When it comes to your personal information, we believe in transparency. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.
1. Some key terms
3. Personal information we collect and how we collect it
We collect various personal information regarding you. This includes the following: your name, mailing address, email address and/or phone number. We obtain this personal information when you fill out our Contact Us form.
4. How we use your personal information
We use the personal information we obtain about you for:
- Communicating with you, including by sending you emails about our services, announcements and other types of communication.
- Administer surveys and promotions.
- Promote our services and send you tailored marketing communications about our services, offers and programs.
- Ensure the security and integrity of our Services.
- Third party relationships.Manage our vendor and partner relationships.
- Enforce our Terms of Service and other legal terms and policies.
- Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).
- Complying with law.Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.
We process your personal information for the above purposes when:
- You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.
- Performance of a contract.We need your personal information to provide you with services and information requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so we can get in touch with more information about our services.
- Legal obligation.We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.
- Protecting you and others. To protect your vital interests, or those of others.
- How we share your personal information
We share personal information in the following ways:
- We share personal information with our affiliates when it is reasonably necessary or desirable, such as to help provide services to you or analyze and improve the services we or they provide.
- Service providers.We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.
- Following the law or protecting rights and interests.We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests or prevent fraud or abuse of Borelli Investment Company, or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
- Business transfers.If we’re involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.
- Your rights and choices
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
You can access, update, change or delete personal information by contacting us at to request the required changes. You can exercise your other rights by contacting us at the same email address.
You can also elect not to receive marketing communications by following the unsubscribe instruction in such communications.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.
7. How we protect your personal information
While no service is completely secure, we maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders and testing for and protecting against network vulnerabilities.
8. How we retain your personal information
The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria.
9. Data transfers
Personal information that you submit may be transferred to countries other than where you live, such as, for example, to our servers in the U.S.
Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We rely upon a number of means to transfer personal information, which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
- Privacy Shield.We transfer, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”).
- Standard data protection clauses.We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
- Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules. You can find out more information about these transfer mechanisms here.
11. How to contact us
If you are a resident of or have your principal place of business in the U.S.:
Borelli Investment Company
2051 Junction Avenue, STE 100
San Jose, California 95131, United States