Broker Processing Service (“bps”) Privacy Policy
 
bps must ask you to provide us information about yourself and your bank account. This provides bps the ability to operate its services and to reduce the risk of fraud. This Privacy Policy describes the information we collect and how we use that information. bps takes privacy of your personal information very seriously and has provided the terms for this Privacy Policy. We will not sell or rent your personal information or a list of our customers to third parties. However, there are limited circumstances in which some of your information will be shared with third parties, (see Section 5.0 below) under strict restrictions, so please review this Privacy Policy. This Privacy Policy applies to all services offered by bps. Investors accepting the Privacy Policy and Terms and Conditions at registration and brokers at signing of the service agreement, expressly consent to our use and disclosure of your personal and/or business information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the bps Terms and Conditions and brokers Service Agreement. This Privacy Policy will take effect on August 1, 2004.
Please note that your information will be stored and processed on our computers in Avon, Connecticut. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the bps service.
bps will hold and transmit your personal information in a safe, confidential, and secure environment. bps is not responsible for the privacy practices or the content of third party referrals or web site links.
 
1.0 Required Personal Information
To signup for the bps service, you must provide your name, address, phone number, e-mail address, and your bank routing number/ABA number and your account number. In order to move your money through bps, you must provide your US registered bank account number. When faxing in your Authorization Agreement a photocopy of a voided check is necessary to process your transfer. bps asks you to follow all the security requirements as it is necessary for us to process transactions, issue a new password, protect identity theft, checking account fraud, and to contact in administering your service.
 
2.0 Personal Transaction Information
We will retain all transaction information for each transfer through bps. bps will collect your Internet address (IP address) from the computer or device you use to access your bps account, in order to help detect possible instances of unauthorized transactions.
 
3.0 Internal Uses
bps will be using your personal information internally for various functions. Internal uses include:
  1. Verification of your identity
  2. Ability to process your transactions
  3. Ability to provide customer service
  4. Determine your eligibility to receive offers for special features or products
  5. Improve our products and services.
4.0 Investor Verification from Third Parties  
To protect against potential fraud and/or scrupulous activities, bps may verify with third parties the information you provide. As example, when you enter your bank account information on our website, bps may verify your bank information and address given to bps with information that you supplied to your U.S. registered bank account.
 
5.0 Disclosure of personal information to Third Parties
bps will not sell or rent any of your personally identifiable information to third parties. Except in the limited circumstances where bps will request your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared. Some examples of using your personal information are as follows:
  1. Shared information is required with companies that help us process the transactions requested, and help to protect investor transactions from fraud. If by chance a investor balance is negative and money owed to bps, we may share information with processing companies including collection agencies.
  2. We disclose information in good faith as we believe it is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of the Terms and Conditions. Specifically, if bps conducts a fraud investigation and conclude that one side has engaged in deceptive practices, we can give the guilty person or entity's contact information (but not bank account information) to victims who request it.
  3. We must disclose information in response to a subpoena, warrant, court order, levy, and attachment, order of a court-appointed receiver or other comparable legal process, and/or Patriot Act requirements.
  4. We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
  5. It is possible that bps in the future could merge with or be acquired by another company. Upon acquisition, the successor company would have access to information maintained by bps, including customer account information, but bps would insure that this Privacy Policy would be bound until it is amended.
  6. bps may share your information with our parent, subsidiaries and joint ventures to help coordinate any additional or standard services.
6.0 Security
bps is committed to handling our investor/broker information with the highest standard of information security. Bank account information is stored on computers that are not connected to the Internet. Employee access to your identifiable information will be limited to those employees who use the information in order to provide products or services. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. Continual testing of our security systems happen on a regular and timely basis.  bps may with out notice to investors/brokers contract outside companies to audit our security systems and processes.
Each employee of bps must sign an agreement stating that maintaining confidentiality is a condition of employment, and any misuse of information is term for immediate dismissal.
The security of our bps service also relies on your protection of your bps password (Refer to Security Policy for choosing secure passwords). Never send your password or other sensitive information to us via an e-mail.
If you do share or someone has obtained your bps password, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe your password is being used by a third party, please change it immediately by logging into your account and selecting Change Password. Please report any misuse of the bps system by contacting a Banking Service Representative.
 
7.0 Notification of Changes
This Policy may be revised over time as new features are added to the bps service. If we use or disclose your personal or business information differently from what was stated at the time we collected the information, you will have a choice if you wish to disclose your information in this new manner. Any material changes to the Privacy Policy will be effective only after we provide you by e-mail with at least 30 days notice of the amended Privacy Policy.
Any amendments to the Privacy Policy will be displayed prominently on our website for your review; what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the bps website for the most current version of our Privacy Policy.
 
8.0 Contacting investors and/or brokers
bps will communicate with users on a continual basis via e-mail or by phone to provide requested services, to resolve customer complaints or investigate suspicious transactions. Your e-mail address will be used to confirm your opening of your bps service. bps management will send information about changes that will affect the service offering, and send notices and other disclosures required by law. Users will not have the option to opt out of these communications, but they will be primarily informational not promotional.
We may also use your e-mail address to send you other types of communications that you will be able can control. You can choose to receive all or none of these communications.
 
9.0 Contacting Us
If you have any questions about this privacy statement, bps’ information practices, or your transactions, you can contact us via e-mail at info@bpsaccount.com, call (203) 659-0372 Monday through Friday between the hours of 9am and 7pm EST. Your call will be monitored and/or recorded for quality and security.
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