Last updated on: 26 December 2022
2. SCOPE AND APPLICABILITY
By visiting Beth’s website at www.bethfinance.com or our mobile application;
By using our services and platform products;
By interacting or communicating with us as part of our marketing practices; or
By connecting with us at industry events and conferences.
Note that certain Beth products may be covered under separate agreements with Beth affiliates. If you have such an agreement in place with Beth, please reference the agreement for details on how the services collect and use Personal Information.
This Policy also describes the choices that Individuals have with respect to their Personal Information, and how to contact Beth to learn more about our privacy practices.
3. PERSONAL INFORMATION WE COLLECT
We may collect Personal Information about you in several ways when you use our services, as described below.
Information You Provide. We collect the information you provide to us directly when you use our services. You can choose to provide Personal Information for:-
Website Use – We collect some or all of the following Personal Information about you when you use our website to contact us:
Company information (state, institution type);
other information you choose to provide to us when you contact us with your inquiries.
Onboarding Process – We collect some or all of the following Personal Information of applicants or their representatives (including control persons, beneficial owners, and authorized users) during the onboarding process:
Date of Birth;
Entities you may be affiliated with;
Country and region;
Tax ID number or equivalent;
Institutional information – We also collect information about our institutional clients, for onboarding and compliance purposes. Types of information include:
Location of headquarters;
Business Registration Number or equivalent;
Names of affiliated entities;
Certificate of Good Standing;
Information on your Know Your Customer/Anti-Money Laundering (“KYC/AML”) program;
Financial history and details (investment activity, bank statements, balance sheets, etc.)
Identity Verification – In addition to the Personal Information described under “Onboarding Process,” we may collect the following Personal Information to verify the identities of our clients or their representatives:
Photographic and video footage;
Additional information collected from your device (see below).
Transaction Execution – Once we verify your identity, we collect additional information to complete any requested transactions:
Names of counterparties to transactions;
Bank account information of counterparties to transactions;
Client Reporting – To execute our reporting services, we collect financial details (account balances, transaction information, etc.).
Research – For internal research and reporting.
Security – To block disruptive uses.
Job Applications – If you apply for a job with Beth, in addition to collecting the Personal Information described under “Website Use,” you will be directed to a third-party platform that may collect the following Personal Information about you:
Any other Personal Information you choose to submit along with your application.
Marketing Activities – If you attend our events, business meetings, visit our booth at an industry conference or interact with our online or targeted marketing materials, in addition to the Personal Information described under “Website Use,” we may collect one or more of the following business contact information about you:
Other information that may be contained on your business card, if you choose to provide one;
Other information as described below in “Information We Collect”.
Information We Collect from Third Parties. When you use our services, we collect the following information from third parties:
Referrals and Account Participant Invitations – We receive information about you, such as your name and email address, if a Beth user refers you to our platform or invites you to participate on their account as an administrator, viewer, or spender.
Integrations – We receive information about you via services you choose to integrate, such as where you link accounts from other service providers to your Beth account.
Third Party Sign In – If you log in to our services using credentials from a third party (for example, Google), we will receive information that you have made public via your privacy settings with that third party.
Onboarding Process – We receive information about you via service providers that assist Beth in gathering the required information for the KYC/AML program.
Publicly Available Information. We may collect information about you via the following publicly available resources when you use our services:
Note that we may combine information received from third parties or publicly available resources with information we have collected directly from you.
Browser and Device Information – Using cookies and other tracking technology, we may collect:
Geolocation data (e.g., zip code, GPS-based information including altitude);
Motion tracking (e.g., number of steps taken, heart rate);
Phone carrier and manufacturer;
Mobile operating system version;
Version of Beth application used;
Http referrer fields;
Browser type and version;
Unique device identification numbers or pages viewed;
Date and time of visit;
Number of times you return to our website or view content from our online targeted marketing materials;
the amount of time spent on content from online targeted marketing materials and other information related to your online behavior and activity.
4. HOW WE USE PERSONAL INFORMATION
We use the Personal Information we have about you as described below.
Provide Our Services – We use the information we have about you to manage your account and provide our services. We also use your information to diagnose and resolve issues with our services, provide technical and customer support, and ensure the safety, quality, and availability of the services, including verifying your identity and detecting, preventing, and prosecuting those responsible for security incidents or malicious, deceptive, fraudulent, or illegal activity.
Communicate with You – We use the information we have about you to respond to your inquiries, and requests, and/or send important notices. This includes, for example, delivering customer support, and periodic emails related to company news, updated policies, product/service updates and information, job openings, or press releases.
Market Our Services – We use the information we have about you to market our services. This includes, for example, sending you email communications about products, offerings, events and webinars or customized offers or materials.
Improve Our Services – We use the information we have about you to improve our services. This includes, for example, identifying usage trends, developing data analysis, determining the effectiveness of our promotional campaigns, evaluating our business performance, researching, demonstrating, developing and improving our products and services, and ensuring quality control. This can also include personalizing your experience.
User Testing and Surveys – We use the information we have about you to invite you to participate in user testing and surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us).
Comply with The Law – We use the information we have about you to comply with applicable laws, regulations, and contractual obligations. This includes, for example, conducting compliance and/or security checks, audits, or assessments, enforcing our contracts and agreements with our customers, or complying with applicable law enforcement obligations.
Protect Our Assets – We use the information we have about you to resolve disputes and protect the rights, property, safety and interests of Beth and our site visitors, customers, and the public. We ensure the security of our assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions. We enforce any legal terms that govern your use of our website or application.
Other Purposes You Consent To – We use the information we have about you for other purposes if you consent to those uses at the time you provide your Personal Information.
De-identified or Aggregate Information – We use the information we have about you to create de-identified or aggregate information, such as de-identified demographic or location information, information about devices used to access our services or other relevant analyses. We also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, etc.
5. HOW WE SHARE PERSONAL INFORMATION
Beth may share the Personal Information we have about you as described below.
Service Providers and Other Third Parties – We share information we have about you with third parties and service providers who assist us with administering the services. This includes, for example, IT service providers, data storage providers, identity verification service providers, and marketing service providers.
Across Our Affiliates – We share information across Beth’s family of companies to provide you with our services, prevent fraud, conduct identity verifications, comply with the law, or in the event of a sale, merger, acquisition, or other liquidity events.
Business Partners or Joint Offerings – In certain situations, we may offer products or services jointly with a business partner. In such an event, we will share your information with a business partner for the purpose of facilitating the offering. In such a case, the business partner’s name will appear along with ours on the product or service.
Advertising Partners – We may share information with third parties to facilitate advertising on third-party websites or mobile apps. If you do not want your Personal Information shared with our advertising partners, please contact us.
Sale, Merger, or Acquisition – As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Beth’s assets are sold or transferred to a third-party, end-user information would likely be one of the transferred business assets.
Protection of Beth or Others – Beth accesses, preserves, and discloses Personal Information in a good faith belief that such access, preservation, or disclosure is permitted by Beth’s Privacy Program Policy or reasonably necessary or appropriate for any of the following reasons:
to enforce our agreement with our Client (i.e. the applicable Custody Service Agreement);
to respond to your requests for customer service;
to protect the rights, property, or personal safety of Beth, its agents and affiliates, its users, and the public; and/or to defend Beth or others against third party claims or allegations.
Legal, Regulatory, Safety, and Compliance Purposes – In certain situations, we may be required to share your information with law enforcement officials or government authorities as required by laws, regulations, legal processes, and governmental requests. These situations may include, but are not limited to:
complying with a subpoena or other legal process requests;
protecting your rights;
protecting your safety or the safety of others;
responding to a government request.
Any third parties that we share your Personal Information with are limited by law and by contract in their ability to use your Personal Information. Beth requires third-party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Policy, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the privacy and data security practices of third parties outside of the Personal Information we receive from or transfer to them.
If you elect to receive periodic email communication from us (i.e., company news, product and service information), you may choose to opt-out from receiving such communications by clicking the ‘Unsubscribe’ link provided in these emails.
6. HOW WE PROTECT PERSONAL INFORMATION
At Beth, we take our responsibility to protect the security and privacy of your Personal Information seriously. We are committed to maintaining the confidentiality, integrity, and security of your Personal Information and taking precautions to protect such information. We use reasonable and appropriate administrative, technical, and physical safeguards to protect the information we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We regularly review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to our community, our customers, and ourselves. We also require third-party service providers acting on our behalf or with whom we share your information to maintain security measures consistent with industry standards.
Additionally, to help protect your privacy and maintain security, we verify your identity before granting you access to your information or your account. Our verification methods include requiring Individuals to create video footage of themselves before conducting a transaction, and the collection of biometric and geolocation data. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our services, please contact us. For your own online security, please do not send any other confidential Personal Information to us via email or through the contact form on our website.
7. CHILDREN’S PRIVACY
Our services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any Personal Information from, or market to, Individuals under the age of 13.
If we become aware, or If you learn that an individual under the age of 13 has provided us with Personal Information contrary to these rules, please contact us and we will delete the information from our systems.
8. PRIVACY AND THE INTERNET
The following additional information will be of interest to you as a visitor to this Site:
“Clickstream” data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Beth itself, or by our service providers, using cookies, web beacons, page tags, or similar tools that are set when you use our website or when you view an advertisement we have placed on another website. Clickstream data and similar information may be shared internally within Beth and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our website; and as otherwise permitted by applicable law or regulation. This information may be processed by us for the purposes described above, or on our behalf by other entities, solely in accordance with our instructions.
Our website are not currently configured to respond to “do not track” signals or similar mechanisms.
9. THIRD PARTY SERVICES, APPLICATIONS, AND WEBSITES
Certain third-party services, websites, or applications used to navigate to and from Beth services have separate user terms and privacy policies that are independent of this Policy. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third-party service, website, and/or application before use.
10. CHANGES TO THIS POLICY
11. CONTACT US
If you have questions about this Policy, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us at [email protected].