Brugler Marketing maintains the highest standards of confidentiality and respect for the privacy of our customers. Our corporate policy satisfies the disclosure requirement under the Gramm-Leach-Boiley Act of 1999, as well as CFTC Regulation 160, and related National Futures Association (NFA) requirements. This statement is designed to provide our customers with up-to-date information on our efforts to keep your information private. If you are viewing this on the Web, you may click the following hyperlinks to jump to individual sections of the policy.
A. Collection of Information
Brugler Marketing collects nonpublic personal information about its customers through the following sources:
- Information from our customers.
- Information about the customer from the customer’s transactions with
- Brugler Marketing or our affiliates.
- Information about the customer from the customer’s reporting agency(ies).
Sources of such information include, without limitation: 1) application forms and subscription agreements, 2) questionnaires, and 3) other information that you provide to us; whether in writing, in person, by telephone, electronically, or by any other means. This information may include your name, address, social security number, financial and investment qualifications, income, employment information, and income and credit references. Such information may also include information received regarding trading and investment activity done by you or for your benefit which is reported to our company.
B. Disclosures to Service Providers
We may disclose all the personal information we collect to companies that provide services to you on our behalf, such as:
- Transmission of advisory and analytical content;
- Providing administrative, customer assistance, or other services;
- Preparing, printing, and delivering statements and other documents;
- Protecting against fraud; and
- Maintaining or developing software for us which enables us to perform the tasks required of a CTA firm.
C. Disclosures Permitted by Law
We may disclose all the personal information we collect as permitted or required by law. For example, we may disclose information to law enforcement agencies or regulatory authorities (such as the CFTC, NFA, or DSRO), to respond to a subpoena, court order, or other judicial process, to consumer reporting agencies or in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or an operating unit.
Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.
D. No Disclosure for Other Purposes
We will not share any personal information we collect with outside companies, except as explained above. That is, we will not sell personal information outside companies that may wish to market their products or services to you on behalf of such outside companies.
E. Annual Notifications
F. Security Procedures
G. Links to Other Web Sites
We use encryption and authentication tools to protect your personal information. Electronic mail you send to us is not necessarily secure, due to the public routers through which it passes on the Internet. If your communication is very sensitive, you should call us or send it by regular mail. Credit card or bank account information may be entered through the encrypted Web site, but should not be sent via electronic mail.
We may also collect nonpublic personal information when you use our corporate Web sites. Information is obtained through online collecting devices known as “cookies”.
"Cookies" are small files of data that reside on your computer and allow us to recognize you as an Brugler Marketing customer if you return to the Brugler Marketing site using the same computer and browser. We may send a "session cookie" to your computer if and when you log in to a Brugler Marketing subscription account. These cookies allow us to recognize you if you visit multiple pages in our site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.
If you prefer that we not disclose non-public personal information about you to nonaffiliated third parties you may “opt out” of those disclosures; that is, you may direct us to make those disclosures (other than disclosures permitted or required by law). If you wish to “opt out” of disclosures to nonaffiliated third parties send us a letter requesting your election to “opt out” to our address below.
L. Contacting Us
If you have any questions about this privacy statement, Brugler Marketing’s information practices, or your dealings with Brugler Marketing, you can call 402-697-3623 Monday through Friday between the hours of 9am and 5pm CDT, or write us at Brugler Marketing & Management LLC, 1908 N 203rd St, Suite 7, Omaha, NE 68022.
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