Privacy Policy

This Privacy Policy explains the manner in which BTM USA and its affiliates collects, utilizes, and maintains nonpublic personal information about its clients and potential clients. This Privacy Policy applies only to nonpublic personal information about individuals who subscribe to products and services provided by BTM USA, including its affiliates, for immigration, investment, or other offered services, or who provide information in connection with their consideration of such services (the “Clients”).

BTM USA collects nonpublic personal information about the Clients from the following sources:  subscription forms, questionnaires, and other information provided by the Clients in writing, in person, by telephone, electronically, or by any other means (including name, address, nationality, social security number or tax identification number, employment information, and financial and investment qualifications); and transactions (including account balances, investments, and withdrawals and redemptions).

Disclosure of Nonpublic Personal Information

BTM USA may share nonpublic personal information about the Clients as permitted by law, including to assist in offering or providing BTM USA’s products and services to the Clients. BTM USA does not disclose nonpublic personal information about the Clients to nonaffiliated third parties except as permitted by law.  For example, BTM USA may share nonpublic personal information with nonaffiliated third parties in the following situations:

• To comply with federal, state, or local laws, rules, and other applicable legal requirements

• To comply with a properly authorized civil, criminal, or regulatory investigation or a subpoena or summons by federal, state, or local authorities

• In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of BTM USA’s business

• To protect against or prevent actual or potential fraud, unauthorized transactions (such as money To), claims, or other liabilities

• To BTM USA’s service providers (which may include, for example, attorneys, accountants, auditors, administrators, or other professionals) in connection with the administration and operations of BTM USA

• To persons acting in a fiduciary or representative capacity on behalf of the Client (which BTM USA has determined it will do only with the Client’s consent)

Protection of Client Information

BTM USA and its affiliates have adopted written policies and procedures, safeguards, and a security program (collectively, the “Information Security Program”) to protect client personal information.  The Information Security Program includes physical, electronic, and procedural safeguards that comply with federal standards to protect customer information and includes policies designed to ensure that access to personal and account information concerning the Clients is restricted to those employees or agents who need to know that information in the course of their job responsibilities.  Pursuant to the Information Security Program, BTM USA will destroy, erase, or make unreadable data, computer files, and documents containing nonpublic personal information prior to disposal.

The Information Security Program also is designed to identify risks to the confidentiality and security of records containing personal information and includes procedures for assessing the likelihood of and potential damage from such threats.  Technical, physical, and administrative safeguards are in place for the protection of personal information and are regularly monitored for effectiveness.  In addition, the only third-party service providers permitted to be in possession of client personal information are those which BTM USA reasonably believes have appropriate security measures in place to protect that information.

Former Clients

The same Privacy Policy applies to former clients.

Further Information

BTM USA reserves the right to change this Privacy Policy at any time.  The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive.  This notice complies with federal law.  Clients may have additional rights under other applicable foreign or domestic laws.

International Visitors

The Services may be accessed and/or used by users located outside the United States in accordance with our Terms of Use and other policies and procedures posted on this website. If you choose to use the Services from the European Union (EU) or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the services you consent to that transfer.

Contact Information

Please contact BTM USA with any questions or comments about this Privacy Policy, your personal information, or your choices with regards to our collection and use of your personal information, email at [email protected].