Bidwell Investment Group, LLC Privacy Notice

Bidwell Investment Group, LLC (collectively, “Bidwell Investment Group” “Bidwell” “we”, “us”, or “our”) are committed to transparency in the collection and use of your personal information.

This notice (the “Privacy Notice”) sets forth a description of how we collect and use personal information, and the circumstances under which we may share this information. This Privacy Notice also describes your data protection rights, including your right to object to some of the processing which Bidwell Investment Group carries out. More information about your data protection rights and how to exercise them are set out below. This Privacy Notice applies to all visitors to Bidwell Investment Group’s website, located at https://bidwellinvestmentgroup.com (the “Website”).

Collection and Use of Information

Information That You Provide: Bidwell Investment Group may collect and use the personal information such as your name, address, email address, signature, and other information that you provide in connection with the following:

Visiting our Website;
Apply to onboard with us; and
Contacting us with a comment, question or complaint.

Onboarding Information: To onboard as a counterparty through our Website, you are required to provide us with your full name, email address, gender, residential address, birth date, phone number, country of residence and nationality, employment information and status, national and governmental identification information, and financial and banking details, including any joint account holders and people appointed to act on your behalf. Bidwell Investment Group uses this information to undertake anti-money laundering and fraud prevention activities and know your customer reviews.

If you do not provide personal information that we tell you is mandatory, it may mean that we are unable to onboard you or provide you with services/perform all our obligations under our agreement with you.

If you give us personal information about other people (such as joint account holders), you confirm that they are aware of the information in this Privacy Notice about how we will use their personal information, including but not limited, use of their personal information to provide services or, if asked, to share such information with third parties (e.g. to provide payment initiation).

Once you have been onboarded as a counterparty, Bidwell Investment Group will continue to use this information as necessary to effect transactions with you.

We also obtain data about you from other sources, including identity verification services, fraud prevention agencies, websites and other publicly accessible information about you. We will also receive data you submit to us through third-party websites.

Communications: You may request to receive communications about Bidwell Investment Group and its products and services from us, through our Website or connect with us on third party websites (including through social media sites). If you signup through our Website or request to receive communications from us, we collect certain personal information (such as first and last name and email address) which we use to send you email and other communications to keep you informed about our events and to tell you about products and services that may be of interest to you. You can ask us to stop or start sending you such marketing messages at any time by writing, electronic messaging or calling us.

Contact Information: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, phone number and email address) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. If you interact with us through social media or other channels we may store details of these interactions.

Automatically-Collected Information: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system, average time spent on our Website and how you are using our Website. We use this information to help us understand activity on our Website and to monitor and improve our Website. We may also collect information from your digital devices so as to perform checks required to meet our regulatory obligations; for example we may identify your IP address in order to ascertain and verify your residency status.

Information Collected with Consent: When we are required to do so by law we may obtain consent to collect and use certain types of personal information (for example when we place cookies on your devices or browsers). If we ask for your consent to process this personal information you can withdraw your consent at any time by using the details at the end of this policy.

Purposes & Lawful Basis

Purpose	Legal basis for data processing
Onboarding and trading activities	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is permitted with your consent Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and compliance reporting requirements
Communication about services for legal, regulatory and servicing purposes	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject
Managing complaints, undertaking remediation activities and resolving queries	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, resolving and investigating complaints and improving our services
Monitoring communications to check your instructions to us, analyze and improve our services and for training and quality purposes	Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, developing and improving our systems, training our staff and providing a high standard of service
Undertaking checks for security, fraud prevention, anti-money laundering and verifying identity (both before providing services and when communicating to ensure we are dealing with the correct person)	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and compliance reporting requirements
Recovering debt and enforcing other obligations as our agreement entitles us, as well as to protect our rights and property interests	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, recovering debts owed to us and protecting our assets
Complying with regulatory and legal obligations and cooperating with regulators and law enforcement	Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and compliance reporting requirements For sensitive data (see below) where processing is in the public interest
Preparing high-level anonymized statistical reports. The information in these reports is never personal and you will not be identifiable from it. We may share these reports with third parties or we may use them for our own analytical purposes	Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, analysing our services and how they are used so as to identify potential improvements
Website related activities (e.g. dealing with enquiries, running analytics)	Processing is necessary for the performance of a contract Processing is necessary for compliance with a legal obligation to which Bidwell Investment Group is subject Processing is permitted with your consent Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, improving and developing new website services, being more efficient and protecting our systems and networks
Marketing communications	Processing is necessary for the purpose of the following legitimate interests pursued by Bidwell Investment Group or others which are not overridden by the interests or fundamental rights and freedoms of affected data subjects: this includes, but is not limited to, providing you with information about our products and services that may be of interest Processing is permitted with your consent
Processing sensitive data to comply with regulatory and legal obligations and cooperate with regulators and law enforcement	Processing is in the public interest

Note: We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Notice.

Disclosure and Transfer of Information

We do not transfer, sell, rent, trade or otherwise disclose your personal information, except as described in this Privacy Notice. We may transfer or disclose your personal information as follows:

Service Providers: Your personal information may be disclosed, stored and / or transferred (or otherwise made available) to third parties who provide services such as identification and background checks, cloud-based information hosting and maintenance, website hosting, record keeping, and analytics, and to exchanges, trading platforms and financial institutions

Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable United States law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: Your personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Bidwell Investment Group or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Safeguarding and Retention of Personal Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We have employed reasonable measures designed to restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have personal information retention processes designed to retain personal information for specified periods of time necessary for legal and business purposes.

Where we process data for onboarding and trading purposes, we keep your personal information for the following time periods:

If you are onboarded as a counterparty with Bidwell Investment Group: for as long as you are a counterparty and for five (5) years thereafter.
If you are not onboarded as a counterparty with Bidwell Investment Group: for no more than five (5) years unless you requested to receive future communications from Bidwell Investment Group.

Where we process contact information and analytics data provided by using and visiting our Website, we do this for as long as you are an active visitor of our Website and for three (3) years after this or as we are required by law.

Where we process personal information for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Your Rights Relating to Personal Information

You have the right to access (ask for a copy of your personal information), update, correct or delete your personal information in our custody and control, and restrict (stop any active) processing of your personal information, subject to certain exceptions prescribed by law. You may request access, updating, deletions and corrections of inaccuracies in other personal information we have in our custody or control by emailing or writing to us at the contact information set out below. You may also obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller. We may request certain personal information for the purposes of verifying your identity when seeking access to personal information records.

In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.

If you have unresolved concerns, you have the right to complain to a data protection authority where you live, work or where you believe a breach may have occurred.

Your California Privacy Rights

California residents, please review the California Privacy Notice for information about certain legal rights.

Your Nevada Privacy Rights

Nevada residents have the right to request that their personal information not be sold (as defined under applicable Nevada law), even if their personal information is not currently being sold. Requests may be sent to [email protected] and are free of charge.

Cookies and Additional Information about our Website

Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which may then be stored on your hard drive so our systems can recognize you while you are using our Website when you return. We use cookies:

Session Management: On the pages on our Website where you are prompted to log in or that are customizable. If you have registered with our Website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers) in order to provide personalized services, and (3) will provide us and our service providers with information that we will use to personalize our Website in accordance with your preferences and interests.
Analytics: We and our service providers (such as Google Analytics) also use cookies to help us understand our website activity and to improve our Website. For more information about Google Analytics, see Google policies

Tracer Tags & Web Beacons: Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our Website. These tracer tags are used to help us optimize and tailor our Website.

Do Not Track Signals: We use analytics systems and providers that process personal information about your online activities over time on our Website, but not across third party websites or services. These systems and providers may provide some of this information to us. Our Website also recognizes “do not track” signals or similar mechanisms of most web browsers, and we will comply with such requests as required by law.

Third Party Websites

Our Website may contain content and links to third party websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on such a link, you will leave our Website and go to another site. During this process, another entity may collect personal information from you, and that collection is subject to the third party’s privacy policy/notice, so please refer to those third-party privacy policies/notices to understand how those parties may process your personal information.

We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture and gender) to deliver the content or as part of the operation of the Website, plug-in or application.

Use by Minors Prohibited

The Website is not designed or intended for use by children under the age of 18, and we do not knowingly collect information from children. If you are under the age of 18, do not use the Website.

Updates to the Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to our privacy practices. We encourage you to periodically review this page for the latest information on our privacy practices, and any use of our Website after any updates constitute your acknowledgement that you have read the updated Privacy Notice.

Contact Us

Please contact us if:

you have any questions or comments about this Privacy Notice;
you wish to access, update, and/or correct inaccuracies in your personal information; or
you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

You may contact us by email at [email protected] or by mail at the following address:

Bidwell Investment Group, LLC
5123 West 98th Street #144
Minneapolis, MN 55437

Last updated: January 1, 2020

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Bidwell Investment Group, LLC is the managing partner of Bidwell Investment Fund, LLC (“the Fund”). This Website does not constitute an offer to sell and is not an offer or solicitation of an offer in respect of an investment in the Fund and should not be construed as an offer of any kind or the solicitation of an offer to buy interests in the Fund in any state or jurisdiction to any person to whom it is unlawful to make such offer or solicitation. Any such offer or solicitation shall be made only to qualifying investors, and only pursuant to the Offering Memorandum for the offering of shares of the Fund (the “Offering Memorandum”), Subscription Agreement for interests of the Fund, and organizational documents of the Fund, which describe the terms applicable to the Fund and certain risks related to an investment in the Fund and which qualify in their entirety the information set forth herein. Such documents and disclosures should be read carefully prior to an investment in the Fund. This Website does not constitute part of any such documents.

Purchasing cryptocurrencies comes with several risks, including volatile market price swings or flash crashes, market manipulation, and cybersecurity risks. In addition, cryptocurrency markets and exchanges are not regulated with the same controls or customer protections available in equity, option, futures, or foreign exchange investing. Investors should carefully review and consider potential risks before investing in the Fund. For a complete list see “Risk Disclosure” in the Offering Memorandum.

Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. All securities involve risk and may result in partial or total loss of your investment. While the data we use from third parties is believed to be reliable, we cannot ensure the accuracy or completeness of data provided by investors or other third parties. Neither Bidwell Investment Group nor any of its affiliates provide tax advice and do not represent in any manner that the outcomes described herein will result in any particular tax consequence. Prospective investors should confer with their personal tax advisors regarding the tax consequences based on their particular circumstances. Bidwell Investment Group does not assume responsibility for the tax consequences for any investor of any investment.