We Safeguard Your Privacy
Bdellium, Inc., a Delaware corporation and its affiliates (“Bdellium”, “we”, “our”) develop decision support tools that enable financial service providers to improve retirement outcomes and grow their business. We provide services through websites that use the top-level domain names www.bdellium.com, www.qdia.com and www.pdor.com, and sub-domains under these top level domains (each a “Site”, collectively the “Sites”).

Sometimes we need to gather and use personal information in order to provide our services. However, we also understand the value you place on maintaining your privacy. That is why we implement strict policies and procedures that govern the collection, maintenance, use, and disclosure of personal information about users of our services. These policies may change from time to time but at all times they are designed to safeguard your personal information and keep it confidential.

What Information is Collected
If you use Bdellium’s services or contact us through any of the Sites, or send us an email or other communication, Bdellium may collect personally identifiable information, such as your full name, company name, title, contact information including email address and demographic information such as postcode and preferences.

In addition, in the course of using our services Bdellium may collect personal information about your clients, including individual dates of birth, gender, earnings, financial account balances, saving, spending and investing activities. Bdellium has implemented procedures and systems so that certain personal information can be gathered and used in an anonymized format to provide Bdellium’ services without personally identifying the individual to whom the information relates. Bdellium also explicitly prohibits every user of its Sites and services from disclosing to Bdellium any information that can personally identify any other individual, including but not limited to that individual’s name or social security number, and/or any information deemed to be personally-identifiable information under applicable federal and state laws.

We use cookies, tags and other standard software on the Sites and in emails that automatically record information about everyone who visits a Site or receives an email from us. In the case of a Site visit, these records contain information about (a) the internet domain from which you access a Site, (b) your IP address, (c) the type of browser you used when you visited a Site, (d) the date and time you visited a Site, (e) the Site pages you visited and your activities on each page and (f) if you linked to a site from another website, the address of that website. In the case of an email, the information includes whether the email has been opened and whether a particular link has been clicked.

How Information is Used
Bdellium will never sell or rent your information. However, Bdellium may share your information with other companies or individuals who help us to provide services to you (“Partners”). In all cases, our written agreements with those companies require them to hold all user information in the strictest confidence and not to disclose it to any person, or entity, or to use it except as necessary in carrying out the purpose for which it was shared and consistent with Bdellium’s privacy and security standards.

Bdellium and our Partners may each use your information for internal record keeping, to provide and improve products and services, to conduct market research and evaluate user needs, to send promotional information about products, services or special offers, to share other information that we think you might find interesting, or for any other purpose to which you consent.

We and our Partners may store your information for as long as is required for the uses described in this privacy policy, which might be indefinitely. At any time you may choose to opt-out of receiving any communications from Bdellium or request Bdellium to update or remove your information by sending an email to info@bdellium.com. Bdellium will comply with any such request as promptly as practical. However, you might receive communications for a transitional period whilst we process your records.

Special Cases of Information Disclosure
It is possible that Bdellium could be required to disclose personal information in response to valid legal process, such as a search warrant, subpoena, or court order. All record keepers face the possibility that disclosure of their records may be compelled in some civil, criminal, or administrative matters. Disclosures may also be appropriate to protect Bdellium’s legal rights or during emergencies if physical safety is believed to be at risk. We think that these events are unlikely, but they are possible. We will take reasonable steps to limit the scope and consequences of any of these disclosures. If we receive a subpoena demanding disclosure of your records, we will make reasonable efforts to notify you of the subpoena when possible.

If all or substantially all of our assets were acquired, through a sale, merger, or other transfer to another third party, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, user data would be one of the assets that is transferred or acquired by a third party. Any acquirer of our assets may continue to use user data as set forth in this policy.

Security Standards
We have implemented physical, technological and operational safeguards in order to protect your personal information from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Only authorized personnel are provided access to personal information and only to the extent necessary to fulfill their duties. These personnel are required to treat personal information as confidential and access to such data is monitored and recorded.

Bdellium is a global organization. In the normal course of our business we may transfer to, or store user data in a country other than the one in which the user resides. Although the data protection legislation in some countries may not be as comprehensive as that in your own country, we will take reasonable steps to protect user data as described in this Privacy Policy. By accessing or using a Site and accepting the terms of this Privacy Policy, users acknowledge and consent to the transfer of their personal data in this way.

Legal Disclaimer
While Bdellium has endeavored to create secure and reliable Sites for you, we cannot guarantee or warrant that unauthorized persons will not obtain access to your personal information or that information that you transmit or otherwise supply to us, or any communications conducted on or through a Site, is or will be totally secure. When disclosing any personal information on any website, including ours, or in any email you should remain mindful of the fact that it is potentially accessible to the public, and consequently, could be collected and used by others without your consent.

You should remember that you access any Site solely at your own risk and are ultimately responsible for maintaining the secrecy of your own personal information. Bdellium cannot assume responsibility or liability for the security of personal information transmitted via the internet.

Moreover, to the extent hyperlinks are utilized to access third-party sites, you should be aware that these third-party web sites are not controlled by Bdellium and therefore, are not subject to this Privacy Policy. You should check the privacy policies of the individual sites to see how they may utilize your personal information, as Bdellium is not responsible for the separate policies or practices of partners or third-party internet websites.

Changes and Updates
In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice so please check back periodically so that you are aware of any changes. This Privacy Policy should be read in conjunction with and is subject to our Terms of Use.

Contact Information
If you have any questions about this privacy policy or feel that your privacy has been compromised, please contact us at info@bdellium.com or alternatively:

Bdellium, Inc.
Seven Waterfront Plaza, Suite 400
500 Ala Moana Blvd.
Honolulu, Hi 96813