Bernoulli | Locke™ Privacy Policy for Non-Members

Welcome to the Bernoulli | Locke privacy policy (the “Privacy Policy”). Bernoulli | Locke, LLC operates the Bernoulli | Locke membership program (“Program”) for the benefit of our members (“Members”). This Privacy Policy describes how Bernoulli | Locke, LLC and its affiliates (collectively “B|L”, “we”, “our” and “us”) collect, use and share personal information.

Types of Information We Collect

Personal information means information that enables someone to identify or contact you. Non-personal information means information that does not directly identify you. We collect both types of information about you.

The following are examples of the types of information that we collect about you and how we use that information.

When We Collect Information

Types of Information We Collect

Primary Purpose for Collection and Use of Information

Bernoulli | Locke Membership Program – Obtaining an Application for Membership

If you request an invitation or are referred to us for an invitation to apply to become a Member of the Program, we collect your name, contact information (such as postal address, e-mail address and telephone number) and date of birth. We may also collect financial information about you, information about your education and employment, information about your profile in the community and your presence on social media, information provided in references from third parties, and other information pertinent to your qualifications to become a Member.

We have a legitimate interest in administering the Program, including, among other things, making sure that you meet our qualifications for membership, and sending (or declining to send) an invitation to apply.

Bernoulli | Locke Membership Program – Applying for Membership

If you apply to become a Member of the Program, we collect your name, postal address, e-mail address, telephone number, date of birth, billing address and credit card (or other payment) information. We use reasonable efforts to protect your payment information from unauthorized access, use or disclosure. (For more information see “How We Protect Personal Information” below.) We may also collect financial information about you, information about your education and employment, information about your profile in the community and your presence on social media, information provided in references from third parties, information obtained from background checks, and other information pertinent to your qualifications to become a Member. We may also collect your photograph. If you apply for membership for one or more of your children, we collect the name and date of birth of each child. We may also collect each child’s photograph.

We have a legitimate interest in administering the Program, including, among other things, making sure that you meet our qualifications for membership, processing your application, processing your payment for membership fees, communicating with you about Program benefits, providing you with membership benefits, detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.

Email Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, and click on any links or banners it contains.

We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

If you provide us feedback or contact us for support, we collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us.

We have a legitimate interest in receiving and acting upon your feedback or issues.

Mailing List

When you sign up for one of our mailing lists, we collect your email address and/or postal address.

We have a legitimate interest in sharing with you information about the Program, and products and services we offer, and we use your email address or postal address to share such information. Where required by law, we first obtain your consent to share information about our products or services with you.

Web logs

We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, and/or a date/time stamp for your visit.

We have a legitimate interest in monitoring our networks and the visitors to our website. Among other things, it helps us understand how to best provide visitors with information.

Screen Trackers

We collect information from you about your computer, and your activity on screen when you are visiting our website, including when our website is open on your screen, where on your screen you spend time, your keystrokes, and other activity.

We have a legitimate interest in monitoring your activity when you visit our website. Among other things, it helps us understand website traffic, how our website is being used, how to best provide visitors with information, and how to enhance the experience of visitors to our website.

Cookies

“Cookies” are small pieces of information that a website sends to your device while you are viewing a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). You can manage cookies by following instructions provided by your browser. If you choose to disable cookies, some areas or features of our website may not work properly.

We have a legitimate interest in being able to identify your device. Among other things, cookies help us to make our website operate efficiently, to improve user experience on our website, and to understand website traffic and how our website is being used. Cookies also allow us to provide you with a more personal and interactive experience tailored to your interests.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates and publicly available sources.

Use and Processing of Your Personal Information

We do not use or process your personal information, except for the uses described above and as follows:

  • To identify you when you visit our website.
  • To conduct analytics (e.g., to enhance user experience on our website).
  • To respond to your inquiries related to support or other requests.
  • To improve and plan our services.
  • To communicate with you about your request for an application or your application for membership in the Program.
  • To send marketing and promotional materials relating to the Program.
  • For internal administrative purposes, as well as to manage our relationship with you.
  • To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, including attempts to manipulate or violate our policies, , and terms and conditions.
  • To comply with legal obligations, to establish or exercise our rights, to defend against a legal claim, and to investigate, prevent or take action regarding possible misconduct.

Sharing of Personal Information

We do not share or disclose your personal information, except in the specific situations discussed elsewhere in this Privacy Policy, and as follows:

  • Affiliates and Acquisitions. We may share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures or other companies under common control). If another company acquires (or proposes to acquire) our company, any of our affiliates, business or assets, we may also share your personal information with that company.
  • Other Disclosures without Your Consent. We may disclose your personal information in response to subpoenas, warrants or court orders, or in connection with any legal process, or to comply with applicable laws. We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our rules or policies, or to comply with your request for the shipment of products to a third party intermediary.
  • Service Providers. We share your personal information with third party service providers. Among other things, service providers may help us to administer our website, provide technical support, and process applications for membership in the Program.

Your Choices

You can make the following choices regarding your personal information:

  • Promotional Emails. If you provide us with your e-mail address, we may send you marketing and promotional materials relating to the Program. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you elect not to receive promotional emails, we may still send you transactional communications, such as those about your application for membership in the Program, or other service-related communications.
  • Promotional Mailings. If you provide us with your postal address, we may send you marketing and promotional materials relating to the Program. You can stop receiving promotional mailings by contacting us at support@14e.com. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that were initiated before your name was removed.
  • Changes to Your Personal Information. We rely on you to update and correct your personal information. If any of your personal information changes, you can update your information by contacting us at support@14e.com. Note that we may keep historical information in our backup files as permitted by law.
  • Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

How We Protect Personal Information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How Long We Retain Information

We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Information for California Residents

  • California Information Sharing Disclosure. California Civil Code 1798.83, 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 states that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share at the end of this Privacy Policy. Because this list is comprehensive it may refer to types of information that we share about people other than yourself.
  • Request Access. If you are a California resident and if required by law, upon request, we will grant reasonable access to the personal information that we hold about you.
  • Request Deletion. In certain circumstances, if you are a California resident and if required by law, upon request, we will delete your personal information. We may also decide to delete your data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. There are some situations in which we may decline to delete your personal information. For example, we may keep your personal information as needed to comply with our legal obligations, where permitted by law, to resolve disputes, and/or to enforce any of our agreements.

You can exercise these rights by contacting us at support@14e.com. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Information for Non-US Residents

  • Transmission of Information to Other Countries. If you are located outside the United States, your personal information may be processed in the United States, where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage and processing of your information in the United States.
  • Rights With Respect to Personal Information. If you are a resident of the European Union, you may have additional rights under applicable data protection laws with respect to your personal information, including:
    • Request Access. If required by law, upon request, we will grant reasonable access to the personal information that we hold about you, including in some cases the right to data portability. You can exercise this right by contacting us at support@14e.com.
    • Request Deletion. In certain circumstances, if required by law, upon request, we will delete your personal information. We may also decide to delete your data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. There are some situations in which we may decline to delete your personal information. For example, we may keep your personal information as needed to comply with our legal obligations, where permitted by law, to resolve disputes, and/or to enforce any of our agreements. You can exercise this right by contacting us at support@14e.com.
    • Request Modification. You may request that we correct or update any of your personal information that is inaccurate or out-of-date by contacting us at support@14e.com.
    • Object to Processing. In certain circumstances, you may object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You may exercise this right by contacting us at support@14e.com.
    • Revoke Consent. We rely on the processing of personal information that you have provided. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may exercise this right by contacting us at support@14e.com.

If you are located outside the United States, and you are not satisfied with our response, you may have a right to lodge a complaint with your local data protection regulatory authority.

Third Party Applications/Websites

We have no control over the privacy practices of websites or software applications that we do not own. To enhance your experience on our website, we may use applications provided by third parties or link to websites operated by third parties. Your use of such services is subject to the privacy policies of such third parties applicable to their applications and websites.

Contact Information

If you have any questions, comments or complaints concerning our privacy practices please contact us at support@14e.com. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.

Changes To This Privacy Policy

We may change our Privacy Policy and privacy practices over time. To the extent that this Privacy Policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information.

Last updated: September 9, 2020.

California Information Sharing Disclosure

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 state that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). The table below indicates the categories of personal information we collect and transfer in a variety of situations. Because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments of membership fees and registration fees, and payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals who only provide us feedback or contact us for support.

Category of Personal Information

Is information collected by us?

Is information transferred for valuable consideration?

Is information shared with service providers for business purposes?

Audio Information (e.g., recordings of customer service calls for quality, training and security purposes)

YES

NO

YES

Visual Information (e.g., photographs provided with an application for membership)

YES

NO

YES

Bank account number (e.g., if you voluntarily provide it to us in connection with an application for membership)

YES

NO

YES

Biometric information (e.g., your iris scan and fingerprints provided with an application for membership)

NO

NO

NO

Commercial information (e.g., payments you made)

YES

NO

YES

Credit card number (e.g., if you voluntarily provide it to us in connection with an application for membership)

YES

NO

YES

Debit card number (e.g., if you voluntarily provide it to us in connection with an application for membership)

YES

NO

YES

Driver’s License Number / State ID

YES

NO

YES

Education (e.g., in some cases to assess your qualifications for membership in the Program)

YES

NO

YES

Electronic network activity (e.g., browsing history)

YES

NO

YES

Email address (e.g., to send you emails in connection with your application to become a Member of the Program, and to send you promotional emails relating to the Program)

YES

NO

YES

Employment (e.g., in some cases to assess your qualifications for membership in the Program)

YES

NO

YES

Employment history (e.g., in some cases to assess your qualifications for membership in the Program)

YES

NO

YES

Health insurance information

NO

NO

NO

Identifiers (e.g., name you provide to us, or the IP address assigned to your computer when you use the Internet and visit our website)

YES

NO

YES

Insurance Policy Number

NO

NO

NO

Medical information (e.g., when we assess your qualifications to become a Member of the Program)

NO

NO

NO

Other financial information (e.g., when we assess your qualifications to become a Member of the Program)

YES

NO

YES

Passport Number

NO

NO

NO

Physical Characteristics (e.g., if you provide us with a photograph)

YES

NO

YES

Postal address (e.g., in connection with your application to become a Member of the Program, or to send you promotional materials relating to the Program)

YES

NO

YES

Signature (e.g., to process credit card or debit card transactions)

YES

NO

YES

Social Security Number

NO

NO

NO

Telephone Number (e.g., to communicate with you about your application to become a Member of the Program, to respond to you if you contact customer service, or to send you SMS messages if you signed up to receive messages)

YES

NO

YES

Transaction information (e.g., to process your payment of membership fees for membership in the Program)

YES

NO

YES