Brugler Marketing & Management LLC Privacy Policy

Brugler Marketing maintains the highest standards of confidentiality and respect for the privacy of our customers. OThis 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:

  1. Information from our customers.
  2. Information about the customer from the customer’s transactions with
  3. Brugler Marketing or our affiliates.
  4. 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:

  1. Transmission of advisory and analytical content;
  2. Providing administrative, customer assistance, or other services;
  3. Preparing, printing, and delivering statements and other documents;
  4. Co-sponsors for Brugler events;
  5. Protecting against fraud; and
  6. Maintaining or developing software for us which enables us to perform the tasks required of an advisor.

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

If you are a current customer, we will provide an annual Privacy Statement Supplement like this one to you in the future. If you no longer have a customer relationship with us, we will continue to follow our Privacy Policy and practices, but you will not receive future notices from us.

F. Security Procedures

We maintain procedures and technology designed to prevent unauthorized access to personal information. We maintain physical, electronic, and procedural protections in accordance with applicable standards to protect personal information. We restrict access to personal information to employees and service providers for legitimate business purposed to assist in providing products or services to you. Employees who violate our Privacy Policy are subject to disciplinary action. Third-parties with which the Company shares member information must agree to follow appropriate standards and security and confidentiality. We do not maintain credit card information after authorized charges have been processed, and any paper credit card information is shredded after use. We do maintain credit card transaction logs as required by our banking agreements, but these logs do not contain complete credit card records.

G. Links to Other Web Sites

We are not responsible for the information collection practices of other Web sites when you link to them from our Web site. For example, we cannot guarantee how those sites use cookies or whether they place on your computer cookies that may identify you personally. You should carefully review the privacy policies of each Web site you visit to understand how they collect, use, and disclose information.

H. Encryption

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.

I. Cookies

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.

J. Change in Privacy Policy

We reserve the right to modify or supplement this Privacy Policy at any time. If we make material changes, we will provide current customers with a revised notice that describes our new practices. The practices and policies contained in this Privacy Policy replace all previous notices or statements with respect to the same subject.

K. Your Right to “Opt Out” of This Privacy Policy

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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