Privacy notice

Backstop Solutions Group, LLC and Backstop Solutions UK, Ltd (“BSG”) provide software solutions to financial institutions around the world.  These include Backstop Suite (formerly Backstop) and Backstop Portal (formerly InvestorBridge).  BSG also provides data to institutional investors, including performance metrics concerning various investments and funds, through its BarclayHedge data offering.

When BSG receives information for its own purposes, such as the contact or billing information of clients or, with respect to BarclayHedge, information regarding investment and fund managers, the processing of that information is described by this privacy notice.  When BSG receives or processes information on behalf of one of its clients, or hosts a website or online portal on behalf of one of its clients, BSG does not determine what information is collected, how it is used, or with whom it is shared.  The privacy practices that apply to such information are described in the privacy notice of the client that retained BSG.

Types Of Information We Collect
Use And Processing Of Information
Sharing Of Information
Your Choices
How We Protect Personal Information
Miscellaneous
Contact Information

Types Of Information We Collect

The following provides examples of the type of information that we collect on our own behalf and describes how we use that information. 

Context	Types of Data	Primary Purpose for Collection and Use of Data
BSG Account Information and Information about Clients	We collect the name, and contact information, of our clients and their employees with whom we interact.	We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.
BarclayHedge Account Information and Information about Clients	We collect the name, and contact information, of our clients and their employees with whom we interact.  We may also collect credit card information when someone is subscribing to one of our services.	We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.  We also use information to perform our contracts with clients, such as to process a credit card transaction for payment.
BarclayHedge Data and Research	We collect name and contact information about the managers of hedge funds and other investment vehicles, as part of creating performance related information regarding their current or past financial products. We gather such information from a number of sources including publicly available directories and websites on the internet.	We have a legitimate interest in creating a database of performance rankings and information regarding hedge funds and other managed funds which includes information concerning the individuals responsible for managing those funds, and we have a legitimate interest in providing access to that database for our clients to perform their own research.  When a client of BarclayHedge performs research in one of our databases, or exports information from one of our databases, they are responsible for determining the permissible purpose for which they use the information and for complying with all data privacy laws.
Client’s Information	We provide software solutions to financial institutions.  In that role we may receive personal information from one of our clients.	As is discussed above, when we receive personal information from one of our clients in order to carry out a project or a service for them, our client determines the purpose for which the information was collected and how we should use it.
Conferences, Events, and Trainings	If you register for one of our events, or conferences, we may collect information relevant to your attendance, such as your name, contact information, company affiliation, and industry interests.	We have a legitimate interest in managing the attendance at our events and conferences and providing you with content and information that may be relevant to your interests, or that may relate to our products and services.  We may also use your information to solicit feedback concerning the conference, event, or training.  We may also solicit your consent to share your information with conference sponsors to allow them to contact you directly about their products or services that may be of interest to you.
Cookies and First Party Tracking	We use cookies and other tracking technology. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.	We have a legitimate interest in making our website operate efficiently.
Cookies and Third Party Tracking	We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.  You can use the following link to change your cookie preferences, and see the types of cookies that we utilize: here. To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: - Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based "AppChoices" download page (https://youradchoices.com/appchoices ) - European Interactive Digital Advertising Alliance (EDAA), consumer opt-out page (http://youronlinechoices.eu) - Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/).	We ask for your consent to use third party tracking technology, and to provide your information to the companies that provide such technology.
Employment	If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee.  This may include, among other things, your Social Security Number.  Providing this information is required for employment.	We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you.  In some contexts, we are also required by law to collect information about our employees.  We also have a legitimate interest in using your information to have efficient staffing and work force operations.
Feedback/Support	If you provide us feedback or contact us for support or information we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.	We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Informational interviews relating to your decision whether to retain us	We may conduct a survey or interview, or retain a third party to conduct a survey or interview, regarding your decision to retain, or not retain our services.	We have a legitimate interest in understanding the decisions of third parties to retain, or not retain, our services.
Mailing List	When you sign up for one of our mailing lists we collect your email address or postal address.	We have a legitimate interest in sharing information about our products or services.
Online Registration	We collect your name and contact information when you create an online account.  We also may allow you to provide demographic and professional information as part of creating a profile.  We also collect information relating to the actions that you perform while logged into your account.	We have a legitimate interest in providing account related functionalities to our users, and tailoring our services and offerings depending upon user demographics and professional traits.
Surveys	When you participate in a survey we collect information that you provide through the survey.  If the survey is provided by a third party service provider, the third party’s privacy notice applies to the collection, use, and disclosure of your information.	We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites, and analyzing website traffic trends.
Whitepapers	When you request a whitepaper, or information concerning a financial topic or service, we collect your contact information.	We have a legitimate interest in using your contact information to deliver the requested document, and to better understand the demographics of individuals that are interested in our publications and services.

In addition to the information that we collect from you directly, or from our clients, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.  For example, if you submit a job application, or become an employee, we may conduct a background check.

Use And Processing Of Information

In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our websites.
• To provide products and services.
• To improve our services and product offerings.
• To conduct analytics.
• To respond to inquiries related to support, employment opportunities, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, or promotions.
• For information reported to us to be included in BarclayHedge databases, we may provide the information to third parties who may contact you regarding their products or services.
• For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you retain us to provide a web-based platform we may collect your information to perform our contract with you, but we also collect your information because we have a legitimate interest in understanding who are clients are and what services we perform on their behalf.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

1. Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or is considering acquiring, our company, business, or our assets, we will also share information with that company.  In such an event, you will be notified via email and/ or a prominent notice on our website of any change in ownership, incompatible new uses of personal information, and choices you may have regarding your personal information.
2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for shipment using third party intermediaries.
4. Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, and process payments. These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions.

Your Choices

You can make the following choices regarding your personal information:

1. Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive, or by contacting us using the information provided below.  If you decide not to receive promotional emails, we may still send you service related communications.
2. Access To Your Personal Information. For information that we collect on our own behalf we will grant you, where required by law, reasonable access to the personal information that we have about you. You may request access to your personal information by clicking here or calling (888) 720-0299.  If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions on whether access should be granted.
3. Changes To Your Personal Information. You can contact us by clicking here or calling (888) 720-0299 in order to request that your information be modified. If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions on any changes that they believe are appropriate.
4. Deletion Of Your Personal Information. We typically retain personal information that we collect on our own behalf for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may request information about how long we keep a specific type of information, or request that we delete your personal information, by clicking here or calling (888) 720-0299.  If we are processing your information on behalf of one of our clients we will forward your request to that client and await instructions from them on whether your information should be deleted.
5. Revocation Of Consent or Objections. You may revoke consent to processing (where our processing is based upon consent), or object to our processing (where our processing is not based upon your consent) by contacting us at the address described below.  If you revoke your consent / object we may no longer be able to provide you services. In some cases we may limit or deny your request to revoke consent / object if the law permits or requires us to do so, or if we are unable to adequately verify your identity.  If we are processing your information on behalf of one of our client we will forward a revocation of consent to that client and await instructions from them on whether the processing to your information should cease.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

Miscellaneous

The following additional information relates to our privacy practices:

• Transmission of Information to Other Countries. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. We participate in, and have certified compliance with, the EU-U.S. Privacy Shield Framework (“EU Privacy Shield") and the Swiss-U.S. Privacy Shield Framework (“Swiss Privacy Shield”).  As part of that certification we have committed to subjecting all personal data received from European Union (EU) member countries and Switzerland in reliance on the EU Privacy Shield, and Swiss Privacy Shield, respectively, to the applicable framework’s Principles, and to be liable for any third parties that receive data on our behalf, if they act contrary to the principles of the EU-US Privacy Shield or Swiss-US Privacy Shield, unless we prove that we are not responsible for causing those actions.  With respect to personal data received or transferred pursuant to EU Privacy Shield and Swiss Privacy Shield, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we 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.  To learn more about the EU Privacy Shield and Swiss Privacy Shield frameworks, visit the U.S. Department of Commerce's Privacy Shield List. [https://www.privacyshield.gov/list]. 
• Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose”, as those terms are defined under California law. You can find a list of the categories of information that we collect and share here.  Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself.  For example, we collect many types of information about our employees that we do not collect about other people. 
• Changes To This Privacy Notice. We may change our privacy notice and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy notice. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information.  If you have any questions, requests, comments, or complaints concerning our privacy practices please contact us at the appropriate address below.  We will attempt to respond to your requests and to provide you with additional privacy-related information.

If you are not satisfied with our response, you may have a right to lodge a complaint with your local data protection agency.

Effective Date: February 20, 2020