Privacy Policy

Last Modified: February 9, 2024

1. Introduction

Bancreek Capital Advisors, LLC (“Bancreek” or “we”), respect your privacy and are committed to protecting it through our compliance with this policy.

This policy (“Privacy Policy,” or “Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.bancreek.com (the “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy is incorporated by reference into Bancreek’s Terms of Use, which are available at: www.bancreek.com/terms-of-use.

This Policy applies to information we collect:

• On the Site.
• In email, text, and other electronic messages between you and the Site.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Bancreek or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy from time to time for updates.

2. Children Under the Age of 13 

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Site. We do not knowingly collect information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@bancreek.com.

3. Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Site, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, telephone number, account identification numbers, passwords, and/or credit card information, and/or any other identifier by which you may be contacted online or offline (“Personal Information”);
• about your internet connection, the equipment you use to access our Site and usage detail;
• that is about you but individually does not identify you, such as technical or device-specific information such as your browser type, computer type, computer or device operating system, your search queries, internet service provider, and technical information about your means of accessing the Site; and/or
• traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

We may collect this information:

• Directly from you when you provide it to us directly or through the use of the comment and blog features on the Site.
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

4. Information You Provide to Us.

The information we may collect on or through our Site may include:

• Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service, posting material, commenting or contributing to the blog, or requesting further services. We may also ask you for information when you report a problem with our Site.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your search queries on the Site.
• The types of articles you engage with, click on, or make comments to.

5. Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests and try to show you articles that may be of interest to you.
• Speed up your searches.
• Recognize you when you return to our Site.

The technologies we may use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small data file that can be placed on your hard drive when you visit certain websites. We use may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our networks. We may use a cookie to save your settings and to provide customizable and personalized services when you access the Site. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
• Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Bancreek, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

6. Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based, behavioral advertising or other targeted content.

We do not control any third parties’ tracking technologies or how the collected information may be used so please be aware of such risks when clicking on third party advertisements of links. If you have any questions about an advertisement or other targeted content, you should contact the responsible third-party provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

7. How We Use Your Information

We may use the information we collect from you in the following way and for the following reasons:

• To present our Site and its contents to you.
• To provide you with the information that you request from us.
• To respond to customer service requests from you and support your needs.
• To fulfill any other purpose for which you provide it.
• To personalize your experience on the Site.
• To aggregate user information to better understand our readers’ needs.
• To improve our Site interface, experience, or functionality.
• To tailor our posted research articles, white papers, and message board threads to engaged with the interested online community.
• To carry out our obligations and enforce our rights arising from any misuse of the website.
• To notify you about changes to our Site.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use your email address to send you information and updates pertaining to your order, or to respond to inquiries, questions, or requests. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, and notifications when new articles are posted. If at any time you would like to unsubscribe from receiving future emails or communications, we include detailed unsubscribe instructions within each communications. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

8. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide to us:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Bancreek’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Bancreek about our Site users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures.
• To other third parties whose products, services and investment offerings are made available through Bancreek, and which you decide to utilize.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

If you conduct business with Bancreek through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.

We may also disclose your Personal Information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bancreek, our audience, or others.

9. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

1. Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Website. If you disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s site available at, http://optout.networkadvertising.org/?c=1#!/.

10. Accessing and Correcting Your Information

You may send us an email at info@Bancreek.com to request access to, correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Use.

11.  Data Security

We maintain measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. That said, the safety and security of your information ultimately depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards or comment sections. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. We make no guarantees on the security of your Personal Information transmitted to our Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

12. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.

13. Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Bancreek Capital Advisors, LLC
401 Wilshire Blvd. Ste 1200
Santa Monica, CA 90401
info@bancreek.com

Additional Information for California Residents

1. Your Rights Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA")

The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA. As used below, a "consumer" means a resident of the State of California and a "covered business" means a business that is subject to the CCPA.

• Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer's personal information disclose to that consumer the following:

1. The categories of personal information it has collected about that consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting, selling or sharing (if applicable) personal information.
4. The categories of third parties to whom the covered business discloses personal information.
5. The specific pieces of personal information that the covered business has collected about that consumer.

• These disclosures are not required to include any information about activity that occurred prior to January 1, 2022. Please also note that a covered business is not required to honor more than 2 of these requests from the same consumer during any 12-month period.
• Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.
• Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.
• Right to Opt-Out of Sale/Sharing. If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business.
• Right to Limit Use and Disclosure of Sensitive Personal Information. If a covered business uses or discloses sensitive personal information for reasons other than those set forth in the CCPA, a consumer has the right to limit the use or disclosure of sensitive personal information by the business.
• Non-Discrimination. A consumer has the right not to receive discriminatory treatment by the covered business for the exercise of privacy rights conferred by the CCPA.

2. Categories of Personal Information We May Collect About You

In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are:

• Personal identifiers, such as your name, postal address, email address, online identifier, internet protocol address, account name, or other similar identifiers.
• Information covered by California's records-destruction law (California Civil Code §1798.80), such as your signature, telephone number, and financial account information.
• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Characteristics of protected classifications under California or federal law, for example, gender.
• Biometric information, such as when you use our voice-recognition service that we use for identity-verification and security purposes.
• Internet/Electronic network activity information, including, but not limited to, browsing history, search history, and other information regarding your interactions with our digital offerings or our advertisements.
• Geolocation data.
• Audio, electronic, visual, and similar data, such as call recordings.
• Professional or employment-related information, such as job title and business contact information.
• Education information.
• Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes.
• Sensitive personal information such as social security number, account log-in, password or credentials allowing access to your account(s) or to our digital offerings.

The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, legal defense and legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.

3. How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text or email [and/or via our website[and apps]]. However, we may also collect information from the following categories of sources:

• You or your representative, such as when using our products, services or digital offerings, when interacting with us or any of our service providers regarding our products, services or digital offerings or when otherwise communicating with us.
• Providers of publicly available information.
• Another person or other persons (typically people who know you) who provide referral information about you to us or who use the capabilities we offer on specific websites and applications to forward an article or other information to you.
• Third parties that provide products and services to you through your relationship with us..
• Third parties that perform services for us or on our behalf.
• Other third-party sources, including government sources, data brokers and social networks.
• Automatically, via technologies such as cookies and web beacons, when you interact with our digital offerings or electronic communications.

4. Why We Collect Personal Information

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or service provider;
• Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;
• To comply with our legal and regulatory obligations;
• For the performance of our contract with you or to take steps at your request before entering into a contract;
• For our legitimate interests or those of a third party; or
• Where you have given consent.

5. Categories of Personal Information Disclosed for Business Purposes

Like most businesses, we disclose personal information, including in some cases certain sensitive personal information, to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we disclose to third parties for business purposes the personal information that is encompassed by one or more of the categories described in the "Categories of personal information we may collect about you" section above, with the categories of third parties listed in the section above entitled "Disclosure of Your Information.”

6. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, you may contact us at:

Bancreek Capital Advisors, LLC
401 Wilshire Blvd. Ste 1200
Santa Monica, CA 90401
info@bancreek.com

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

• Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.