Last updated: February 09, 2022
This Build Asset Management, LLC Privacy Statement (“Privacy Statement”) explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.
A reference to “Build,” “we,” “us” or the “Company” is a reference to Build Asset Management, LLC and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data.
Build Asset Management, LLC is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.
1. Purposes for Collected Data
This Privacy Statement applies to the processing of Personal Data collected by us when you:
- Visit our websites that display or link to this Privacy Statement;
- Visit our branded social media pages;
- Visit our offices;
- Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts, or faxes;
- Use our products and services as an authorized user (for example, as an advisor using one of our strategies) where we act as a controller of your Personal Data;
- Register for, attend or take part in our events, webinars, programs or contests;
- Act as or work for a service provider or Supplier to Build, to the extent Build acts as a controller with respect to your Personal Data;
- Participate in community and open source development; or
- Participate in surveys, research or other similar data collection faciliated by us.
Our websites and services may contain links to other websites, applications, platforms and services maintained by third parties. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.
Please note Processing of Personal Data is required for receiving certain products or services.
2. Types of Personal Data We Collect
2.1 Personal Data we collect directly from you
The Personal Data we collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information, among others. We collect such information in the following situations:
- If you express an interest in obtaining additional information about our services; request client support; user our “Contact Us” or similar features; register to use our websites or to receive communications; sign up for an event, webinar or contest; participate in a program or survey; act as an authorized user for our products and services; or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
- If you register with us for a variety of purposes, including joining an event that we host or participating in a program, we may ask you to provide a username, photo or other biographical information, such as your occupation, location, social media profiles or usernames, company name, areas of expertise and interests;
- If you interact with our websites and emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data (please see Section 3 below) using cookies, web beacons, or similar technologies;
- If you use and interact with our products and services, we collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data (please see Section 3 below)
- If you communicate with us via a phone call, we may record that call in accordance with applicable laws;
- If you attend an event or visit our offices, we may collect your image or video;
- If you voluntarily submit certain information to us, such as filling out a survey, responding to a questionnaire or participating in other forms of research, we may collect the information you have provided as part of that request, which may include special categories of Personal Data, to the extent you voluntarily choose to provide it;
- If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival;
- If you visit our offices or attend an event, due to the COVID-19 pandemic, you may be required to provide information regarding your health status, including your temperature, COVID-19-related symptoms, exposure to COVID-19 positive individuals, vaccination status, testing results, and recent travel history; and
- If you are a supplier or service provider to Build (or work for a supplier or service provider), you may also be required to provide us with Personal Data such as your contact details and payment and billing information.
If you provide us, our service providers or our affiliates with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in Section 12 below.
2.2 Personal Data we collect from other sources
We also collect information about you from other sources including third parties from whom we purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:
- Third part providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiels, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information;
- Another individual at your organization who may provide us with your personal information, which may include Personal Data and special categories of Personal Data, to the extent you consent to providing it and sharing it, for the purposes of obtaining services and assessing our goals related to our vendors; and
3. Types of Devices and Usage Data We Process
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.
3.1 Device and Usage Data
As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.
In addition, we gather certain information automatically as part of your use of our products and services which may include identifiers, commercial information. This information is used to provide necessary functionality, improve performance of our services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to identify customer opportunities, and for the security of Build generally (in addition to the security of our products and services). Some of the device and usage data collected by the services, whether alone or in conjunction with other data, could identify you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.
3.2 Cookies, web beacons and other tracking technologies on our website and in email communications
When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.
We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. To change your cookie settings and preferences for one of our websites, use the cookie controls on your device. Choosing to disable cookies on your device may limit your ability to use some features on our websites and services.
We may also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in a mareting email that notifies us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see Section 10.4 below.
The following describes how we use different categories of cookies and imilar technologies and your options for managing the data collection settings of these technologies:
|Type of Cookies||Description||Managing Settings|
|Required cookies||Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies.
If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online requests.
|Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.|
|Functional cookies||Functional cookies enhance functions, performance, and services on the website. Some examples include: cookies used to analyze site traffic, cookies used for market research, and cookies used to display advertising that is not directed to a particular individual.
Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/partners/.
|You can choose to opt out of functional cookies. To learn how to control functional cookies via your individual browser settings, click here.
To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here.
|Advertising cookies||Advertising cookies track activity across websites in order to understand a viewer’s interests and to direct marketing to them.
|You can choose to opt out of targeting and advertising cookies. See Section 3.3, below, to learn more about these and other advertising networks and your ability to opt out of collection by certain third parties.|
3.3 Notices on behavioral advertising and opt-out for website visitors
As described above, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks, please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here.
To manage the use of targeting and advertising cookies on this website, consult your individual browser settings for cookies.
3.4 Opt-Out from the setting of cookies on your individual browser
In many cases you may opt-out from the collection of non-essential device and usage data on your web browser (Section 3.1 above) by managing your cookies at the browser or device level. In addition, if you wish to opt-out of interest-based advertising, click here (or, if located in the European Union or United Kingdom, click here. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Build takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
4. Purposes for Processing Personal Data and Legal Bases On Which We Rely
We collect and process your Personal Data (including, where legally permissible, special categories of Personal Data) for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for the below purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data, as further detailed below.
- Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, websites, systems and applications and the security of Build generally, and in protecting our rights and the rights of others;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
- Handling contact and client support requests: If you fill out a “Contact Us” web form or request client support, or if you contact us by other means including but not limited to via phone, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
- Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you or to perform our contract with you or where we receive your consent;
- Managing, and participating in, contests, programs or promotions: If you register for a contest, promotion, or a program, we process your Personal Data to perform our contract with you or where we seek your consent. Some contests, programs and promotions have additional rules containing information about how we will process your Personal Data;
- Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
- Contract fulfilment: We may process your Personal Data for the purposes of fulfilling our contract with you or your employer (e.g. if you are an authorized user of our products and services or work for a service provider or supplier to Build). We do this where it is necessary for the performance of the relevant contract;
- Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your consent;
- Assessing and improving user experience: We process device and usage data as described in Section 3.1 above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering or website, or where we seek your consent;
- Reviewing compliance with applicable usage terms: We process your Personal Data to validate that you are a licensed user and to review compliance with the applicable usage terms in our customer’s or user’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
- Registering and hosting visitors to the office or at events: We process your Personal Data for security, health, and safety reasons, to register visitors and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices, staff and visitors and our confidential information against unauthorized access. In addition, certain health data (which may include special categories of Personal Data) may be processed for office visits and at events during the COVID-19 pandemic to ensure the safety and security of our visitors and employees (where legally permitted) with your consent or where necessary for reasons of public interest in the area of public health;
- Recording phone calls: We may record phone calls for training, quality assurance, and administration purposes. If required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded;
- Displaying personalized advertisements and content: We process your Personal Data to conduct market research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent (please see Section 9 below, to learn how you can control the processing of your Personal Data by Build for personalized advertising purposes);
- Administering surveys and conducting research: We process your Personal Data (including special categories of Personal Data) in order to meet the goals set out in surveys or research as well as to analyze our compliance with internal policies. If required under applicable law, we will obtain your consent to process your responses;
- Sending communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions, news or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see Section 9 below to learn how you can control the processing of your Personal Data by Build for marketing purposes);
- Compliance with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
5. Who do We Share Personal Data With?
We may share your Personal Data as follows:
- Service providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above in Section 4;
- Affiliates: If you use our websites to register for an event or webinar organized by one of our affiliates, we may share your Personal Data with the affiliate to the extent this is required on the basis of the affiliate’s contract with you to process your registration and ensure your participation in the event; in such instances, our affiliate will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required.
- Event sponsors: If you attend an event or webinar organized by us, or download or access an asset on our website, we may share your Personal Data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or you can opt-out in accordance with Section 9 below;
- Customers with whom you are affiliated: If you use our services as an authorized user, we may share your Personal Data with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
- Contest and promotion sponsors: With sponsors of contests or promotions for which you register in order to fulfill the contest or promotion;
- Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Build can market and advertise on third party platforms and websites;
- Professional advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data; and
- Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
We may also share anonymous or de-identified usage data with Build’s service providers for the purpose of helping Build in such analysis and improvements. Additionally, Build may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.
6. International Transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third-parties disclosed in Section 5, above, that are based in other countries.
Therefore, your Personal Data may be processed outside your jurisdiction, including in countries and jurisdictions that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction. We ensure that the recipient of your Personal Data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with your prior consent.
Our websites and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in Section 12 below and we will take steps to delete their Personal Data from our systems.
8. Retention Period of Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see Section 4 above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
9. Your Rights Relating to Your Personal Data
9.1 Your rights
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
- Access your Personal Data held by us;
- Know more about how we process your Personal Data;
- Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
- Erase or delete your Personal Data;
- Restrict our processing of your Personal Data;
- Transfer your Personal Data to another controller, to the extent possible;
- Object to any processing of your Personal Data;
- Opt out of certain disclosures of your Personal Data to third parties;
- If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt in to certain disclosures of your Personal Data to third parties;
- Not be discriminated against for exercising your rights described above;
- Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”); and
- Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.
Please note that Automated Decision-Making currently does not take place on our websites or in our services.
9.2 How to exercise your rights
To exercise your rights, please contact us by using the information in Section 12 below. Your Personal Data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Build customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in Section 12 below.
9.3 Your rights relating to customer data
As described above, we may also process Personal Data submitted by or for a customer to our products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement. If your data has been submitted to us by or on behalf of a Build customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Build customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
9.4 Your preferences for email marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Build by clicking on the “unsubscribe” link located on the bottom of Build marketing emails/
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
9.5 Your preferences for telemarketing communications
If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in Section 12 below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register.
Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.
10. How we Secure Your Personal Data
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in Section 12 below.
11. Changes to This Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
12. Contacting Us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please email us at email@example.com. When you contact us, please indicate in which country and/or state you reside.
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority.