Privacy Policy

This Privacy Policy establishes rules to govern the collection, use and disclosure of personal information collected by BLUEFIN, LLC (the “Company”), on behalf of itself and its affiliates, in the course of business, in compliance with federal, state and provincial privacy laws in the countries where we operate.

This Privacy Policy applies to all individuals whose personal information the Company collects, uses or discloses in the course of doing business. This includes individuals who are customers or potential customers who visit the Company’s website, and all individuals who are contract workers, contractors, and consultants to the Company. It is our policy to only disclose your personal information as required or authorized by law or as otherwise set out in this policy.

We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: www.bluefinllc.com/privacypolicy

WHAT IS PERSONAL INFORMATION?

For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual, but does not include a person’s name, title, e-mail address, business address or telephone number, as an employee of an organization. Where this Privacy Policy states that a list of items is “including”, the lists so described are meant to be examples and not exhaustive or exclusive.

This Privacy Policy applies to all personal information that is collected, used or disclosed by the Company. The Company has designated a Privacy Officer to be accountable for the operation of this Privacy Policy. Individuals may question or report any privacy concerns, breaches, violations or compliance issues to the Company at the address indicated below.

If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact the Company (info@bluefinllc.com) for guidance or clarification.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The Company collects and uses only the personal information that we need for providing services and operating our business. Generally, the Company collects the following personal information from individuals for the various purposes set out below:

· name;

· company name;

· metropolitan area;

· city;

· state / province;

· country;

· email address;

· IP address / ISP Trunk;

· phone number / cell phone number;

· preferences;

· comments;

· in the case of contract workers, contractors and consultants personal credit history, social security numbers or social insurance numbers, tax information; and

· any other information that relates to an identifiable individual.

The Company collects, uses and may disclose personal information in an effort to provide you excellent services, including, for example:

· to manage the Company's business and operations, including customer relationships and matters;

· to meet legal and regulatory requirements;

· to inform individuals about the Company's services that we believe may be of interest to them;

· to better understand an individual’s interests in or experience with our services;

· to deliver, develop, enhance or improve services;

· to provide information on future opportunities;

· to verify access rights to our website;

· to meet regulatory requirements;

· to conduct market research;

· to enforce our legal relationship with you;

· to initiate and maintain a consultant or contractor relationship with you; and

· as is necessary in contemplation of business transactions.

We normally collect information directly from our clients. We may collect your information from other persons with your consent or as authorized by law. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.

In addition, we also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use, and our third party contractors contracted to provide these services may use, tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best.

Finally, your Internet browser has a feature called "cookies," which stores small amounts of data on your computer about your visit to our site. Cookies tell us nothing about who you are, however, unless you specifically give us personal information. You do not need to have cookies turned on to visit www.bluefinllc.com. You may also elect not to allow cookies to be collected by selecting certain options on your browser.

HOW DOES THE COMPANY COLLECT PERSONAL INFORMATION?

(1) Information You Provide Us

The Company may collect Personal Information when you use the Company’s products or services, when you visit the Company’s website, when you enter into a contractor relationship with us, and when you enter the Company’s facilities. For example, we require customers who register to use our services to give us certain personal information, including but not limited to: their name, business name, address, phone number, e-mail address, and financial qualification and billing information, such as billing name and address, fax number, credit/banking information, bank wiring number(s), the identity of users within the organization that will be using the services, production information, financial performance information or other information necessary for us to correctly identify and provide the appropriate services.

All financial and billing information that we collect from you is used for the purposes of checking your qualifications as a prospective customer and billing you for services provided. The Company may use a third-party intermediary to manage the billing processing.

Other personal information we collect, as described above, may be used by the Company to provide service to you, to advertise or market our business, promotions, or services, keep and maintain accounts, keep records of transactions, maintain our contractual relationship with you, and for financial management of our business.

(2) Automatic Information

When you visit the Company’s website, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. In addition, we receive and store certain types of information whenever you interact with us via our Site, including what pages you visit and activities you perform on our Site. The Company automatically receives and records certain "traffic data" on our server logs including your IP address, cookie information, the page you requested, and your communications and interactions with other site registrants. We use this traffic data to help diagnose problems with our servers, to analyze trends and to better understand and market to our customers or website users, individually or in the aggregate.

We automatically collect usage information, such as the numbers and frequency of visitors to our Site and use of components of our service. We may use this information to provide research, advice and information, including, without limitation, for benchmarking purposes (e.g. we may publish an industry white paper that uses data collected through the use of our service). This data is only used in the aggregate. This type of collective data also enables us to determine how often customers use parts of the service so we can make the service appealing to as many customers as possible. In addition, we may provide statistical information to our partners about how our customers, collectively, use our website and service. We may share this type of statistical data so that our partners also understand how often people use areas of our website and our service, so that they, too, may provide you with an optimal experience.

(3) Information from Other Sources

In order to enhance our ability to provide relevant marketing, offers and services to you, we may obtain information about you from other sources and add it to our account information.

The Company uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", text files that are stored on your computer, to analyze your use of the website. The information generated by the cookie about your use of this website (including your shortened IP address) is transmitted to a Google server in the U.S. and stored there. Google will use this information to evaluate your use of the website, compile reports on website activity for website operators and to provide other services related with the website and internet use. Google may also transfer this information to third parties if required by law, or where third parties process these data on behalf of Google. For more information about Google Analytics, or to opt out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.

(4) Information that You Post on Our Site

Our site may provide you with opportunities to post comments and identifying information, such as to our Customer Portal feedback, comments or blog functionality. When you provide any such feedback, this information may appear in public or semi-public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties. Please do not post any information that you are not comfortable revealing to the public at large.

CONSENT

Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain services if we do not have the necessary personal information.

The purpose for collecting personal information is set out in this policy. Any necessary consents shall be obtained before personal information is collected, used or disclosed.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).

In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.

The amount and type of personal information collected by the Company shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.

Personal information collected by the Company or on behalf of the Company will be sent to the Company’s main office in Greenwood Village, Colorado USA and will be subject to the laws of Colorado and the United States.

HOW DO I OBTAIN ACCESS TO MY PERSONAL INFORMATION?

Upon request received by the Company in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by the Company should be directed to the Company.

Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.

The Company responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.

A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.

Requested information will be provided in a form that is generally understandable.

The Company will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, the Company will provide a list of organizations to which it is likely to have disclosed information.

Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from the Company, individuals wishing to view an original record will do so at the Company's main office and under the supervision of designated Company personnel.

Limitations on Access

The Company will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.

In the event that the Company refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. The Company will respond to your requests for access in accordance with applicable privacy legislation.

HOW WILL MY PERSONAL INFORMATION BE MAINTAINED?

Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.

Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by the Company and have it amended as appropriate.

Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Company.

All formal requests to amend personal information must be accompanied by appropriate supporting documentation. The Company will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.

If the individual is not satisfied with the results of the request, the Company shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.

HOW IS MY PERSONAL INFORMATION STORED AND SECURED?

Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.

Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.

We will notify all required authorities, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

CHALLENGING COMPLIANCE

Inquiries or complaints concerning compliance with this Privacy Policy should be addressed, in writing, to the Company.

If you are not satisfied with the response from the Company after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Canadian Federal Privacy Commissioner or your state or provincial Privacy Commissioner, as applicable.

QUESTIONS AND COMPLAINTS

If you have a question or concern about any collection, use or disclosure of personal information by the Company, or would like to request access to your own personal information, please contact:

The Company: info@bluefinllc.com