PRIVACY NOTICE FOR BRAUN CAPITAL
Please read the following below carefully.
Last Updated: February 1, 2024
We at Braun Capital Inc., including our relevant local entities listed in Appendix A (“Braun Capital“), respect your concerns about privacy. This Privacy Notice describes how we process the Personal Data:
that we collect on Braun-Capital.com and other websites or applications that may link to this Privacy Notice (the “Sites“);
where you visit our premises;
where you are a contact at one of our suppliers or other business partners; and
through other data collection points or notices that reference this Privacy Notice.
We provide information on the types of Personal Data we collect, how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. “Personal Data” has the meaning given to it under data protection laws that apply to our processing of your information and includes any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).
If you are a California consumer, please see the section below of this Privacy Notice called “California Consumer Privacy Statement” which supplements this Privacy Notice.
Information We Obtain
The types of information we collect concerning individuals includes:
business and personal contact information (such as name, postal and e-mail addresses, and telephone number);
demographic information, such as age, race, gender, and citizenship;
account information, including login credentials for our Investor Portal and on our career site;
financial and other information you provide, such as date of birth, banking information, account numbers, taxpayer ID number, jurisdiction of tax residence, and certain investment-related information;
government-issued identifiers and other information we need in order to identify you and complete necessary security and safety checks, including in connection with our products and services and where you visit our premises;
CCTV footage on our premises for the purposes of safeguarding our customers and employees and our facilities and property;
content (and related information) in connection with your electronic communications with us or our service providers (including by e-mail or other forms of electronic communication);
professional details and employment data in connection with job inquiries or applications on our careers pages, such as resume/CV, current or past employment history, performance-related information (e.g., performance evaluations), talent management information (e.g., education history, professional designations, qualifications and other information about your background) and work authorization status;
voluntary information you provide in connection with job inquiries or applications on our careers pages, including information about your political contributions (not applicable if you are based in the European Union or the United Kingdom), and diversity-related information, such as gender, race/ethnicity, sexual orientation, veteran status and disability status;
information from third-party data providers and publicly available sources for compliance with anti-money laundering obligations, background screening and to otherwise protect our business and comply with our legal and regulatory obligations;
information from our charitable foundation, such as details relating to your involvement with our philanthropic and charitable causes, and your charitable contributions;
information from organizations that you represent and with which we have a business relationship, such as your business contact details or details of your role at the organization; and
other information you provide to us (such as information provided by registering for e-mail alerts, filling in forms, and online registration details).
If you provide information to us about another person, you should ensure that you provide that person with this Privacy Notice and comply with any legal obligations that may apply to your provision of the information to us.
Information We Obtain by Automated Means
When you visit our Sites or open our e-mails, we may collect certain information by automated means (such as by cookies, web server logs, web beacons and JavaScript). The information we collect in this manner includes your IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our Sites, and dates and times of website visits. Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device – please see our Cookie Policy for information about what cookies are and how we use cookies and similar technology. We also may use these and similar technology in e-mails we send you to collect certain information, such as whether you opened or clicked on links in our e-mail and what content was interesting to you.
Our Sites may use cookies (such as HTTP, HTML5 and Flash cookies) as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all the features of our Sites or other websites and services.
In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you used to connect to our Sites. We may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons”, which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Sites.
We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyze how visitors use the Sites, including attributing site interactions to known contacts who have subscribed to receiving communications from us. The information processed for this purpose (including your IP address, CRM ID/BX ID and other information collected by automated means) may be disclosed to or collected directly by these service providers.
The providers of third-party plugins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.
How We Use the Information We Obtain
We may use, disclose or otherwise handle the information described in this Privacy Notice for the following purposes to:
operate, evaluate, develop, promote, and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; managing our premises; and performing accounting, auditing and other internal functions);
create and manage your account;
manage your investments;
comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
protect against, identify and prevent fraud, money-laundering, breach of confidence, cyber attack, theft of proprietary materials, financial or business crimes, and other unlawful activity;
in some cases, in order to operate, administer and improve the user’s experience of the Sites;
provide our products and services to you, such as market commentary and e-mail alerts;
send you (or produce) promotional materials, newsletters and other communications, including in visual and audio form (such as videos, podcasts and seminars);
communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
respond to your inquiries;
manage your employment application, assess your qualifications and manage your employment with us –
please see our Job Applicant Privacy Notice for full information about how and why we use your Personal Data in this context;comply with US Equal Employment Opportunity reporting requirements and similar legal and compliance obligations – note that Braun Capital will not consider any voluntary information you provide in connection with a job inquiry or application or your choice to decline to provide such information in evaluating your qualifications for employment;
verify your information;
perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information);
operate, schedule and facilitate online meetings, webinars and (video) conferences (for example, using Zoom and other online meeting platforms);
record and monitor details and content of your electronic interactions with us or our service providers, to the extent permitted or required by applicable law; and
record audio and video content (for example, of our in-person or online events, training, and meetings where permitted by, and collected in accordance with, applicable data protection law).
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our Sites, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Sites, and (iii) managing our Sites and other aspects of our business.
CCTV operates in some of our buildings for security and safety purposes, in accordance with applicable data protection law. Where CCTV is not operated by us, the CCTV will be under the control of the relevant building landlord, manager or operator.
We may also use the information in other ways for which we provide specific notice at the time of collection.
We will only process your Personal Data as necessary so that we can pursue the purposes described above. Where we process your Personal Data for our legitimate interests as a business or those of a third party, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
When we collect Personal Data from you, unless indicated otherwise, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.
If you are a former employee, worker, contractor or member of Braun Capital, we will continue to process your Personal Data for a reasonable period following the end of your employment or engagement for our legitimate business and/or our legal compliance purposes and/or for the establishment or defense of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g., to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further below).
Online Tracking and Interest-Based Advertising
We and third parties acting on our behalf (such as Facebook, Twitter and LinkedIn) may collect information about your online activities over time and across third-party websites to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes. If you do receive direct marketing communications from us (for example, by post, e-mail, fax or telephone), you may opt-out by clicking the link in the relevant communication, completing the forms provided to you (where relevant).
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Sites and on
third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts and tailor content relevant to your interests..
The Sites are not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/
Information We Disclose to Others
We do not disclose Personal Data we obtain about you through the Sites or other channels covered by this Privacy Notice, except as described in this Privacy Notice. We may share your Personal Data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we also share Personal Data with service providers who perform services on our behalf (including cloud services), our financial and transaction counterparties, Philanthropic, charitable and advocacy partners, our professional advisors, and your agents and representatives. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements.
We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer Personal Data we have about you or otherwise process in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
In addition, we may share anonymous / aggregated information with third parties, such as service providers, in order to facilitate our business operations.
Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and Braun Capital is not responsible for those providers’ information practices.
Data Transfers
We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information was originally collected. Where you are based in the UK, the EU, or another country which imposes data transfer restrictions outside of its territory, this includes transfers outside of the UK and the European Economic Area (“EEA“) or that geographical area, including to those countries in which our affiliates, group members, service providers and business partners operate, such as the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK, the EEA, or other territories subject to data transfer restrictions to other members of the Braun Capital group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements or safeguards, designed to ensure that your Personal Data is protected as required under applicable data protection law (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission or by obtaining your consent).
Retention and Deletion of Your Information
We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it. We retain your Personal Data for as long as it is required by us for our legitimate purposes, to perform our contractual obligations, or where longer, such longer period as is required or permitted by law or regulatory obligations which apply to us.
We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
Note that we may retain some limited information about you (even when we know that you have left the organization that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
Your Rights and Choices
We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Notice. To the extent provided by the law of your jurisdiction or otherwise applicable to our processing of your information, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward.
These rights, subject to certain limitations, may include:
Rights of access, correction and deletion. You may have a right of access to the Personal Data that we hold about you, and to some related information, including the purpose for processing the Personal Data, the categories of recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collected directly from you, the source. You may also have the right to require any inaccurate Personal Data to be corrected or deleted.
Right to object, and portability. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require it to be deleted) in some other circumstances. In some circumstances, you may also have a “data portability” right to require us to transfer your personal data to you or a third party, in a data portable format.
We review and verify requests to protect your Personal Data, and will action data protection requests fairly and in accordance with applicable data protection laws and principles.
If you wish to exercise any of these rights, please contact us as set out below.
Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called “California Consumer Privacy Statement.”
How We Protect Personal Data
We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Links to Other Websites
Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
Updates to Our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated. Please check for any updates regularly.
How to Contact Us
You may write to:
Braun Capital
Attn: Legal & Compliance
228 Park Avenue South #96890
New York, NY 10003
Please also contact us via any of the above methods if you have a disability and require an alternative format of this Privacy Notice.
Appendix A
For purposes of our Privacy Notice and Investor Data Privacy Notice, below are country-specific contact details for the relevant local Braun Capital entities. References in the Privacy Notice to “we”, “us”, “our” and “Braun Capital” are references to the relevant entity below, which is responsible for the processing of your Personal Data.
Braun Capital Inc. California Consumer Privacy Statement
Last updated: June 30, 2023
This California Consumer Privacy Statement (“Statement”) supplements the Privacy Notice. It applies solely to California consumers, which includes visitors to our premises and our public-facing websites and mobile apps, Braun Capital job applicants and representatives of our suppliers and business partners.
This Statement does not apply to (1) Braun Capital personnel, their emergency contacts or their relatives for whom we administer benefits; or (2) information collected, processed or disclosed in connection with the provision of financial products or services pursuant to the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act.
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).
Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, e-mail 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, and financial information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender expression, sexual orientation, medical condition, citizenship status, and military and veteran status
Commercial Information: commercial information, including records of 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, or advertisements
Sensory Information: audio, electronic, visual, thermal and similar information
Employment Information: professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), work authorization status, talent management information (e.g., résumé information, current or past employment history, performance evaluations, education history, professional designations and qualifications, and other information about your background)
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
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA/CPRA:
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services
Providing advertising and marketing services to you, except for cross-context behavioral advertising
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us
Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes
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 a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement.
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 will retain your personal information as described in the “Retention and Deletion of your Information” section of our Privacy Notice.
Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we 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 visit our websites or mobile apps
Our affiliates and subsidiaries
Vendors who provide services on our behalf
Professional services organizations, such as auditors, accountants and law firms
Our business clients and partners
Philanthropic, charitable and advocacy partners
Our portfolio companies
Other individuals, such as in connection with a referral
Recruiting and talent agencies
Data analytics providers
Government entities
Social networks
Publicly accessible databases
Data brokers, such as credit reporting agencies and background check services
Sale or Sharing of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared 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 to online advertising services:
Identifiers
Commercial Information
Online Activity
Inferences
We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with: (1) government entities, such as law enforcement authorities and regulators; (2) self-regulatory organizations; and (3) third parties in connection with an actual or proposed corporate transaction, such as a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation.
California Consumer Privacy Rights
You 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 about you during the past 12 months.
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.
Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
How to Submit a Request. To submit an access, correction or deletion request, you can call 212-287-7858. You can opt out of the sale or sharing of your personal information by using the “Do not Sell or Share my Personal Information” link in the footer of each page of our Sites or using the Global Privacy Control signal. To submit a request as an authorized agent on behalf of a consumer, contact us at 212-287-7858. For questions or concerns about our privacy policies and practices, contact us at 212-287-7858
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 request. If you request access to, correction of or deletion of your personal information, we may require you to verify your e-mail address or certain of your information in our records, such as your name, e-mail address, mailing address, phone number, company name and job-details, or other information about your 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.
Additional Information. If you choose to exercise any of your rights under the CCPA/CPRA, 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.