Privacy Policy

This Privacy Policy was last updated on March 4, 2016.

The www.TheDailyBell.com website (the “Website”) is owned and operated by Blacksmith PTE, LTD.

We consider privacy of paramount importance to liberty and thus implement rigorous security in safeguarding user information. As a part of that commitment, we have implemented this Privacy Policy that explains our privacy practices for information we collect through our Website. Your privacy matters to us, so please do take the time to get to know our practices – and if you have any questions, contact us at CustomerService@TheDailyBell.com (“Service Contact”).

1. Blacksmith Global Ltd.’s Commitment to Privacy

We are committed to protecting the privacy of our members. We have and will take measures that protect the privacy of personal information held by us.

This Privacy Policy provides you with details regarding:

  1. why we collect personal information;
  2. what we do with that information;
  3. the steps we take to ensure that access to that information is secure;
  4. how you can access personal information pertaining to you; and
  5. who you should contact if you have questions or concerns about our policies or practices.

If you are under the age of 18, please do not provide information on our Website. We encourage parents to get involved with their children’s online usage and to be aware of the activities in which they are participating.

2. Personal Information

In general terms, personal information means any information about an identifiable individual. For example, this includes your name, postal and e-mail address, telephone number, investor status, and demographic information.

Personal information does not include aggregate information (data about a group or category of products, services or members, from which individual member identities have been removed). For example, information about how you use a service may be collected and combined with information about how others use the same service, but no personal information will be included in the resulting data. Likewise, information about the products you purchase may be collected and combined with information about the products purchased by others. Aggregate information about product purchases helps us understand trends and member needs. It can also assist us in determining whether it would be appropriate to offer new Website functions by looking at member Website browsing activities.

3. Collection of Personal Information

We only collect such personal information as is strictly necessary for the purposes outlined in Section 4.

We collect personal information:

  1. when you contact us;
  2. when you use our Website;
  3. when you subscribe; and
  4. when you participate in any of our programs.

We may automatically collect some information when you visit our Website, such as your computer’s network address and operating system, the site from which you linked to us, and the time and date of your visit and purchases. This information is not linked by us to personal information, but rather is only used to compile aggregate information. This information may be collected through the use of cookies and pixels (see our “On-line privacy practices” in Section 9 below).

4. Use of Personal Information

As part of our business operations, we hold and use certain personal information pertaining to you in order to process your requests, and to understand your needs so that we can serve you better. We may also tell you about opportunities we think will be of interest to you. Specifically, we may use personal information for the following purposes:

  1. Managing the provision of services to you, which includes introducing you to potential investment opportunities;
  2. Monitoring your satisfaction with our services and contacting you regarding the status of such services;
  3. As described in our “On-line privacy practices” in Section 9 below;
  4. Promoting, offering or marketing additional products, goods and services we or an affiliate may offer; and
  5. To create aggregate information as well.

5. Sharing of Personal Information

Personal information we collect in accordance with this Privacy Policy may be shared with our affiliates, for the purposes listed above, provided that such shared information is required for and is used and disclosed for such purposes only.

Personal information may also be disclosed to unaffiliated third parties in connection with the sale, assignment or other transfer of our business, in which case we will require such third parties to adhere to the terms of this Privacy Policy.

From time to time we engage unaffiliated third parties and their affiliates, agents and subcontractors (“Service Providers”) to perform certain technological or administrative services. For example, we may use a Service Provider to host and administer one or more of our Websites, process and store data, and fulfill similar technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to only the personal information held by us that they need in order to render their service to us. The companies that are provided with the personal information are first required to sign an agreement that obligates them to keep the information confidential and secure and prohibits them from using it for unauthorized purposes. We are not responsible for any additional information you provide directly to these parties.

We also may engage Service Providers to provide us with cloud computing services. Cloud computing is the provision of network-based services, located on remote computers, that allow individuals and businesses to use software and hardware operated by third parties. Examples of these services include online file storage, webmail and online business applications. Service Providers have policies and processes in place to ensure that the confidentiality of information in their care is properly safeguarded at all times.

You acknowledge that our e-mail systems are operated in the “cloud”. Cloud computing allows businesses or individuals to use computers and software programs operated by third parties. The computers provided by our current “cloud” Service Provider may be located in any jurisdiction we consider appropriate (each a “Jurisdiction”). Our current “cloud” Service Provider has policies and processes in place to ensure that the confidentiality of information in their care is safeguarded at all times.

You confirm your consent to this manner of storage, and permit your online inquiry to be processed accordingly. You acknowledge that this Service Provider may be located in one or more Jurisdictions, your personal information may be processed and stored in one or more Jurisdictions and the governments, courts or law enforcement or regulatory agencies of one or more Jurisdictions may be able to obtain disclosure of your personal information through a lawful order made where the information is located.

We will also disclose personal information in accordance with Section 9 below when the information is collected on-line at the Website and/or may disclose personal information without your knowledge or consent if a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so. We may also disclose personal information to protect the rights, property or personal safety of Blacksmith PTE Ltd., its members, employees or other members of the public.

6. Accuracy

To ensure that the personal information you provided is accurate, complete and up-to-date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the personal information we hold by emailing Service Contact.

7. Security Measures

We will continue to keep in place security measures in an effort to protect personal information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our Service Providers do the same. Access to personal information will be restricted to authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties. Please also see our “On-line privacy practices” in Section 9 below.

We periodically update our policies regarding information security measures in an effort to protect the personal information held by us in the most effective manner possible.

8. Accessing Personal Information

Our members are entitled to access the personal information held by us concerning them. In recognition of the importance we attach to each member’s information, you can only access personal information we hold about you, but not personal information about your spouse or others. Under limited circumstances, we may give you access to personal information that we hold about others, but only if required or permitted by law. You can access the personal information by emailing Service Contact. We will generally respond to your request for information within thirty (30) days, unless, for reasons beyond our control, a longer response time is necessary, in which case you will be advised accordingly. While our response will generally be provided at no cost, you will be informed in advance of any charges that apply in connection with the information request. Charges may relate to the transcription, reproduction or transmission of personal information held by us.

In very limited circumstances, we may not be able to supply personal information for reasons of a legal nature, including privileged communications between professional and client or a pending judicial proceeding. In each case, we will provide written reasons outlining why your request for access has not been granted by us.

9. Online Privacy Practices

Collection: We may collect personal information on-line when you visit our Website. In addition, we may collect cookie information when you browse the Website. Cookies are small files that are stored on your computer. Pixels are small blocks of code on webpages that allow another server to measure viewing of a webpage and often are used in connection with cookies. Web beacons are electronic images that allow us to count visitors visiting certain web pages, to access cookies, and to analyze whether advertising banners on our site or other sites were effective. At our Website, we may use cookies, pixels and/or beacons to help optimize your Website experience, to evaluate use of our Website and to support Website analytics. In doing so, we may collect technical information such as your IP address, your browser type, the addresses of referring Websites, and your path through our Website. Cookies help us to customize our Website for you and to better display pages according to your browser type.

Use: We use personal information collected online as described above. In addition, we use personal information:

  1. to respond to your questions and concerns and to understand your needs and preferences;
  2. to conduct surveys and other research;
  3. to provide you with customized Website content and advertising;
  4. to detect, prevent, or otherwise address fraud, security or technical issues, or
  5. protect against harm to the rights, property or safety of Blacksmith PTE Ltd., its users or the public as required or permitted by law.

Protection: Personal information we collect on our Website is stored electronically, and may be combined with other off-line information. Personal information entered on our Website is encrypted using a security protocol called SSL (Secure Sockets Layer). SSL encrypts information entered on our site before it is sent over the Internet. SSL also allows you to view securely your on-line account and registration information. Account information is accessible on-line only through the use of a password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Website by any person using your password. You are advised that, unlike communication within our Website, we have no control over the privacy of your e-mail communications with us while in transit. We recommend that you do not include confidential, proprietary, personal information in e-mails, including credit card numbers, passwords, and other similar information. Also, if other people have access to your e-mail account, they may be able to access your password and obtain personal information about you, or change information about your user profile. You should not use an e-mail account operated by your employer because many employers have the legal right to access such e-mail accounts. If you believe your password has been misused, please advise us immediately by emailing us at our Contact Information noted below.

Online links to other Websites: Through links provided on our Website, you can link to other Websites of third parties who have agreed to offer goods and services to our members. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Except as described above, we are not responsible for the content or privacy and security practices and policies of Websites to which we provide links. Links from our site to third parties or to other sites are provided for your convenience. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

10. Review of Privacy Policy

We reserve the right to change this Privacy Policy at any time; however, any changes or additions regarding the reasons we use personal information will not apply to you unless you consent to them. We will alert you that changes have been made by indicating at the top of the Privacy Policy the date that it was last updated. We encourage you to review our Privacy Policy to make sure that you understand how information that you provide will be used.

11. Comment Process

If you are not completely satisfied with or wish to submit comments concerning this Privacy Policy or its application by us, we invite you to convey your concerns or suggestions to Service Contact. We will reply as quickly as possible and inform you of the steps, if any, that has been or will be taken in order to address the concern or implement the suggestion.

If you wish to be removed from the Daily Bell’s databases, please send an e-mail detailing your request to CustomerService@TheDailyBell.com.

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