Privacy Policy
Updated 10/18/2023
Introduction
BKLN is focused on serving as the bridge between independent financial advisors and wealth management services. Our main business centers around working on a sub-advisory basis with our financial advisor partners to help them scale their businesses and retain their own clients. BKLN provides its tech-enabled investment management product, covering both equities and fixed income, through a user interface referred to as the “Platform.” As such, BKLN interacts with both financial advisor partners and directly with select investors. Together these two groups are referred to as “Clients.” While the majority of personal identifiable information (PII) is collected by the financial advisors, BKLN does interact with a portion of it to perform its services as a sub-advisor. To that end, the policy below addresses such instances.
Data collected by BKLN and its usage
This information is presented in conformity with 15 U.S.C. 6801-6810 and the Securities and Exchange Act of 1934 as amended by 15 U.S.C. 6801-6810. The customer and account-identifying nonpublic personal information is hereafter referred to as PII.
All financial companies need to share customers’ personal information to run their processes and provide services. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons BKLN would choose to share in the instances that it is acting as a primary advisory; and whether the investor can limit this sharing.
The investor must be 18 years or older to use the financial advisory services provided by BKLN and by its financial advisor partners. In addition, the Platform is not designed or intended for use by children under 13 years old, and neither BKLN nor its financial advisor partners knowingly collect personally identifiable information from anyone under 13 years old. IF SOMEONE IS UNDER 13 YEARS OLD, PLEASE DO NOT USE BKLN’S PLATFORMS AT ANY TIME OR IN ANY MANNER. If there is knowledge or confirmation that someone under 13 years old has provided BKLN or its financial advisor partners with personal information without consent, please contact BKLN at compliance@bkln.com so that the data can be deleted.
BKLN or any of its financial advisor partners would share PII for the following two purposes: (1) To run the daily processes that underpin the investment advisory and sub-advisory services provided to clients or in response to compliance requests and / or legal proceedings, and; (2) For marketing purposes, to offer additional products and services existing or prospective clients. We may also extract information on client accounts to use for company research. In such instances, PII will always be anonymized.
BKLN does not share PII for joint marketing with other financial companies (other than the primary advisor in a sub-advisory relationship) or with any affiliates or non-affiliates.
Maintaining the security and confidentiality of client PII is a BKLN priority. As such, meaningful precautions are taken to safeguard PII.The following information explains BKLN’s privacy policy in more detail.
Information typically collected by BKLN’s financial advisor partners (BKLN has access to a limited subset of this information):
Direct PII
Account opening information, such as financial product or service of choice, name, email, address, social security number, networth, citizenship status, whether the end investor is a control person, a politically exposed person, and / or if they have any affiliation with FINRA when establishing a brokerage account, any additional information necessary to verify compliance with law, and, information obtained for the purposes of tax reporting to the investor and the various agencies to which reporting is required by law, including disclosures on various Internal Revenue Service (IRS) forms
Transaction Data
Information that relates to account balances, payment history, trading activity and any other such transactions for which BKLN provides investment advice and direction
Banking Information
When a financial advisor partner and / or investor uses the Platform, BKLN may record certain details about the user’s computer or mobile phone, Internet Service Provider (ISP), IP Address, last website visited before that of BKLN, the pages visited and the sequence thereof, the date and length of the visit and other statistical information about the visit to the Platform
Transaction data for nonaffiliated third parties, including information related to account servicing for purposes of liaising with the custodian
Investment preferences, including risk tolerance, investment objectives and experience, time horizon, liquidity needs, and the like
Methods of Collection and Data Usage: BKLN uses the aforementioned information to:
Fulfill client requests with respect to its sub-advisory services and to improve bug reporting and user issue resolution;
Analyze the use of its site, app, and services in the spirit of product and service enhancements;
Research and develop new products and services;
Assist authentication on the Platform;
Secure and improve its network and services;
Detect and prevent potentially prohibited, fraudulent or illegal activities and otherwise in accordance with its Terms of Use; and for any other purposes disclosed at the time of data collection or with the consent of its clients
3rd Party Data Usage: Since BKLN mainly acts as a sub-advisor, it relies on the primary advisor to verify the identity of its end investors as it pertains to the anti-money laundering (“AML”) policies, and when establishing client brokerage accounts through partner broker-dealers, including Charles Schwab and Fidelity Brokerage Services. In the event that BKLN works directly with the end client, the aforementioned data would be collected and used for that purpose. Communications: To the extent that a client provides BKLN their email address, BKLN may use its newsletters, press releases, and/or new offers. BKLN will do so unless its client requests for this activity to cease, by sending an email to info@bkln.com, via the financial advisor partner, or by using the ‘unsubscribe’ instructions provided with each email communication.
BKLN does not use email address data or any other information to provide unsolicited messages not related to your existing account or possible additional financial advisory services, nor will BKLN sell, rent or lease it the data to any third party for such use.
Access: BKLN restricts access to personal account(s) and information to those employees who need to know that information to provide the relevant products and services. BKLN maintains physical, electronic, and procedural safeguards that meet or exceed industry standards to safeguard PII. Third parties who have access to such PII are obligated to follow appropriate standards of security and confidentiality.
California Privacy Rights: For purposes of adhering to the California Private Rights, BKLN does not share information collected about clients with its affiliates, or with any unaffiliated third parties, for direct marketing purposes.
Business Transfer Policy: In the event that BKLN is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, client data may be sold or transferred as part of that transaction. This Privacy Policy will apply to the PII sold or transferred to the new entity.
Data Retention: Clients with online accounts on BKLN’s Platform may request their financial advisor partner to close their accounts. This must be accompanied by a notification to the account’s custodian. Once an account is closed, all data records are eliminated except for created strategies and those records that must be maintained by law. All account and data requests must be presented to BKLN by the primary advisor. If clients are unable to request account closure through their primary advisor, they should contact help@bkln.com.
Dispute Resolution: If there are any complaints regarding BKLN’s compliance with this privacy policy, please contact BKLN at compliance@bkln.com. BKLN will investigate and attempt to resolve complaints and disputes regarding use and disclosure of PII in accordance with this privacy policy. Platform users are entitled to request information on how their PII is being used. The request will be acknowledged within 10 days and fulfilled within 45 days of inquiry. If there are any unresolved privacy or unaddressed data use concerns beyond that,please contact BKLN at compliance@bkln.com about the matter.
Future Changes to Privacy Policy: BKLN may update this Privacy Policy as necessary to reflect any business changes and to satisfy legal requirements. BKLN will ensure that a link to this privacy policy is available on its website and its users are notified of the changes at least 30 days before the effective date of said changes.
What law governs this Privacy Policy?
You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of New York, without reference to the choice of law or conflicts of law principles thereof, and will be subject to the dispute resolution clause contained in our Terms of Use.
If any provision of this Privacy Policy is judged to be illegal, void or unenforceable due to applicable law or by order of a court of competent jurisdiction it shall be deemed deleted and the continuation in full force and effect of the remainder of the provisions will not be prejudiced.