Privacy Policy

Effective April 1, 2021

Who we are

Our website address is: http://www.baerinvestment.com (the “Website” or “Site”).  We are Baer Investment Advisory LLC (“we” or “BIA”), an investment adviser registered with the State of California.

What personal data we collect and why we collect it

We recognize that privacy is important to our users.  This Privacy Policy outlines the types of personal information we may gather when you visit our Site or use our services, as well as some of the steps we take to safeguard it.  Please read this Privacy Policy to learn more about the ways in which we protect, use and disclose your personal information.  By visiting the Site, you agree to be bound by the terms and conditions of this Privacy Policy.  If you do not agree, please do not use or access the Site. 

By accepting the Privacy Policy and the Terms of Use https://baerinvestment.com/terms–of–service/, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy.  This Privacy Policy is incorporated into and subject to the terms of the Terms of Use.  

Overview

We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site is protected by those policies and procedures.  Generally, we collect non-public personal information about our clients from the following sources:

• Information we receive from clients on applications, intake form, questionnaires or other forms, including for example contact information (including information we collect on the Site), investment preferences and choices, financial situation and balances, employment status and household income information, and
• Information about clients’ or investors’ transactions with us, our affiliates or others.

Our policy is that:

• We use the information you provide to us to provide services to you, including understanding your interests and customizing your account.
• We restrict access to non-public personal information about our clients and investors to employees and service providers who need to know that information to provide services to our clients.
• We maintain physical, electronic and procedural safeguards to guard clients’ and investors’ personal information.
• We protect any non-public personal information about our clients or former clients and we do not share that information with anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our clients or former clients to regulatory authorities in connection with our business, but we do not share personal financial information with third parties for marketing purposes.  We share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential.  For example, we may provide such information to custodians, attorneys and auditors. 

In connection with providing our services, it also may be necessary for us to share personal information about you with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios.  In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities.  In those circumstances, we require those third parties to treat your private information with the same degree of confidentiality that we do.  In some instances, the third-party service provider may collect information directly from you.  In those cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you.  If you provide additional information to a service provider directly, their use of your personal information is governed by that service provider’s privacy policy.

We may also share information about you if we believe that disclosure is required under law.  For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.  

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy.  For example, we may be legally required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Site.  Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.

BIA is not currently in scope for the California Consumer Privacy Act.  If and when it is in scope it will revise this Policy as needed. 

Collection of Information

In general, you can browse the Site without telling us who you are or revealing any personal information about yourself.  We automatically track certain information that your browser makes available whenever you visit a website.  This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser.  Our Website service provider may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients.  This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address.  We use this information to operate, develop and improve our services.

The Site also uses Google Analytics to improve the Site’s visibility and effectiveness.  The information described above is shared with Google Analytices, where it will be shared, saved and used in the manner described at https://policies.google.com/privacy?hl=en

We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote trust and safety.  “Cookies” are small files placed on your hard drive that assist us in providing our services.  We offer certain features that are only available through the use of a “cookie.”  Cookies can also help us provide information that is targeted to your interests.  Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session.  You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to reenter your password more frequently during a session.  We use cookies to better understand how people interact with us.  

Contact Us and Scheduling

When you complete the “contact us” scheduling part of the Site, your contact information and other information is provided to Acuity, which is an affiliate of Squarespace.  That information will be shared, saved and used in the manner described in the Acuity and Squarespace privacy and cookie policy available at: https://www.squarespace.com/privacy

The emails and phone numbers collected by BIA during this process will be saved and may be used for marketing purposes.  Individuals who are not BIA clients may unsubscribe from BIA’s marketing email distributions by responding to an email and requesting to be unsubscribed.

Security

Your information is stored on our web hosts servers located in the United States.  We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers.  We treat data as an asset that must be protected against loss and unauthorized access.  We employ security techniques to protect such data from unauthorized access by users inside and outside the company.

It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect.  In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Children

Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.  

Effective Date 

This Privacy Policy is effective as of April 1, 2021.