Privacy Policy

BondWave LLC (“BondWave”, “we”, “us”, “our”) values our relationship with you and considers privacy an important priority in maintaining that relationship. We are committed to protecting the security and confidentiality of personal information.

Sources of Information

We collect nonpublic personal information from the following sources:

  • Information we receive from broker‐dealers, investment professionals, or financial representatives;
  • Information about transactions with us, our affiliates, or others;
  • Information we collect as a result of a services agreement or your use of our software per our license agreement, or other forms;
  • Information we receive from inquiries by mail, e-mail, or telephone; and
  • Information we collect on our website through the use of “cookies.” For example, we may identify the pages on our website that a browser requests or visits.

Information Collected

The type of data we collect may include name, company name, address, phone number, e-mail address, tax identification numbers, account balance and transaction history, family relationships, and other personal information. We may also collect information you provide to us on the identity of your clients.

Disclosure of Information

We do not disclose any nonpublic personal information about our customers or former customers and their clients to anyone, except as permitted by law. In addition to using this information to verify identity (as required under law), the permitted uses may also include the disclosure of such information to unaffiliated companies for the following reasons:

  • In order to provide you with products and services and to provide products or effect services that you request or authorize, we may disclose personal information as described above to unaffiliated financial service providers and other companies that perform administrative or other services on our behalf.
  • We may release information we have if you direct us to do so, if we are compelled by law to do so with fraud prevention and law enforcement agencies, courts, and non-governmental regulators, or when we believe, in good faith, that such disclosure is legally required or that we have a legitimate interest in making a disclosure, such as to protect our rights and property.
  • Furthermore, we may enter into joint marketing agreements with nonaffiliated third parties. Please note that, in these cases, we only share your personal information with nonaffiliated third parties after entering into a contractual relationship that (1) limits the nonaffiliated third party from using your personal information for any purpose other than the purpose we intended, unless it is aggregated and anonymized; and (2) requires the nonaffiliated party to keep your personal information confidential and secure.

BondWave does not sell any of your personal information to third parties.

In certain cases, you may opt out of information sharing.   Please see the section entitled “Rights Regarding Your Personal Information” below to learn when and how you can instruct BondWave not to share your personal information.

International Transfer of Your Personal Information

If you are a client based in the European Union (“EU Data Subject”), the personal data collected from you is transferred and processed in the United States, which country is not recognized by the European Commission as providing an equivalent level of protection for personal data as provided in the EU.  By submitting your personal information to us, you expressly consent to the transfer of your personal data to recipients located outside of the European Economic Area.  You may withdraw your consent to such transfer at any time by contacting us at 877.795.2929.

Retention Of Your Personal Information

The length of time that BondWave will retain your personal data will depend on the specific type of information contained therein.  However, we will not retain your personal data longer than is reasonably necessary to provide you with the requisite products and services, and to fulfil our obligations to you.  We may also retain your personal data to the extent necessary to meet our legal obligations related to certain accounting, reporting and various recordkeeping requirements.  

Use of Website Analytics

We currently use a third party analytics tool, Google Analytics, to gather information for purposes of improving BondWave’s website and marketing our products and services to you. This tool employs cookies, which are small pieces of text stored in a file by your web browser and sent to websites that you visit, to collect information, track website usage and viewing trends such as the number of hits, pages visited, videos and PDFs viewed, and the length of user sessions in order to evaluate website performance and enhance navigation of the website. We may also collect other anonymous information, which is generally limited to technical and web navigation information such as the IP address of your device, internet browser type and operating system for purposes of analyzing the data to make BondWave’s website better and more useful to our users. The information collected does not include any personal identifiable information such as your name, address, phone number or email address unless you provide that information through the website for us to contact you in order to answer your questions or respond to your requests. To find out how to opt-out of this service click on: Google Analytics.

Confidentiality and Security

With regard to our internal security procedures, BondWave restricts access to nonpublic personal information to those BondWave employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect nonpublic personal information. When we share your personal information with a nonaffiliated third party (other than for legal or regulatory purposes), we require that party to enter into a contractual agreement that limits the use of your personal information and requires that party to maintain the confidentiality of your personal information. Should your relationship with BondWave end, your personal information will remain protected in accordance with our privacy practices as outlined in this Policy.

Third Party Providers

Some applications and services embedded within, or linked from, our website are controlled by nonaffiliated third party providers. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. We do not control these third parties or their privacy practices, and this Policy does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policy or advertising, please contact the responsible provider directly.

Protecting Children’s Privacy Online

Our online services are not directed to or intended for individuals under 18 years of age.

Rights Regarding Your Personal Information

OPTING OUT OF SHARING YOUR INFORMATION

BondWave reserves the right to disclose or share your personal information with the aforementioned nonaffiliated third parties, for the aforementioned purposes, as permitted by applicable laws and regulations.

You may, however, instruct us not to share information with our affiliated companies for marketing purposes or for purposes other than providing products or services to you, as described above. 

You may also opt out of information sharing with nonaffiliated parties, except as may be required in order to meet our legal and regulatory requirements, or as may be necessary to provide products or services.

For your convenience, BondWave provides several methods for you to opt out of sharing your information in the above circumstances and as permitted by law. You may send an email to us at info@bondwave.com with your name and company name requesting that your name be added to BondWave’s “Opt Out” list.

Additional data privacy rights

BondWave recognizes that the state where you live may provide its residents with additional data privacy rights that are not specifically addressed in this Policy. If you are a California resident, please refer to the section titled “CALIFORNIA RESIDENTS” in BondWave’s Privacy Policy below.  If you wish to exercise a data privacy right provided to you by your state of residence, please reach out to us in the manners described above. Please note that all such requests will be reviewed on a case-by-case basis and that submitting a request to BondWave does not guarantee BondWave will volunteer to accommodate your request. 

CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Protection Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”), related regulations, and other California privacy laws may provide you with additional rights regarding your personal information. This section describes those rights and explains how to exercise them. Additionally, the CCPA requires us to make additional disclosures regarding the collection, use, and sharing of your personal information. Any terms defined in the CCPA have the same meaning when used in this Section of the Policy. Please note, however, that the CCPA and any rights provide thereunder do not apply to certain personal information subject to an exemption, including without limitation, personal information collected, processed, sold, and disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”). Accordingly, please be advised that a determination regarding the applicability of the CCPA to your personal information will be made on a case-by-case basis and that submitting a request to BondWave does not guarantee an accommodation of your request.

Personal information we collect and for what purpose

In the preceding 12 months, we may have collected the following categories of personal information, including sensitive personal information: identifiers; information subject to Cal. Civ. Code § 1798.80(e); characteristic of protected classifications under California or federal law; commercial information; internet or similar activity; geolocation data; professional or employment-related information; education information; social security, driver’s license, state identification card or passport numbers; and any inferences drawn from the forgoing. Please note, the preceding sentence merely describes but does not expand the previously disclosed categories of information we collect described in the section titled “PERSONAL INFORMATION WE COLLECT AND MAINTAIN” above.

We only use or disclose your personal information, including sensitive personal information, in the ways described in this Policy, including helping ensure security and integrity of your information, performing other essential business functions such as maintaining or servicing accounts, providing customer service, and processing transactions.

We do not sell your personal information or share it for cross-context behavioral advertising. We may share your personal information with third parties as described in the section titled “Disclosure of Information” above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes to the following categories of recipients:

Categories of Personal Information Disclosed for a Business Purpose

  • Identifiers like your name, address, or contact information
  • Information subject to Cal. Civ. Code § 1798.80 like computerized information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to name or signatures
  • Protected Classifications Characteristics under California or U.S. law
  • Commercial Information
  • Internet or other similar network activity
  • Geolocation Data
  • Employment-Related Information
  • Social Security, Driver’s License, State Identification Card or Passport Numbers

Categories of Third Parties

  • Third-party administrators, investment advisers, custodians, transfer agents, securities brokers, and other third-party businesses, and their affiliates
  • Our affiliates
  • Credit reporting agencies
  • Legal or professional consultants
  • Marketing Partners
  • Essential information and technology providers
Access to specific information and data portability rights

You may request that we disclose the categories and/or specific pieces of your personal information that we collected over the past 12 months. Once we receive and confirm your verifiable consumer request and if we determine that your personal information is not otherwise exempt from the CCPA’s requirements, we will provide you with a summary of such information. For details on the categories of personal information that we collect, the category of sources for that personal information and our business or commercial purpose for collecting such information, please refer to the preceding table as well as the sections above titled, “PERSONAL INFORMATION WE COLLECT AND MAINTAIN” AND “USE OF YOUR PERSONAL INFORMATION AND LAWFUL BASIS FOR ITS PROCESSING.”

Deletion rights

You may request that we delete any of your personal information that we collected from you and that we retained, subject to certain statutory and other exceptions. Once we receive and confirm your verifiable consumer request, we will purge, and direct our service providers to purge, to the extent applicable, your personal information from our records, unless an exception applies. Please note that if you request that your personal information be deleted, we will no longer be able to maintain your account. In addition to certain data exceptions, please note that our compliance with such a request will not extend to data that we are required to maintain as part of our legal and regulatory recordkeeping requirements. We will, however, delete all information subject to such a request once the term of those requirements has expired. Please refer to “RETENTION OF YOUR PERSONAL DATA” above for a description of those terms.

Correction of your personal information

You may request that we correct any inaccurate personal information that we maintain about you, considering the nature of the personal information and the purposes of the processing of that personal information.

Right against Discrimination

You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you with a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising your rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

  • Sending us an email at info@bondwave.com;
  • Calling us at the following toll-free number: 877.795.2929; or
  • Submitting a request at 85 Broad Street, 22nd Floor, New York, NY 10004.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information to enable us to reasonably verify that you are the person about whom we collected personal information, or an authorized representative thereof.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

For security purposes, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If you are a client of BondWave, we will call the number that we have on file for you in an effort to verify your request. Making a verifiable consumer request does not require you to create an account with us. However, before we comply with your request for access or deletion, you may have to answer some questions about you and your relationship with us, along with providing us additional identification documentation. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Additional data privacy rights

BondWave recognizes that the state where you live may provide its residents with additional data privacy rights that are not specifically addressed in this Policy. If you which to exercise a data privacy right provided to you by your state of residence, please reach out to us in the manners described above. Please note that all such requests will be reviewed on a case-by-case basis and that submitting a request to BondWave does not guarantee BondWave will volunteer to accommodate your request.

Response timing and format

BondWave will acknowledge receipt of your request in writing within 10 days of its receipt. A response to a verifiable consumer request will then be provided within 45 days of its receipt. If we require more time to process your request (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Policy Updates and Inquiries

This Policy may change on occasion to reflect changes in our practices concerning the collection and use of personal information.  Please refer to this Policy from time to time so that you are aware of any changes or updates to the Policy.  Changes to this Policy become effective when posted, so please check periodically for updates. The date that this Policy was last revised is identified below. For questions about our policy, or for additional copies of this notice, please go to www.bondwave.com, or contact us at 1-877-795-2929.

Last updated: May 2024