Last modified: June 29, 2021
BROWN GIBBONS LANG & COMPANY:
- Children Under the Age of 16
- Information We Collect About You and How We Collect It
- Information You Provide to Us
- Information We Collect Through Automatic Data Collection Technologies
- How We Use Your Information
- Disclosure of Your Information
- Choices About How We Use & Disclose Your Information
- Assessing & Correcting Your Information
- Your California Privacy Rights
- Data Security
- Rights of European Economic Area (EEA) Citizens
- Contact Information
Brown Gibbons Lang & Company and its affiliates (collectively, “BGL,“ “Company,“ “we,“ or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.bglco.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect:
- On this Website.
- In e-mail, text, and other electronic messages between you and this Website.
- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- On our social media pages.
- When you correspond, or otherwise interact, with our members.
- When you register or attend an event or webinar sponsored by us.
- By information that we collect, receive, or generate in connection with our business, professional, and consulting operations (collectively the “Services”).
It does not apply to information collected by:
- us offline or through any other means not listed, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact BGL’s Data Protection Officer, Lynn Basconi, at email@example.com.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, fax number, or ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”);
- that is about you but individually does not identify you, such as job title; or
- about your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service or requesting further services. We may also ask you for information when you report a problem with our Website.
- Information you provide that is necessary to facilitate your access to, use of, or participation in our service offerings in which you have expressed interest, including, but not limited to: email alerts, content downloads, events, and our Careers page.
- Records and copies of your correspondence including e-mail addresses, if you contact us.
- Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please contact BGL’s Data Protection Officer, Lynn Basconi, at firstname.lastname@example.org for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies: Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons: Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
You have the option of setting your computer to disable cookies or to alert you when cookies are being used. If you choose to disable cookies, please be aware that portions of BGL.com may not function properly. To learn more about cookies, visit resources such as http://www.allaboutcookies.org.
We use Google Analytics and other third-party services, such as Campaign Monitor and bit.ly, to automatically collect information from individuals for our internal analytics purposes. We use this information primarily to optimize the website, and to understand our audience, for example, to count how many individuals visit the website, where visitors come from, and how they arrive at the website. These service providers are not permitted to use this information for their own purposes.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with information, products or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To notify you of BGL official news, activities, programs, events, and services, or otherwise engage in marketing activities.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including responding to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of BGL, our customers or others.
Choices About How We Use and Disclose Your Information
Personal information may be given to a third party in order to complete a specific business transaction on behalf of BGL. Such transactions may include the following:
- Your name and contact information, as provided to BGL, may be shared with BGL employees in order to provide a service, satisfy a question, or develop a prospective business relationship.
- We may share your personal information with third parties that provide services to BGL, including, but not limited to, marketing and communications; program or event enrollment; database management; or other data processing, including Google, with which we share Google Analytics data.
- We also may disclose personal information if we become subject to a subpoena, court order, or law enforcement or other government agency inquiry or investigation or if we are otherwise legally required to disclose such information. We also may use and disclose information about you to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.
BGL does not disclose an individual’s personal information to third parties, except when one or more of the following conditions is true:
- The disclosure is required by law or mandatory professional standards;
- The disclosure is to another BGL entity or to persons or entities providing services on our or the individual’s behalf (each a “transferee”), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
- Is subject to law providing an adequate level of privacy protection;
- Has agreed in writing to provide an adequate level of privacy protection; or
- Subscribes to the Safe Harbor Principles published by the U.S. Department of Commerce.
Accessing and Correcting Your Information
BGL takes your privacy and the protection of your personal information seriously, and we will provide you with reasonable access to and control of the personal information that you have provided to us. You may request to update your personal information, or to opt-in to or opt-out of any service offerings, at any time. If you do not want to access or correct your information in this way, please contact BGL’s Data Protection Officer, Lynn Basconi, at email@example.com.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to BGL’s Data Protection Officer, Lynn Basconi, at firstname.lastname@example.org or write us at: Brown Gibbons Lang & Company, One Cleveland Center, 1375 East 9th Street, Cleveland, Ohio 44114.
California laws require operators of websites or similar services to make certain disclosures to individuals who reside in California regarding their rights, specifically:
- Shine the Light: Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed personal information that is primarily used for personal, family or household purposes to a third party for the third party’s direct marketing purposes, must disclose to its Californian individuals, upon request, the identity of any such third party, along with the type of personal information disclosed. We do not share any personal information with third parties for their direct marketing purposes.
- Do-Not-Track: Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to individuals how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law. In the meantime, there are technical means to prevent some of the tracking, if any.
- Consumer Rights Notice: Under California Civil Code Section 1789.3, California users are entitled to the following specific consumer rights notice: If you have a question or complaint regarding the website, please send an email as indicated in the “Contact Information” section.
California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at +1 916.445.1254 or +1 800.952.5210.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. BGL has technological and operational security functions in place to protect personally identifiable information from loss, misuse, alteration or destruction. The data you may provide via the United States website is shared only with authorized employees of BGL, and on a limited basis, with vendors who help us manage our website, supply information management services, and third parties in association with any BGL-related events. Access to your information is limited by need, and those who have access to the data have agreed to maintain the confidentiality of such information. In addition, BGL may disclose personally identifiable information as may be required by subpoena, search warrant, or other legal process.
BGL retains your personal information for as long as necessary to fulfill the purposes for which it was collected as set forth in this Privacy Notice, after which we will securely destroy or delete such personal information from our records unless otherwise required by law. We will retain and use information as necessary to comply with legal obligations, resolve disputes, enforce agreements, and as otherwise set forth in this Privacy Notice
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Rights of European Economic Area (EEA) Citizens
The European Union’s General Information Protection Regulation (GDPR) grants individuals who are in the European Economic Area (EEA) the following rights, with some limitations:
- Right Not to Provide Consent or to Withdraw Consent: We may seek to rely on your consent to process certain personal information. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdrawal.
- Right of Access: You have the right to obtain confirmation as to whether we collect or process personal information concerning you and, if this is the case, you have the right to request a copy of such personal information in digital format.
- Right of Rectification: You have the right to require that we correct any inaccurate personal information concerning you, and that we complete incomplete personal information.
- Right of Erasure: In certain circumstances, you have the right to request that we erase personal information concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.
- Right to Restrict Processing: In certain circumstances, you have the right to request that we restrict the processing of the personal information that we have collected about you; for example, where you believe that the personal information that hold about you is not accurate or lawfully held.
- Right to Information Portability: In certain circumstances, you have the right to receive the personal information concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the information to another entity where technically feasible.
- Right to Object to Processing: In certain circumstances, you have the right to request that we stop processing your personal information.
- Right to Object to the Processing for Direct Marketing Purposes: You have the right to request that we stop sending you marketing communications.
- Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects: In certain circumstances, you have the right no to be subject to a decision based solely on automated processing – including profiling – that produces legal effects or similarly affects you.
- Right to Complain to a Supervisory Authority: You have the right to lodge complaint with a supervisory authority or other dispute resolution mechanism if you believe that our processing of personal information relating to you infringes your rights under Applicable Law.
Individuals may contact BGL’s Data Protection Officer, Lynn Basconi, at email@example.com or write us at: Brown Gibbons Lang & Company, One Cleveland Center, 1375 East 9th Street, Cleveland, Ohio 44114, to exercise any of these rights, and we will respond with the requested action or information or will let you know why that right does not apply to you.
Or write to us by postal mail to:
Lynn Basconi, Data Protection Officer
Brown Gibbons Lang & Company
One Cleveland Center
1375 East 9th Street
Cleveland, Ohio 44114
BROWN, GIBBONS, LANG, & COMPANY SECURITIES, INC.:
Privacy Practices Notice
You do not need to take any action as a result of this notice, but you do have certain rights as described below.
Information We May Collect & Use
We collect information about you, which we may share now or in the future. We do this to help us identify you as our customer or our former customer, to process your transactions and requests quickly, to provide investment services to you or tell you about products or services we believe you may want and use.
Information we collect includes:
• Information from you – When engaging in a transaction with our firm, you may give us information such as your name, address, Social Security number, financial, and employment history.
• Information about your transactions – We may keep information about your transactions with our company, for example, the products you purchase from us.
• Information from our websites – We may obtain information about you from on-line forms, site visitorship data and on-line information collecting devices commonly called “cookies.”
We do not collect medical or health information in providing our financial services.
How We May Treat Your Information
Brown, Gibbons, Lang, & Company Securities, Inc. may share the information described above with our service providers. These providers may require access to information about you to process or service transactions you have requested, to provide efficient customer services, or to inform you of our products or services you may find useful. Our service providers may be affiliated or unaffiliated with us and may include financial service providers (for example, third party administrators, broker-dealers, insurance agents and brokers, registered representatives, companies that perform marketing services on our behalf, reinsurers, other financial institutions with whom we have joint marketing agreements) or non-financial companies and individuals (for example, consultants and vendors). We require these service providers to safeguard your personal information and to use or disclose it only for the services they are performing on our behalf, or as permitted by law.
We may provide information to regulatory authorities and law enforcement officials in accordance with applicable law or to others when we believe in good faith that the law requires it. In the event of a sale of all or part of one of our businesses, we may share customer information related to that business as part of the transaction. Brown, Gibbons, Lang, & Company Securities, Inc. does not sell or share your information with marketers outside our company who may want to offer you their own products and services. Neither do we share information we may receive about you from a consumer-reporting agency. You do not need to take any action for this benefit.
Security of Information
Keeping your information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect your information. Employees are authorized to access your information only when they need it to provide you with products and services.
Making Sure Information Is Accurate
We want to make sure that we have accurate information about you. Generally, upon written request, we will make your personal information available for your review. Information we have collected in connection with or in anticipation of a claim or legal proceeding will not be made available. If you believe that any of our records are inaccurate, you may notify us in writing of any corrections, amendments or deletions that you believe should be made. Questions about accessing or correcting your personal information should be directed to Brown, Gibbons, Lang, & Company Securities, Inc., 1375 E. 9th Street, Suite 2500, Cleveland, OH 44114, (216) 241-2800. Please describe the information you wish to see or corrections required.