Privacy Policy

1. Introduction and Scope

BFD CAPITAL GROUP LLC respects the privacy of every person who visits our website, contacts our counting room or engages our computer integrated systems design services. This Privacy Policy explains what information we collect, why we collect it, how we use it, with whom we share it and how we protect it. It also describes the choices and rights that are available to you and the steps you can take to exercise them.

This policy covers the website published at bfdcapital.mom and every subsidiary page under it, together with the communications, proposals, workshops and consulting engagements that BFD CAPITAL GROUP LLC conducts with clients and prospective clients. It does not cover any third party website, platform or service that we may link to, and it does not cover information that we process strictly on behalf of a client under that client instruction, which is governed by the written agreement between the client and BFD CAPITAL GROUP LLC.

By using our website or by contacting us, you acknowledge that you have read and understood this policy. If you do not agree with the practices described here, please do not submit information to us and contact us with any questions you may have before proceeding. We have written this policy in plain language on purpose, because a privacy notice that cannot be read is a privacy notice that cannot be trusted.

2. Who We Are

BFD CAPITAL GROUP LLC is a computer integrated systems design consultancy registered in the United States. Our principal place of business and counting room is located at 2265 E Murray Holladay Rd, Holladay - 84117-5379, United States (US). We design, weigh, classify and record integrated systems for client organizations across several industries, always following the counting room discipline that gives our practice its character.

For the purposes of applicable data protection law, BFD CAPITAL GROUP LLC is the controller of the personal information described in this policy when we collect it for our own business purposes. Where we process information strictly on the instruction of a client during a consulting engagement, we act as a processor and the client remains the controller. In that situation the client privacy notice governs the processing of that information, and you should direct your rights requests to the client in the first instance.

You may reach our privacy contact at any time by writing to finance@bfdcapital.mom or by telephoning +14587577725 during business hours. We answer privacy enquiries within one business day and will always confirm in writing when we have actioned a request.

3. Information We Collect

We collect information in three broad ways. First, we collect information that you provide to us directly, such as when you complete a contact form, send us an email or speak with us on the telephone. Second, we collect information automatically as you browse our website, such as technical data about your device and your interaction with our pages. Third, we collect information that arises in the course of delivering our services, such as the working notes, tallies and correspondence that a consulting engagement naturally produces.

The categories of information we may collect include identity and contact details, business information about the organization you represent, correspondence you send to us, technical and usage data, and any other information you choose to share. We do not seek sensitive categories of personal information, and we ask that you do not send us sensitive information through a general website form. Where an engagement genuinely requires access to sensitive records, we will agree written safeguards with you before any such information is shared.

We keep the amount of information we collect to the minimum we need. If a piece of information does not help us answer your question, deliver a service, keep our records accurate or meet a legal obligation, we prefer not to collect it at all. That restraint is part of the same discipline we apply to the systems we design.

4. Information You Give Us Directly

When you complete the contact form on our website, we receive the name, email address, subject line and message that you enter, plus any information contained in the selected service category. When you email us at finance@bfdcapital.mom, we receive your email address, the content of your message and any attachments you choose to include. When you telephone us at +14587577725, we may make a written note of the matter discussed so that we can respond properly and keep an accurate record.

During a consulting engagement we may receive business records that a client shares with us deliberately, such as system inventories, interface specifications, reconciliation files and records of asset classes. We treat those records as confidential client material, we use them only for the purpose the client has authorized, and we return or securely dispose of them at the end of the engagement according to the terms of the written agreement.

If you apply to work with BFD CAPITAL GROUP LLC, we receive the information you include in your application, such as your name, contact details, employment history and any materials you submit. We use that information solely to assess your application and to communicate with you about it, and we retain it only for as long as necessary for that purpose or as required by law.

5. Information Collected Automatically

Like most websites, ours records certain technical information when you visit. This can include the internet protocol address from which your request originated, the type and version of your browser, the operating system of your device, the pages you view, the time and duration of your visit and the address of any page that linked you to us. This information is used in aggregate to keep the site working correctly and to understand which parts of it are useful.

We do not attempt to identify individual visitors from this technical data, and we do not combine it with information that would allow us to do so unless a security incident requires investigation. Our website is a static publication with a small amount of interaction, and we have deliberately avoided heavy tracking systems that would follow you across other sites. Where a hosting provider records requests in a server log for operational and security reasons, those logs are retained for a short period and then discarded.

The one piece of verification metadata we publish in the head of our homepage exists solely to confirm site ownership to a search provider. It does not collect information about you and it does not set any cookie or persistent identifier on your device.

6. How We Use Information

We use the information we collect to respond to enquiries and arrange vault hours, to prepare proposals and deliver our six services, to maintain accurate business and financial records, to improve our website and service quality, to protect our systems and clients from misuse, and to comply with legal, accounting and regulatory obligations that apply to a United States limited liability company.

We may also use contact details to send occasional updates about our services where we have a lawful basis to do so, and every such message includes a simple way to opt out. We do not use information for automated decision making that produces legal or similarly significant effects, and we do not sell personal information to anyone for any purpose.

Where we use information for a new purpose that is not described in this policy, we will tell you before that new use begins and, where the law requires it, obtain your consent. We will not quietly repurpose information that you shared for one reason into an unrelated use, because doing so would break the trust that a counting room depends upon.

7. Legal Bases for Processing

Where data protection law requires us to identify a legal basis for processing, we rely on one or more of the following. We process information to perform a contract with you or to take steps at your request before entering a contract, such as preparing a proposal or delivering a service you have engaged. We process information for our legitimate interests in running and improving our business, provided those interests are not outweighed by your rights and expectations.

We process information to comply with legal obligations, including tax, accounting and record keeping requirements. We process information with your consent where we have asked for it, for example when you ask to receive updates, and you may withdraw that consent at any time without affecting processing that took place before withdrawal. We process information to protect the vital interests of individuals where necessary, and to establish, exercise or defend legal claims.

If you have questions about the legal basis we rely on for a particular processing activity, please write to finance@bfdcapital.mom and we will explain it in writing. We keep a record of the bases we rely on so that we can answer such questions promptly and consistently.

8. Cookies and Similar Technologies

Our website is built to work with the smallest possible number of cookies. We use strictly necessary storage only where it is required for a feature such as remembering the state of the mobile navigation menu during a visit. That storage contains no personal information, it does not identify you, and it is cleared when you close your browser or shortly afterward.

We do not use advertising cookies, cross site tracking cookies or third party marketing pixels on this website. If we ever introduce an optional analytics or preference cookie, we will describe it in this policy, explain what it does and ask for your consent before it is set, in line with applicable law.

You can control cookies through your browser settings, and you can delete stored data at any time. Blocking strictly necessary storage may affect the behavior of a small number of interactive features, such as the mobile menu, but it will not prevent you from reading any content on the site.

9. How We Share Information

We do not sell, rent or trade personal information. We share information only in the limited circumstances described below, and always with safeguards that require the recipient to protect it and to use it only for the purpose for which it was shared.

• With service providers who support our operations, such as email, hosting and accounting providers, under written agreements that limit their use of the information.
• With professional advisers such as auditors, insurers and legal counsel where necessary to run our business or defend our rights.
• With a client where you have asked us to share information as part of a consulting engagement you are involved in.
• With authorities where we are required by law, regulation, court order or a valid legal process, or where disclosure is necessary to protect rights, safety or property.
• With a successor entity in connection with a merger, acquisition, restructuring or sale of assets, in which case the recipient will be bound by this policy or one that is at least as protective.

Where we share information with a service provider, we limit the disclosure to what the provider needs to perform the task, and we do not authorize the provider to use the information for its own marketing. We review the security and privacy practices of our providers before we engage them and periodically afterward.

10. Service Providers and Subprocessors

To operate our business we rely on a small number of service providers. These typically include a web hosting provider that serves this static website, an email provider that delivers and stores our correspondence, a domain registrar and a professional accounting firm that helps us keep statutory records. Each provider is selected with care and bound by an agreement that requires confidentiality and appropriate security.

When we act as a processor for a client, we may engage subprocessors to help deliver the engagement. We remain responsible to the client for the performance of those subprocessors, we impose equivalent data protection obligations on them, and we notify the client before adding a new subprocessor where the engagement agreement requires it.

You may request a current list of the categories of service providers we use for a specific purpose by writing to finance@bfdcapital.mom. We will provide the categories and, where confidentiality permits, the names, so that you can assess how your information is handled.

11. International Transfers

BFD CAPITAL GROUP LLC is based in the United States, and the information we collect is generally stored and processed in the United States. Some of our service providers may operate facilities in other countries, so information may be transferred to and processed in a jurisdiction outside the one in which you live.

Where we transfer personal information across borders and the law requires safeguards, we put appropriate measures in place. These measures may include standard contractual clauses approved for the purpose, an assessment of the legal environment of the destination, and additional technical and organizational protections such as encryption in transit and at rest.

If you would like more detail about the safeguards that apply to a particular transfer, please contact us. We will explain the mechanism in plain language and provide the relevant documentation where we are permitted to do so and where doing so does not compromise the security of our systems or the rights of others.

12. Data Retention

We keep personal information only for as long as we need it for the purpose for which it was collected, or for as long as the law requires. Enquiries that do not lead to an engagement are typically retained for a short period so that we can respond and follow up, and then deleted. Business correspondence and engagement records are retained for the period required by tax, accounting and contractual obligations.

When information is no longer needed, we delete it or make it anonymous in a way that cannot be reversed. Where deletion is not immediately possible because information is held in a backup archive, we isolate it from ordinary processing and delete it when the archive is next cycled, within the period described in our retention schedule.

Retention periods vary according to the kind of information and the reason we hold it. Records that support a signed reconciliation or a completed engagement are kept for the statutory period that applies to them, because those records may need to be produced to an auditor, a regulator or a court. Information linked to a security incident is retained until the incident is fully resolved and any legal limitation period has passed.

13. How We Protect Information

We maintain administrative, technical and physical safeguards designed to protect personal information against loss, misuse and unauthorized access, disclosure, alteration or destruction. These safeguards include access controls that limit information to personnel who need it, encryption of data in transit, secure configuration of the systems we operate, and a practice of keeping only the information we actually need.

Our team is small and deliberately so. Every person who handles client or visitor information understands the confidentiality obligations that apply, and access to sensitive material is granted for a defined purpose and reviewed regularly. We use unique credentials, we protect our accounts with strong authentication, and we keep our software current with security updates.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at finance@bfdcapital.mom so that we can investigate and take appropriate action. We will tell you what we find and what steps we are taking.

14. Your Privacy Rights

Depending on where you live, you may have a number of rights regarding your personal information. These can include the right to know what information we hold about you, the right to request a copy, the right to correct information that is inaccurate, the right to request deletion, the right to restrict or object to certain processing, the right to data portability and the right to withdraw consent you have previously given.

To exercise any right, write to finance@bfdcapital.mom or telephone +14587577725. Please describe the right you wish to exercise and the information it concerns. We may ask for enough detail to verify your identity, and we will not use the verification process to collect more information than we need. We will respond within the period required by applicable law, typically within thirty days, and we will tell you if we need more time and why.

You will not be discriminated against for exercising your rights. If you are not satisfied with our response, you may have the right to complain to a supervisory authority in your jurisdiction. We would prefer the chance to resolve your concern directly first, and we will cooperate fully with any competent authority that reviews the matter.

15. Privacy for Children

Our website and services are intended for businesses and professionals. They are not directed to children, and we do not knowingly collect personal information from children under the age required for consent in the relevant jurisdiction. If you believe that a child has provided information to BFD CAPITAL GROUP LLC, please contact us at finance@bfdcapital.mom and we will delete the information promptly.

Where a client engagement might involve information about children, we require the client to have a lawful basis and appropriate safeguards in place, and we limit our processing to what the engagement genuinely requires. We do not create profiles of children, we do not use information about children for marketing, and we do not share it for any purpose that is not strictly necessary to the agreed service.

Parents and guardians who have questions about the handling of information concerning a child may contact us and we will explain our practices and take appropriate action. Protecting young people online is a responsibility we take seriously, and we would rather receive a cautious enquiry than miss a genuine concern.

16. California Privacy Notice

If you are a California resident, you have specific rights under California law, including the right to know the categories of personal information we have collected, the sources of that information, the business purposes for which it is used and the categories of third parties with whom it is shared. You also have the right to request deletion, the right to correct inaccurate information, the right to opt out of the sale or sharing of personal information and the right to limit the use of sensitive personal information.

BFD CAPITAL GROUP LLC does not sell personal information and does not share it for cross context behavioral advertising. In the past twelve months we have collected the categories of information described in this policy, namely identifiers and contact details, business information, correspondence and technical usage data, and we have used and shared them only for the purposes set out above.

To exercise your California rights, write to finance@bfdcapital.mom with the subject line California Privacy Request or telephone +14587577725. You may use an authorized agent to submit a request on your behalf, and we will ask for proof of that authorization. We will confirm receipt and respond within the time required by law.

17. Do Not Track and Global Privacy Signals

Some browsers offer a Do Not Track setting that asks websites not to track a visitor across services. Because our website does not track visitors across other services and does not sell or share personal information for advertising, there is no cross context behavioral tracking to disable. We nevertheless honor the intent of such signals by keeping our data collection minimal.

Where a browser transmits a recognized opt out preference signal in a form we can read, we treat that signal as a request not to sell or share the information it concerns. Since we do not sell or share personal information in that sense, the signal is honored by default, and we will document how we respond to any future recognized signal in this policy.

If you would like to understand exactly what your browser sends and how our site responds, we are happy to explain it. Write to finance@bfdcapital.mom and we will describe the behavior in plain language rather than leaving you to infer it from a technical manual.

18. Third Party Links and Integrations

Our website may contain links to third party websites, and our engagements may involve integrations with third party systems. This policy applies only to information that BFD CAPITAL GROUP LLC collects and controls. When you follow a link to another website or use a third party service, the privacy practices of that third party apply, and we encourage you to read its privacy notice before providing any information.

We are not responsible for the content, security or privacy practices of third party websites or services, and a link from our site does not imply that we endorse them. Where we integrate with a third party system on your behalf, we will tell you which parties are involved and what information will be exchanged, so that you can make an informed decision.

If you believe that a link on our site points to a service whose practices are inconsistent with the standards we hold, please tell us. We review our links periodically and we will remove any that we can no longer stand behind.

19. Automated Processing and Analytics

We use limited automated processing to keep our website and correspondence running smoothly. This can include spam filtering on email, basic server logging for security, and aggregate page view counts that contain no personal information. These tools support our operations; they do not make decisions about you that have legal or similarly significant effects.

We do not build profiles of visitors for advertising, we do not use automated systems to make hiring decisions without human review, and we do not feed personal information into external training systems. Where we use analytics at all, we keep the data aggregated and we avoid identifiers that would allow an individual to be singled out.

If we ever adopt a new automated tool that processes personal information in a materially different way, we will update this policy, explain the change in plain language and, where the law requires, obtain your consent before the tool is used with your information.

20. Data Breach Notification

We maintain a response plan for security incidents. If we become aware of a breach involving personal information, we will investigate promptly, take steps to contain and remediate it, and assess the likelihood and severity of any risk to individuals. Where the law requires notification, we will notify affected individuals and the relevant authorities without undue delay and will explain what happened in plain language.

Our notification will describe the nature of the incident, the categories of information involved, the likely consequences, the measures we have taken and the steps you can take to protect yourself. We will keep a record of every incident, the decisions we made and the improvements we introduced afterward, because a counting room keeps an accurate ledger even of its troubles.

If you suspect a breach related to your interaction with us, please contact finance@bfdcapital.mom immediately. Early warning helps us contain an incident, and we would rather hear from you quickly than learn of a problem too late.

21. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services or the law. When we make a material change, we will update the effective date at the top of this page and, where appropriate, provide a more prominent notice on the website. We encourage you to review this page periodically so that you remain aware of how we handle information.

If a change is significant enough to require your consent under applicable law, we will ask for it before the change takes effect. For other changes, your continued use of the website or your continued engagement with our services after the update indicates that you have reviewed and accepted the revised policy.

We keep prior versions of this policy in our records. If you would like to see an earlier version, write to finance@bfdcapital.mom and we will provide it, together with a short explanation of what changed and why.

22. How to Contact Us

We welcome questions, requests and concerns about privacy. Please reach the counting room using the details below, and we will respond within one business day.

If you are not satisfied with our response, you have the right to complain to the data protection authority in your jurisdiction. We will cooperate with any such authority and will do our best to resolve your concern fairly and promptly.