PRIVACY POLICY.

Effective Date: January 13, 2026

BSquare Advisors LLC (“BSquare Advisors,” “we,” “us,” or “our”) is committed to protecting the privacy, confidentiality, and security of personal information in compliance with applicable federal, state, and District of Columbia laws, including:

  • New York Stop Hacks and Improve Electronic Data Security Act (NY SHIELD Act)

  • New York General Business Law §899-aa

  • California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA)

  • District of Columbia Data Breach Notification Law (D.C. Code § 28–3851 et seq.)

This Privacy Policy explains how we collect, use, disclose, safeguard, and respond to incidents involving personal information obtained through our website and related communications.

1. Scope

This Privacy Policy applies to:

  • Website visitors

  • Clients and prospective clients

  • Business contacts and service inquiries

  • Residents of New York, California, Washington, D.C., and other U.S. jurisdictions

By accessing or using our website, you agree to this Privacy Policy.

2. Information We Collect

a. Personal Information

We may collect the following categories of personal information:

  • Identifiers (e.g., name, email address, phone number)

  • Professional or employment-related information (e.g., company name, job title)

  • Communications and inquiry content

  • Internet or electronic activity information (e.g., IP address, browsing activity)

We do not intentionally collect sensitive personal information unless voluntarily provided for a legitimate business purpose.

b. Automatically Collected Information

We may automatically collect:

  • IP address

  • Browser type and operating system

  • Device identifiers

  • Pages visited and time spent

  • Referring URLs

This information is collected through cookies, analytics tools, and similar technologies.

3. How We Use Personal Information

We use personal information to:

  • Respond to inquiries and provide requested services

  • Deliver consulting, advisory, communications, and strategic services

  • Manage operations and professional relationships

  • Improve website functionality and performance

  • Send professional updates or marketing communications (where permitted)

  • Comply with legal, regulatory, and contractual obligations

We do not sell personal information and do not share personal information for cross-context behavioral advertising.

4. Cookies and Analytics

Our website uses cookies and analytics tools to understand site usage and improve performance. You may control cookie preferences through your browser settings. Disabling cookies may limit certain features of the website.

5. Disclosure of Personal Information

We may disclose personal information:

  • To service providers acting on our behalf under confidentiality and data security obligations

  • To comply with applicable laws, subpoenas, or lawful government requests

  • To protect the rights, property, or safety of BSquare Advisors or others

We do not disclose personal information for independent third-party marketing purposes.

6. Data Security (NY, CA & D.C.)

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information, including:

  • Access controls and authorization limitations

  • Secure systems and encryption where appropriate

  • Periodic review of data protection practices

While we take reasonable steps to protect personal information, no system can be guaranteed to be completely secure.

7. Data Retention

Personal information is retained only for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy or as required by applicable law.

8. Data Breach Notification (New York & Washington, D.C.)

a. Definition of a Data Breach

A “data breach” means the unauthorized access to or acquisition of computerized data that compromises the security, confidentiality, or integrity of personal information.

Personal information may include an individual’s name in combination with one or more of the following:

  • Social Security number

  • Driver’s license or non-driver identification number

  • Financial account, credit, or debit card information

  • Biometric information

  • Username or email address combined with a password or security credentials

b. Notice to Affected Individuals

In the event of a data breach involving personal information of New York or Washington, D.C. residents, BSquare Advisors will provide notice in the most expedient time possible and without unreasonable delay, consistent with:

  • The legitimate needs of law enforcement; and

  • Measures necessary to determine the scope of the breach and restore system integrity

Notice may be provided by written notice, electronic notice, or substitute notice, as permitted by law.

c. Content of Breach Notice

Where required by law, breach notifications will include:

  • A description of the incident

  • The type of personal information involved

  • The date or estimated date of the breach

  • Contact information for BSquare Advisors

  • Steps individuals may take to protect themselves

  • Information on obtaining additional assistance

d. Government Notification

As required by law:

  • New York residents: We will notify the New York State Attorney General, Department of State, and Division of State Police.

  • Washington, D.C. residents: We will notify the District of Columbia Attorney General if a breach affects D.C. residents.

Consumer reporting agencies will also be notified where required by applicable thresholds.

e. Law Enforcement Delay

Notification may be delayed if a law enforcement agency determines that notice would impede a criminal investigation. Notification will be provided promptly once such determination is lifted.

9. California Privacy Rights (CPRA)

This section applies to California residents.

California residents have the right to:

  • Know what personal information we collect, use, and disclose

  • Access personal information we maintain

  • Request deletion of personal information, subject to legal exceptions

  • Correct inaccurate personal information

  • Limit the use of sensitive personal information (if applicable)

  • Not be discriminated against for exercising privacy rights

BSquare Advisors does not sell or share personal information as defined under the CPRA.

Requests may be submitted by contacting us at:
Email: compliance@bsquareadvisors.com

10. Rights of New York and Washington, D.C. Residents

Residents of New York and the District of Columbia may request:

  • Access to personal information we maintain

  • Correction of inaccurate personal information

  • Deletion of personal information, where permitted by law

  • Opt-out of non-essential communications

Requests may be submitted using the contact information below.

11. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites.

12. Children’s Privacy

Our website is not intended for children under the age of 13, and we do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Changes will be effective upon posting with an updated effective date. Continued use of the website constitutes acceptance of the revised policy.

14. Contact Information

For questions regarding this Privacy Policy or privacy rights requests:

BSquare Advisors LLC
Email: compliance@bsquareadvisors.com

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