Introduction

This Privacy Policy (the “Policy”) explains what we do with your information. It describes how we collect, use and process your information, and how, in doing so, we comply with our legal obligations to you. Your privacy is of utmost importance to us, and we are committed to protecting and safeguarding your information privacy rights. Except as noted below, this Privacy Policy applies to you whether you interact with BestEx Group Research Group LLC (“BestEx Group”) through its website or otherwise (whether directly or through its affiliated subsidiaries, all of which are directly or indirectly owned by BestEx Group (together “BestEx Group”, “we”, “our”, or “us”).

Information you may provide to BestEx Group

We may collect your contact details (name, telephone numbers, job title and employer and email or postal addresses) when you engage with us when using the BestEx Group website or otherwise, such as when you request information about BestEx Group or you sign up for and attend BestEx Group webinars, conferences and other events. Where we are required to carry out verification checks to comply with our legal and regulatory obligations, we will collect specific additional information about relevant individuals (such as directors and beneficial owners), including, for example, date of birth, payment details, tax residence information, copies of photo identification documents (such as a driver license and/or passport/identity card), information about nationality/citizenship/place of birth, national identification numbers and other identity verification documents. We may also hold information that another person within your organization has chosen to provide to us. Where existing or prospective corporate clients/vendors provide us with information relating to their directors, employees, officers, agents, clients or any other person, such information is deemed to have been provided on the basis that: (i) those individuals have been informed and understand that their information is being provided to us or our affiliates; (ii) the client/vendor has a lawful basis (in accordance with applicable data protection laws and regulations) to provide such information to us; and (iii) those individuals affected are aware of their privacy/data protection rights and how to exercise them.

We do not seek to collect or otherwise process sensitive information about individuals (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or criminal conviction/offence data unless it is necessary for compliance with a legal and/or regulatory obligation. We request that you do not provide such sensitive information to us.

Information automatically collected

We may also collect information through automated and technical means as you browse or otherwise use our website. As you browse the website, we and our service providers who work on our behalf, use various technologies, like cookies (see below for more information) and webserver logs, to assist in automatically collecting information about how you use the website. A web server log is a file where website activity is stored and our servers may automatically record certain information, such as your web request, IP address, referring/exit pages and URLs, number of clicks and how you interact with links on the website, browser type and settings, domain names,  pages viewed, mobile carrier, mobile device identifiers and information about the device you are using to access the website, date and time stamp information, and other such information through web server logs.

Cookies and other tracking technologies

A cookie is a small text file that is placed on your computer when you visit a website, that enables us to recognize your computer; enhance your user experience by delivering content specific to your inferred interests; understand the web pages you have visited; perform searches and analytics; and assist with security administrative functions. Generally, cookies may contain information about your Internet Protocol ("IP") addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the website or your usage of our services, including a history of the pages you view.

You can configure your browser to block or alert you about these cookies, but certain areas of the site will not function properly if you block cookies. These cookies do not store any personal data.

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the site. All information that these cookies collect is aggregated and, therefore, anonymous. If you block these cookies, our aggregated statistics will not have a record of your visit.

Information we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we may seek contact and other information about you or your organization from other sources by way of due diligence or other market intelligence including: (i) from third party data providers and by analyzing online and offline media (which we may do ourselves, or employ other organizations to do so for us); (ii) from delegate lists at relevant events; and/or (iii) from other limited sources and third parties (for example, from third party brokers and counterparties who may provide us with your details in accordance with applicable regulatory requirements).

How we use your information

We may use information that we collect about you or that you provide to us, including any personal information, for any purpose including but not limited to:

• Provide you with materials you have requested;
• Personalize our contact with you;
• Operate, provide, improve, and maintain our website;
• Engage in research, analytics and reporting;
• Develop new products and services;
• Prevent abusive and fraudulent use of our website;
• Send you administrative messages, content, and other services and features in which we believe you may be interested.

We may combine information that we collect from or about you (including automatically collected information) with information we obtain about you from any companies that are part of BestEx Group and/or non-affiliated third parties,  and will use such combined information in accordance with this Policy. We may aggregate and/or de-identify/anonymize information collected through the website or otherwise. We may use aggregate or de-identified/anonymized information for any purpose, including without limitation for research and analytics, and may also share such information with any third parties, including partners, affiliates, subsidiaries, services providers, and others.

How we share and disclose your information

Where appropriate and in accordance with local laws and requirements, we may share your information, in various ways and for various reasons, with the following categories of people: 

• BestEx Group affiliates and personnel; 
• Tax, audit, regulatory bodies, law enforcement agencies or other authorities, when we believe in good faith that the law or other regulation requires us to share this information or for Security Purposes; 
• Third party service providers who perform functions on our behalf (including, without limitation, administrators, external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems, and others who provide sales, marketing, analytics, data storage, Security Purposes related, and other similar services);
• Third party outsourced IT and document storage providers (including cloud-based storage providers) where we have an appropriate processing agreement (or similar protections) in place;
• Third parties for legal purposes.
• If BestEx Group is subject to an acquisition bid, or otherwise merges with or is acquired by another business or company in the future, we may share your information with the new (or prospective) owners of the business or company.
• To ensure that your information receives an adequate level of protection, we put in place appropriate procedures with the third parties we share your information with to ensure that your information is treated by those third parties in a way that is consistent with, and which respects, the laws and regulation on data protection.

How we safeguard your information

We are committed to taking appropriate steps to protect the information that we hold from misuse, loss, or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures. These include measures to deal with any suspected data breach and training for staff on handling information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no Internet and/or other electronic transmissions and data can be completely secure. Please note you are responsible for ensuring that any information that you send to us is sent securely (e.g. encrypting attachments) and that you do not share your credentials with anyone.

How long we keep your information

‍We will ordinarily process your information throughout the course of our interactions and will then generally retain it for an appropriate amount of time after we have parted ways. The precise length of time will depend on the type of information, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. There may also be some legal, regulatory or risk-management requirements to retain information, including where certain information might be relevant to any potential litigation (bearing in mind relevant limitation periods). Once we have determined that we no longer need to hold your information, we will undertake one or more of the following: delete it from our systems and destroy hard copies, archive the information so it is beyond normal use, or anonymize/de-identify the relevant information.

California Privacy Rights

If you are a California resident, California law provides you with some additional rights regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe in this Policy the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we share. Under CCPA you have certain rights to know, to delete, to opt-out of sale or sharing, to correct, to limit use or disclosure of personal information.

European Privacy Rights‍

Where personal data of individuals resident in the European Union is controlled or processed by BestEx Group in the US, then, in addition to the above, BestEx Group will follow the provisions of the EU as to such EU personal data.

Changes to our Privacy Policy

We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our website, or advances in technology. We will make the revised Policy accessible through our website.

‍BestEx Group Contact Details

If you have any comments, questions or concerns about any of the information in the BestEx Group Privacy Policy, or any other issues relating to the processing of your information by BestEx Group, please contact info@BestEx Groupresearch.com or call us at 203-989-9218.