BNK Research LLC (“BNK,” “us,” or “we”) recognizes that the privacy and security of your Personal Information (as defined more fully below) is important to you.
SPECIAL MESSAGE TO PERSONS IN THE EU, SWITZERLAND, THE UK, AND ELSEWHERE OUTSIDE THE U.S.:
• We recognize that individuals (“data subjects”) subject to the protections of the EU General Data Protection Regulation (“GDPR”)1 have specific rights provided by the GDPR related to their Personal Information, including, subject to certain exceptions: (1) the right to be informed regarding the collection and use of your personal information; (2) the right of access; (3) the right to correction; (4) the right to erasure; (5) the right to restrict processing; (5) the right to data portability; (6) the right to object; and (7) rights in relation to automated decision-making and profiling2. If you are an individual “data subject” subject to the protections of the GDPR and would like to assert those rights with regard to your Personal Information processed by BNK, you may contact us at firstname.lastname@example.org. We will respond to your inquiry within 30 days.
This Site is not targeted toward, and we do not seek or desire to collect information from, persons under the age of 21. We will not knowingly request information from persons under such age. You agree not to provide any Personal Information to us related to any person under the age of 21.
Types of Information We Collect
In order to better provide you with the various features and functions of our Site and our Services, we collect the following types of information about our users:
• Personal Information3: This refers to information that lets us know the specifics of who you are, sometimes referred to as personally identifiable information. When you engage in certain activities on this Site, such as registering for an account, downloading content made available to you, purchasing or subscribing to our Services, submitting content and/or posting content to a forum or blog (subject to the “Blog or Forum Posts” below), or sending feedback, we may ask you to provide certain information about yourself. Examples of Personal Information, include, but are not limited to, your first and last name, email address, mailing address (including zip code), telephone/facsimile numbers, and other identifying information, including the credit card number we may ask you to provide when you establish an account or subscribe to our Services.
• Aggregate Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analyzed on both a personal and an aggregated basis. This information may include a website’s Uniform Resource Locator (“URL”) that points to the website you came from, which URL you go to after visiting our Site, what browser you are using, and your Internet Protocol (“IP”) address.
How We Collect and Use Information
We do not collect any Personal Information about you unless you voluntarily provide it to us. However, you may be required to provide certain Personal Information to us when you elect to use certain Services available on the Site. These may include: (a) registering for an account; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting a form or transmitting other information by telephone or letter; or (e) submitting your credit card or other payment information when ordering and purchasing Services. When processing certain information, such as payment information with affiliated banking institutions or payment processors, we encrypt the transaction, using Secure Socket Layer (“SSL”) encryption technology, in order to help prevent your Personal Information from being stolen or intercepted. Additionally, your credit card information is encrypted and stored on a restricted-access database and only accessible by authorized personnel.
BNK or its advertising partners (“Advertising Partners”) may collect certain Aggregate Information. For example, we may use your IP address to diagnose problems with our servers, software or hardware, and/or to gather demographic information. Our Advertising Partners may also provide us with aggregate, but not individual, reports that will tell us how many advertisements were presented and clicked upon at our Site.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Site may not function properly if you elect to disable cookies.
Release of Information
We will not sell, trade, or rent your Personal Information to others. We do provide some of our Services through contractual arrangements made with affiliates, service providers, partners and other third parties (collectively “Service Partners”). We and our Advertising Partners or Service Partners may need to use some Personal Information in order to perform tasks between our respective websites, or to deliver Services to you. For example, we must release your credit card information to the card-issuing bank to confirm payment for Services purchased on this Site; release your address information to the delivery service to send any products you may order; and provide order information to third parties that help us provide customer service.
Occasionally, we may be required by law enforcement or judicial order to provide Personal Information to the appropriate governmental authorities. In such cases, we will disclose Personal Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. Please see the “Compliance with Legal Requirements and Corporate Transactions” below.
We may also provide Aggregate Information about our customers’ sales, traffic patterns, and related Site information to third party advertisers, but these statistics do not include any Personal Information.
Updating and Correcting Information
You have the ability to access and edit the Personal Information that you have provided us. You may change any of your Personal Information in your account online at any in accordance with instructions posted elsewhere on this Site. You may also access and correct your Personal Information and privacy preferences by emailing or writing to us. Please see the “Contacting BNK/SaferBankingResearch” section below:
We encourage you to promptly update your Personal Information if it changes. You may ask to have the information on your account deleted or removed. However, some information, such as past transactions, logs of technical support calls, or other information may not be deleted. In addition, if you wish to remain a subscriber to our Services, we will need to retain those elements of your Personal Information necessary to support an active account, such as contact information and financial and payment information (e.g., credit card). Under any circumstances, as is the case with virtually all information stored in digital form, it may be impossible to completely delete your information without some residual information retained in data backups.
User Choices on Collection and Use of Information
We may, from time to time, contact you by phone, email, or text message, regarding offers or information concerning products or services that may be of interest to you, whether offered by us, our affiliates or our business partners. Only BNK, its affiliates or their respective personnel or agents working on their behalf, will send you the offers or information, and only if you have previously indicated that you wish to receive them. If after opting in you do not want to continue to receive offers or information from us, you can “opt-out” by accessing and editing your account online.
In addition, you have options with respect to cookies as described above. Most browsers allow you to set cookie preferences, such as electing to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of the Site may not work properly.
Security of Your Personal Information
BNK takes reasonable steps to protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures. For example:
• We work hard to ensure that the data we collect is reliable, accurate, complete and current. The elements of our Site and Services which permit the communication of Personal Information provide for encrypted transmission of such information.
• We limit access to Personal Information only to specifically authorized employees, contractors and agents who have a reasonable need to access it. For example, we may provide members of our technical support team with limited access to your account in order to allow them to troubleshoot problems you may be having with the Site or our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including, but not limited to, termination and criminal prosecution, if they fail to meet these obligations.
• Additionally, we also employ a number of physical, electronic, and procedural safeguards to protect Personal Information. Our servers and datacenters are protected by industry-standard encryption, and our servers reside behind firewalls and employ high-level password protection.
• Finally, we allow you to access all of your Personal Information (for additional security, we display to you only the last four digits of your credit card information), through a unique password and customer ID selected by you. These log-in credentials are encrypted during transmission and at rest. We recommend that you do not divulge your password to anyone (you are responsible for all activity that occurs under your customer ID and password).
In order to most effectively serve you, credit card transactions and order fulfillment are handled by established third-party banking institutions and processing agents (e.g., PayPal). They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order. Use of these third party services will be governed by their posted terms and conditions and privacy policies.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet, which are beyond our control; and (b) the security, integrity, and privacy of any and all information exchanged between you and us through this Site cannot be guaranteed.
Sensitive Personal Information
We have no need for any sensitive Personal Information from you in order to provide our Service, and we take no steps to collect it. Sensitive Personal Information means data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation. You agree not to provide any sensitive Personal Information to us.
Compliance with Legal Requirements and Corporate Transactions
Blog or Forum Posts
To request removal of your Personal Information or postings from our blog or discussion forums, please contact us as described in the “Contact BNK/SaferBankingResearch” section below. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
A Publication of BNK Research LLC
3470 Olney Laytonsville Rd., Suite 226
Olney, MD 20832
Attn: Privacy Compliance Officer
Please include your name, address, and/or email address when you contact us.
(1) See http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN and https://ec.europa.eu/info/law/law-topic/data-protection_en.
(2) See Articles 12-22, GDPR.