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction of or deletion of your personal information, we may verify your identity by requiring you to authenticate your email address or providing information about your transactions or prior interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you submit a request through an authorized agent, we may ask for your written permission or a power of attorney. Where you provided your authorized agent with a written permission, we may require that you also verify your identity.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. Please contact [email protected] if you have any questions about this Statement or our information practices.