This Privacy Policy explains how Baumgarten Capital, LLC (“Baumgarten Capital,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information when you interact with our website, consulting services, and any software, platform, portal, or hosted service that links to this Policy.
1. Scope and our role
This Policy applies to personal information we handle through the Baumgarten Capital website, direct business communications, consulting engagements, and covered software-as-a-service offerings (collectively, the “Services”). It does not apply to third-party websites, products, or services that have their own privacy notices.
When you communicate or contract directly with us, Baumgarten Capital generally determines why and how the relevant personal information is used. When we process information through a SaaS product on behalf of a business customer, that customer generally determines the purposes and means of processing, and Baumgarten Capital acts as its service provider or processor. Section 6 explains this distinction in more detail.
2. Information we collect
Information you provide
Depending on how you interact with the Services, we may collect:
- Contact and professional information, such as your name, business email address, telephone number, title, employer, and professional profile;
- Account information, such as login credentials, account preferences, organization membership, and authentication details for a covered SaaS service;
- Engagement and transaction information, such as service inquiries, proposals, contracts, subscription details, invoices, and limited billing records;
- Communications, including emails, meeting information, support requests, feedback, and other correspondence;
- Customer content, such as files, text, records, instructions, or other data submitted to a covered SaaS service; and
- Other information you choose to provide.
If online payment functionality is offered, payment-card information may be collected directly by a third-party payment processor. We may receive limited transaction details but generally do not receive the complete payment-card number.
Information collected automatically
Our hosting, security, and service infrastructure may automatically process technical information such as IP address, browser and device type, operating system, approximate location derived from IP address, pages or features accessed, referring page, timestamps, diagnostic data, and security or activity logs. Covered SaaS services may also record account activity, feature interactions, configuration events, and performance information needed to operate and secure the service.
Information from other sources
We may receive relevant information from your organization, its administrators, referral sources, business partners, integrations you or a customer enables, service providers, and lawful public or professional sources. We use information obtained from another source consistently with this Policy and any additional restrictions imposed by that source.
Sensitive information
Please do not send sensitive personal, confidential, or regulated information through an initial website or email inquiry. A SaaS customer should submit sensitive information only when the applicable agreement permits it and appropriate safeguards and instructions are in place.
3. How we use information
We may use personal information to:
- provide, administer, and support consulting engagements and covered SaaS services;
- create and manage accounts, authenticate users, and follow customer instructions;
- respond to inquiries, schedule conversations, provide support, and manage business relationships;
- process subscriptions, invoices, and related business transactions;
- operate, monitor, secure, troubleshoot, and improve the Services;
- detect, investigate, and prevent fraud, misuse, security incidents, and violations of applicable terms;
- develop and evaluate features using aggregated, de-identified, or otherwise permitted information;
- send administrative notices and, where permitted, relevant business communications;
- maintain records, enforce agreements, protect rights and safety, and resolve disputes;
- comply with applicable law, regulation, legal process, and professional obligations; and
- carry out another purpose disclosed when information is collected or with your direction or consent.
5. How we disclose information
We may disclose personal information to:
- Service providers and processors that support hosting, security, communications, customer support, payments, professional services, and business operations;
- Your organization and its administrators when you use an organization-managed account or service;
- Integrations and third-party services that a customer or user chooses to enable;
- Professional advisers, such as attorneys, accountants, auditors, insurers, and consultants, subject to appropriate obligations;
- Government authorities or other parties when reasonably necessary to comply with law or legal process, enforce agreements, investigate misuse, or protect rights, safety, and security;
- Transaction participants in connection with a financing, merger, acquisition, reorganization, sale of assets, or similar corporate event; and
- Other recipients at your direction, with your consent, or as otherwise disclosed when information is collected.
We may also use and disclose aggregated or de-identified information that cannot reasonably be linked to an individual, subject to applicable law. Under our current practices, Baumgarten Capital does not sell personal information for money or share it for cross-context behavioral advertising. If those practices change, we will update this Policy and provide legally required choices before the change applies.
6. SaaS customer data
Business customers may submit or make available personal information through a covered SaaS service (“Customer Data”). The customer is responsible for providing required notices, obtaining necessary rights and permissions, configuring the service appropriately, and responding to individuals whose information is included in Customer Data. Baumgarten Capital processes Customer Data to provide, secure, support, and maintain the service and as otherwise permitted by the applicable customer agreement and law.
If your information was submitted by or for one of our business customers, please direct your privacy request to that customer first. We may refer the request to the customer and assist it as required by contract or applicable law. This Policy does not replace a customer’s own privacy notice.
7. Retention and security
We retain personal information for as long as reasonably necessary to provide the Services, maintain the relevant account or business relationship, follow customer instructions, comply with legal and contractual obligations, resolve disputes, enforce agreements, and protect the Services. Retention periods vary based on the nature and sensitivity of the information, the purposes for processing it, applicable requirements, and operational needs. When information is no longer required, we take reasonable steps to delete, de-identify, or securely dispose of it.
We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No security measure, internet transmission, or storage system can be guaranteed completely secure, and we cannot promise absolute security.
8. Privacy rights and choices
Depending on where you live and subject to applicable exceptions, you may have the right to request access to personal information, obtain a portable copy, correct inaccurate information, request deletion, restrict or object to certain processing, withdraw consent, or opt out of certain sales, targeted advertising, or profiling. You may also have the right to appeal our response and to exercise your rights without unlawful discrimination.
To submit a request concerning information Baumgarten Capital controls, email luke@baumgartencapital.com with “Privacy Request” in the subject line. Describe the request and identify your relationship with us. We may request information reasonably necessary to verify your identity, authority, and applicable jurisdiction. Authorized agents may submit requests where permitted by law, subject to verification of their authority.
Our current practices do not involve selling personal information or using it for targeted advertising, so an opt-out signal may not require a change to how we process information. If applicable practices change, we will provide required controls and recognize legally required universal opt-out signals. You may unsubscribe from nonessential marketing email using the instructions in the message or by contacting us. Administrative and transactional communications may continue when necessary.
9. International users
Baumgarten Capital is based in the United States, and information may be processed in the United States and other countries where we or our service providers operate. Those countries may have different data-protection laws. Where applicable law requires a transfer mechanism or safeguard, the relevant transfer will be addressed through appropriate contractual or other lawful means.
If data-protection law in the European Economic Area, United Kingdom, or Switzerland applies, our legal bases may include performance of a contract, legitimate interests in operating and protecting the Services and business, compliance with legal obligations, and consent where required. Applicable law may give you rights to access, correct, erase, restrict, port, or object to processing, withdraw consent, and complain to your local supervisory authority.
10. Children’s privacy
The Services are designed for business and professional use and are not directed to children under 13. We do not knowingly collect personal information directly from children under 13 through the public website. Customers are responsible for ensuring that any use of a covered SaaS service involving children is authorized and complies with applicable law and the customer agreement. If you believe a child provided personal information improperly, contact us so we can review the matter.
11. Third-party services and links
The Services may link to or integrate with third-party websites, applications, or services. Their privacy practices are governed by their own notices, and Baumgarten Capital is not responsible for those independent practices. Review the applicable third-party notice before providing information or enabling an integration.
12. Changes to this Policy
We may update this Policy to reflect changes in the Services, our practices, or applicable requirements. The “last updated” date identifies the current version. If a change is material, we will provide additional notice when required by law, such as through the relevant Service or by direct communication.
13. Contact us
For privacy questions, requests, or concerns, contact Baumgarten Capital, LLC at luke@baumgartencapital.com.
This Policy describes general privacy practices and does not create contractual rights beyond applicable law or an applicable written agreement. Privacy obligations depend on actual services, data flows, vendors, contracts, users, and jurisdictions.