Privacy Policy | Black Hawk Resources

Thank you for visiting Black Hawk Resources Limited’s website. This Privacy Policy explains how Black Hawk Resources Limited (referred to as “Black Hawk,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information from users who visit our website and use our services, including our general educational materials and any market signals provided to subscribers (collectively, the "Services"). It also describes your rights and choices regarding your personal data and how you can contact us about our privacy practices.

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our practices, please do not access or use the Services. We may update this Policy from time to time (see "Changes to This Policy" below). If you have any questions about our privacy practices, please contact us using the information provided in the "Contact Us" section.

We are committed to protecting your privacy and complying with applicable data protection and privacy laws. Because our audience and users may be international, we strive to adhere to U.S. privacy laws (including the California Consumer Privacy Act, “CCPA”), the EU and UK General Data Protection Regulation (“GDPR”), and other relevant international privacy regulations and best practices.

1. Information We Collect

We collect various types of personal information about you in order to provide and improve our Services, to communicate with you, and to carry out our business operations. "Personal information" (also referred to as "personal data") means any information that identifies, relates to, describes, or can be reasonably linked to an individual. The types of personal information we collect may include:

Contact Information: such as your name, email address, phone number, mailing address, and other identifiers. We collect this information when you register for an account, subscribe to our Services, fill out forms (for example, to download materials or request information), or communicate with us.
Account and Login Data: If you create an account on our site, we collect your login credentials (such as username and password). Passwords are stored in an encrypted format.
Geographic Information: We may collect your general geographic location, such as country, state, or region. This may be derived from your IP address or you may provide it directly (for example, selecting your location during sign-up). We do not collect precise geolocation (exact GPS coordinates) without your explicit consent.
Usage and Technical Data: We automatically collect information about how you access and use our website and Services. This may include your IP address, device identifiers, browser type, device type, operating system, referring URLs, pages viewed, links clicked, the dates/times of access, and other usage statistics. If you are a subscriber, we may track your use of the paywalled content to understand your interests and improve your experience.
Cookies and Tracking Information: We and our third-party partners may use cookies, web beacons, and similar tracking technologies to collect information about your interactions with our
site and emails. This may include information about your browsing behavior and usage patterns. See "Cookies and Tracking Technologies" below for more details.
Communications: If you contact us (such as through email, phone, or via our website forms), we will collect the information you provide in those communications (for example, your inquiries or feedback). We may also keep records of our correspondence with you.
Information from Third Parties: We may receive information about you from third-party sources. For example, if you engage with our content on social media or provide your information to our marketing partners or referral programs, those parties may share your information with us. We may also use third-party platforms like HubSpot for lead capture and customer relationship management (CRM); if you have interacted with us through a HubSpot form or marketing campaign, we will collect any information you provided (such as your name, contact details, company, and interests) through that platform.

We do not purchase personal data from data brokers or other sources.

We collect the above information either directly from you (for instance, when you provide it) or automatically through your use of the Services. In some cases, we may be required by law to collect certain personal data (for example, for identity verification or compliance as a regulated financial entity). You may choose not to provide certain information; however, this may limit your ability to register or use some features of the Services (for example, we need an email address to create an account).

2. How We Use Your Information

Black Hawk may use the collected information for various purposes consistent with the provision of our Services. The primary purposes for which we use your information include:

Providing and Improving the Services: We use the collected information to operate, maintain, and provide you with our content and Services. This includes using data to authenticate you when you log in, to process your subscriptions and transactions, to display personalized content, and to improve our content offerings based on usage patterns.
Customer Support and Communications: We use contact information and communication records to respond to your inquiries, provide customer support, send service-related announcements (such as subscription confirmations, technical notices, updates, security alerts), and to inform you of changes to our Services or this Policy.
Marketing and Promotional Communications: We may use your contact details and information about your preferences or usage to send you newsletters, educational materials, and promotions about our Services or new products that may interest you. We may also use tools like HubSpot to automate and personalize these marketing communications. You can opt out of marketing emails at any time by clicking the unsubscribe link in the email or contacting us (see "Your Rights and Choices" below).
Analytics and Product Development: We use usage and technical data (often in aggregated or de-identified form) to analyze how our website and Services are used, to troubleshoot
performance issues, to conduct research and development, and to improve the design, functionality, and content of our Services. For example, we use Google Analytics and similar tools to understand traffic patterns and user interactions on our site, which helps us enhance user experience.
Personalization: We may use cookies and collected data to remember your preferences and personalize your experience. For example, we might remember which content you've viewed or suggest similar content.
Security and Fraud Prevention: We process personal data as needed to maintain the security of our website, accounts, and users. This includes monitoring for suspicious activity, enforcing our terms of service, protecting against fraudulent transactions or misuse of our Services, and preventing or detecting illegal activities.
Legal and Compliance Purposes: As a CFTC regulated entity and NFA memebr, we are subject to certain financial regulations. We may use your personal information to comply with applicable legal and regulatory obligations (such as know-your-customer (KYC) requirements, anti-money laundering laws, record-keeping rules, or responding to lawful requests from authorities, as applicable). We also use and disclose information as necessary to exercise or defend legal claims or to protect our rights, property, and safety or those of our customers and others.

We will only use your personal information for the purposes outlined above or as otherwise disclosed to you at the time of collection. If we need to use your data for a materially different purpose, we will obtain your consent or provide required notice, as applicable.

3. Cookies and Tracking Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect data about your device and interactions with our Services. Cookies are small text files that websites store on your browser or device. They allow us and our third-party service providers to recognize your browser and remember information about your visit.

Types of cookies and why we use them:

Essential Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. For example, they enable you to log in, use our subscriber-only pages, and help us authenticate your account. Without these, some parts of our site may not work.
Analytics and Performance Cookies: We use these to understand how visitors move around our site and to improve the website. For instance, we use Google Analytics cookies to collect information on site usage and performance. This helps us know which pages are popular, observe traffic patterns, and fix issues. The information collected is generally aggregated and does not directly identify you. Google Analytics may collect data such as your IP address, but Google provides options to anonymize IP addresses. You can learn more about how Google Analytics handles data on Google's site, and you can opt out of Google Analytics by installing Google's browser opt-out add-on.
Functional Cookies: These cookies remember your preferences and settings to enhance your experience. For example, they might recall your language or region or keep you logged in during a session.
Advertising/Marketing Cookies: We (or our advertising partners) may use cookies and pixels to deliver relevant ads and marketing messages to you. If we engage in marketing on other platforms, cookies may be used to track the effectiveness of our ads or to reach users with similar interests. Additionally, if we send marketing emails, we may use tracking pixels to measure engagement (such as open and click rates).

We may also utilize HubSpot on our site, which may set cookies or similar trackers. HubSpot helps us identify visitors who have submitted forms, track their site usage, and tailor marketing efforts. For example, if you fill out a contact form or subscribe to a newsletter, HubSpot cookies allow us to recognize your subsequent visits and interactions, enabling us to provide more personalized content and follow up more effectively.

Your Choices Regarding Cookies

On your first visit to our site (and periodically as required), you may be presented with a cookie consent banner (particularly if you are in a jurisdiction like the EU/UK where consent is required for certain cookies). You can choose to accept or reject non-essential cookies. Even if you've accepted, you can always adjust your browser settings to refuse or delete cookies. However, please note that blocking certain cookies might affect the functionality of our Services. For more information on how to manage cookies, consult your browser's help documentation. Additionally, some third parties (like Google or HubSpot) may offer their own opt-out mechanisms for their cookies or analytics.
We currently do not respond to "Do Not Track" (DNT) signals from web browsers, because there is no consistent industry standard for compliance. We treat any user who has enabled a DNT signal the same as other users with respect to cookies, but you still have the options described above to manage cookies and tracking.

4. How We Share Your Information

We understand that your personal information is important, and we only share it with others in certain circumstances. We may disclose your personal information to the following categories of recipients for the business or commercial purposes described:

Service Providers: We may share personal information with third-party service providers and vendors who perform functions on our behalf and under our instructions. These may include:
- Analytics and Technology Partners: We may use partners like Google Analytics to process usage data and HubSpot for CRM and marketing automation. These partners may receive information (like your IP address, cookies, and site usage data or contact info in the case of HubSpot) in order to provide their services to us.
- Email and Communication Providers: We may use email service platforms (which could include HubSpot or other providers) to send out newsletters, signals, and account-related
  emails. These providers will have access to your email address and necessary information to send such communications.
- Hosting and Infrastructure: Our website and databases may be hosted on third-party servers or cloud platforms. Those providers may process stored data as part of providing infrastructure services.
- Contractors and Advisors: We may share information with professional advisors (like auditors, legal counsel, compliance consultants) who need access for advising us or auditing our compliance.
- Other Tools: We may use other software-as-a-service tools for things like billing or support ticketing. If these tools process personal data (like your name or email in a support ticket system), we ensure that those providers are bound by privacy and security obligations.
  
  These service providers are contractually required to protect your information and use it only for the purposes of providing their services to us (they are our "processors" or "service providers" under laws like GDPR/CCPA).
Affiliates: We may share your information with our affiliates (if any) as necessary for business operations, internal analytics, marketing, or to provide the Services. Any affiliate receiving your information will handle it with the same level of care and security as we do under this Policy.
Business Partners: We might share your information with partners in cases where we jointly offer services, or in joint marketing arrangements (for example, a co-hosted webinar or a special offer we co-sponsor).
Third-Party Marketers (Sale of Data):
- We do not sell or rent personal information to third-party companies for their own marketing and commercial purposes. This means that your personal information (such as your name, contact information, and information about your interests or usage of our Services) will not be shared with other companies who may want to offer you their products or services. We do not sell personal data of individuals who we know are under 16 years of age.
Legal Compliance and Protection: We may disclose your information when we believe in good faith that such disclosure is necessary to:
- Comply with a legal obligation, government request, or applicable law (e.g., in response to subpoenas, regulatory requests from agencies like the CFTC or NFA, court orders, or similar legal process).
- Protect and defend our rights or property, or the rights and safety of our customers, employees, or others. This could include sharing information with law enforcement or regulators if we suspect fraudulent or illegal activity, or to investigate violations of our terms or policies.
- In connection with audits, compliance checks, and regulatory reporting as required for our financial services business.
Business Transfers: If we undergo a business transaction such as a merger, acquisition by another company, sale of all or part of our assets, or in the unlikely event of bankruptcy or receivership, your personal information may be among the assets transferred or reviewed as part of the due diligence for such transaction. In such cases, we will ensure that any successor entity will be bound by terms substantially similar to this Privacy Policy with respect to your personal information (or we will obtain your consent if required by law).
Aggregate or De-Identified Data : We may share information that has been aggregated or de identified in such a way that it cannot reasonably be used to identify you. For example, we might publish aggregate statistics about Site usage (e.g., “Our site has X registered users from 50 countries” or “75% of our site visitors have over 5 years of trading experience”) or share these stats with partners. Such information does not contain any personal data and is used for industry analysis, research, marketing, and other legitimate business purposes.

We do not disclose any personal information to non-affiliated third parties except as described in this Policy, as you have otherwise authorized, or as permitted or required by law. Even if you cease to be our customer or subscriber, we will continue to protect your information as described here and honor any privacy opt-out choices you have made.

4.1 Legal Bases for Processing (EU/UK Users)

If you are located in the European Economic Area (EEA) or United Kingdom, we rely on the following legal bases to process your personal data:

Performance of a Contract: We process personal data to provide our Services as per our contract with you. For example, when you subscribe to our service, we must use your personal data to set up and maintain your account, provide access to paywalled content, send you the signals or educational materials you've paid for, and process payments.
Legitimate Interests: We process certain data for our legitimate business interests, in a way that is not overridden by your data protection rights. For instance: (i) To understand how users interact with our site (analytics) so we can improve our content and user experience; (ii) To send you marketing communications about our own Services if you are an existing customer (subject to your right to opt-out) – under GDPR this may be considered a legitimate interest; (iii) To prevent fraud or security threats to our Services; and/or (iv) To share limited data with third-party marketers as part of our business (however, please note that in contexts where GDPR applies, we will ensure compliance by either relying on consent or honoring your right to object to such processing, as described below).
Consent: In certain cases, we rely on your consent: (i) For sending marketing emails or SMS to individuals in jurisdictions where consent is required to do so; (ii) For placing non-essential cookies (like analytics or advertising cookies) on your device, we obtain consent as required by ePrivacy laws in the EU/UK; (iii) If we ever collect any sensitive personal data or plan to share your data with third parties in ways that require consent, we will obtain your consent. For example, if we were to "sell" your personal data to third-party marketers for their own use and you are an

EEA/UK individual, we would seek your consent or ensure we have another valid legal basis to do so; (iv) You have the right to withdraw your consent at any time where we are relying on consent. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Legal Obligation: We process and retain personal data as necessary to comply with our legal obligations. For example, financial laws may require us to keep certain transaction records, or to verify identities, or to report certain information to authorities.
Vital Interest / Public Interest: These bases are less likely to apply in our context. We would rely on them only if necessary (for example, if necessary to protect someone's life, or for some public interest task), but our normal course of business does not typically involve such processing.

If you have questions about the legal basis of how we process your personal data, please contact us (see "Contact Us" below) and we will explain further.

5. Your Rights and Choices

You have certain rights and choices regarding your personal information. These rights may vary based on your location and applicable privacy laws. We are committed to honoring your rights and providing you control over your data. Below, we outline key privacy rights and how you can exercise them:

5.1 Rights of California Residents (CCPA/CPRA)

If you are a resident of California, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know: You have the right to request that we disclose what personal information we have collected about you in the past 12 months, including the categories of information, the categories of sources, the business or commercial purposes for collecting it, the categories of third parties we disclosed it to, and specific pieces of information we hold about you.
Right to Delete: You can request that we delete personal information we have collected from you. Upon verification of your request, we will delete your personal information from our records, unless an exception applies (for example, if we need to retain certain information to comply with legal obligations, complete a transaction you requested, detect security incidents, or other purposes permitted by law).
Right to Correct: You have the right to request that we correct any inaccurate personal information we maintain about you.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. This means we will not deny you our services, charge you a different price, or provide a different level or quality of service just because you exercised your rights. However, please note that if the exercise of your privacy rights limits our ability to process personal information (for example, if you ask us to delete your data), we might not be able to provide you with certain services that require that information.
Right to Limit Use of Sensitive Personal Information: Sensitive Personal Information (SPI) may include, for example, government-issued identifiers (like Social Security numbers), financial account details in combination with login credentials, precise geolocation, racial or ethnic origin, health information, biometrics, or other data defined as SPI under California law. We do not collect SPI via our website as defined under California law.

5.2 Rights of EU/EEA and UK Individuals (GDPR)

If you are in the European Union, EEA, Switzerland, or the United Kingdom, you have the following rights regarding your personal data under GDPR (and equivalent UK law):

Right of Access: You have the right to request confirmation of whether we are processing your personal data, and if so, to obtain a copy of the personal data we hold about you, along with information about how we use and share it.
Right to Rectification: You can request that we correct or update any inaccurate or incomplete personal data that we hold about you.
Right to Erasure: You have the right to request that we delete your personal data in certain circumstances (also known as the "right to be forgotten"). For example, you can request erasure if the data is no longer necessary for the purposes it was collected, if you have withdrawn consent and no other legal basis for processing applies, or if you believe we are unlawfully processing your data. We will honor valid erasure requests, subject to any legal obligations to retain data.
Right to Restrict Processing: You can ask us to restrict or pause the processing of your personal data in certain situations. This could apply if you contest the accuracy of your data (while we verify it), if our processing is unlawful and you prefer restriction over deletion, or if you need us to preserve the data for the establishment, exercise, or defense of legal claims.
Right to Data Portability: You have the right to request a copy of personal data you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller (when the processing is based on consent or contract and carried out by automated means). Essentially, you can ask for your data in a format that can be easily transferred to another’s system.
Right to Object: You can object to our processing of your personal data when such processing is based on legitimate interests, including profiling based on legitimate interests. If you make such an objection, we will review whether our legitimate grounds for processing override your privacy rights. Importantly, you have an absolute right to object to the processing of your personal data for direct marketing purposes (including any profiling related to direct marketing). If you object, we will cease such processing for direct marketing purposes.
Right to Withdraw Consent: If we rely on your consent to process personal data, you have the right to withdraw that consent at any time. (For example, you can unsubscribe from marketing emails you previously consented to receive or decline cookies that you previously accepted through our cookie manager).
Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects for you, unless it is necessary for a contract with you, based on your explicit consent, or otherwise permitted by law. In general, we do not make such automated decisions about users without human involvement. If that changes, we will inform you and ensure any required safeguards are in place.
Right to Complain: If you believe our handling of your personal data violates the GDPR or UK data protection law, you have the right to lodge a complaint with a supervisory authority, particularly in the EU/EEA country or UK where you live, work, or where the alleged infringement occurred. For example, UK residents can complain to the UK Information Commissioner's Office (ICO). We would, however, appreciate the chance to address your concerns directly before you do this, so we encourage you to contact us first.

5.3 Other U.S. and International Rights

Residents of certain other U.S. states or countries may have similar rights under their respective privacy laws. For example, residents of states like Virginia, Colorado, or others may have the right to access and delete personal data and opt out of certain data processing under state laws; and individuals in countries such as Canada, Brazil, etc., may have their own data subject rights. We are committed to extending fundamental privacy principles to all our users. Even if you are not in California or the EU/UK, you can contact us with any privacy-related request, and we will consider it in line with applicable laws.

5.4 How to Exercise Your Rights

To exercise any of your rights or choices described above, please contact us by any of the following methods (or as otherwise specified):

Webform/Email: Email us at inquiry@blackhawkrisk.com. Please include your name, contact information, and detail the nature of your request (for example, "California Access Request" or "GDPR Data Deletion Request").
For your protection, we may need to verify your identity and/or authority before fulfilling certain requests. For example, if you request access to or deletion of your data, we might ask you to provide additional information to confirm you are the correct person (so we don't delete the wrong person's data). If you have an account with us, we might ask you to make the request through your logged-in account or reply to a verification email.

If you are an authorized agent making a request on behalf of another individual (such as a California resident), please provide proof of your authorization (e.g., a signed permission from the individual or proof of power of attorney) and be prepared to verify the identity of the person for whom you are making the request.

We will respond to privacy requests within the timeframes required by law. For example, under CCPA we generally have 45 days to respond to access or deletion requests (with the possibility of a 45-day extension). Under GDPR, we will try to respond within one month of receipt. If we need more time, we will inform you of the reason and extension period.

6. Data Retention and Security

6.1 Data Retention

We retain personal information for as long as necessary to fulfill the purposes we collected it for, as outlined in this Privacy Policy, and for legitimate business or legal purposes. This means:

Account Information: We retain your account information (like your email, phone, profile info) for as long as your account is active. If you delete your account or request deletion, we will remove or anonymize your personal information within a reasonable time, except as noted below.
Communications: If you contacted support or gave feedback, we may retain those communications as long as needed to address your issue and improve our services, and as required by regulatory guidelines.
Analytics Data: We generally aggregate or anonymize analytics data over time. Raw web logs are typically rotated or deleted within a short period (e.g., 90 days), unless needed for security analysis. Analytics in Google Analytics are retained as per our settings (which could be, for example, 26 months for user-level data before deletion or aggregation).
Legal Requirements: We may need to retain certain data for longer if necessary to comply with legal obligations (e.g., record-keeping under CFTC/NFA regulations, or data preservation in connection with litigation). We may also retain data as necessary to resolve disputes or enforce our agreements.

When we have no ongoing legitimate business need or legal requirement to retain your personal information, we will either delete it, anonymize/de-identify it, or if deletion or anonymization is not possible (for example, because the data is stored in backup archives), we will securely store the data and isolate it from further processing until deletion is feasible.

6.2 Data Security

We take the security of your personal information seriously. We implement reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include, for example:

Encryption of data in transit (e.g., using TLS/SSL for our website) and, where applicable, at rest.
Access controls to restrict who within our organization and our service providers can access personal data on a need-to-know basis.
Regular security assessments and training on data protection.
Use of reputable vendors and platforms that adhere to high security standards.
In the event of a security breach that affects your personal data, we have a data breach response plan. If a breach occurs, we will take steps to mitigate the impact, notify affected users and relevant authorities as required by law, and learn from the incident to improve our safeguards.

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security. You should also play a role in keeping your information safe by maintaining the security of your account credentials and by using unique and strong passwords and not sharing your account information with others. If you believe your interaction with us is no longer secure (for instance, if you suspect the security of your account or personal data has been compromised), please immediately contact us so we can take appropriate measures.

7. International Data Transfers

Black Hawk is based in the United States, and our Site is operated from the U.S. If you are accessing our Services from outside the U.S., please be aware that your information, including personal data, will be transferred to and processed in the United States and possibly other jurisdictions where our service providers are located. The data protection and privacy laws in these countries may offer a different level of protection than those in your home country.

However, regardless of where your data is processed, we handle it in accordance with this Privacy Policy and take appropriate safeguards to ensure its protection.

7.1 Transfer Mechanisms (for EU/UK Users)

If you are located in the EEA, UK, or Switzerland, and we transfer your personal information to a country outside of these areas (which is the case when data is sent to the U.S.), we will ensure a lawful transfer mechanism is in place, such as:

Legal adequacy mechanisms: We may transfer data to countries that the European Commission (or UK authorities) have determined provide an adequate level of protection.
Standard Contractual Clauses: We may rely on standard data protection clauses (Standard Contractual Clauses, or "SCCs") approved by the European Commission/UK for transfers of personal data. These are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data.
Consent and Necessary Transfers: In some cases, we may rely on your explicit consent to transfer personal data (for example, when you sign up knowing your data will be transferred to the U.S.), or where the transfer is necessary for the performance of a contract with you (e.g., to provide the requested service) or to implement pre-contractual measures.
Supplementary Measures: We may apply additional technical measures (like encryption in transit and at rest) to further protect data transferred out of the EU/UK.

By using our Site and providing information to us, you acknowledge the transfer of your personal data to the U.S. and other jurisdictions as described.

8. Child Privacy

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, please do not attempt to register on our Site or send any personal information about yourself to us.
If we learn that we have inadvertently collected personal data from a child under 16 (or the applicable age of consent), we will take steps to delete that information promptly. If a parent or guardian becomes aware that their child has provided us with personal information without their consent, they should contact us (see Section 10), and we will delete the information.

For minors above 16 (or the applicable age) but under 18, we advise that they use the Site only with parental consent and supervision. Certain jurisdictions (like the California “Privacy Rights for Minors in the Digital World” law) allow minors to request deletion of content they have posted.

While our Site currently may not allow user-generated content posting publicly, if it did, minors would have additional rights to remove or request removal of their postings.

9. Changes to This Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we update the policy, we will change the "Effective Date" at the bottom. If the changes are significant, we may also provide more prominent notice (such as by posting a notice on our website or sending an email notification). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If we make changes that materially affect how we handle personal information previously collected from you, we will provide you with an opportunity to consent to such changes if required by law.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you can contact us using the information below. We are here to help and will respond to your inquiry as soon as reasonably possible.

Black Hawk Resources Limited
Shaker Heights, OH 44120, USA
Email: inquiry@blackhawkrisk.com
Phone: +1 (216) 452-9165 (Monday to Friday, 9am-5pm ET)
for privacy inquiries, email is preferred for record-keeping and more efficient response.

If you contact us to exercise any of your rights described in Section 5, please include sufficient information for us to verify your identity (for example, the email associated with your account and a specific request). For authorized agents making requests on behalf of someone else, we may require proof of authorization and verification of the identity of the subject of the request.

Effective Date: _______________ 6/5/2025
Last Updated: ________________ 6/5/2025