At Butter and Egg Road USA, Inc. (“we,” “our” or “us”), we are committed to protecting the privacy, and confidentiality of certain information of our clients (collectively “BAER Clients”) who use our services. In order to achieve this goal and instill confidence in our BAER Clients that such information they entrust to us is protected, we have adopted this Privacy Policy. We want our BAER Clients to know why we ask for certain information, how we use it, what safeguards we employ to protect it and how to contact us with privacy-related questions.

1. Private Information 
In this Privacy Policy, “Private Information” means information that, whether alone or together with other such information, may identify a BAER Client and is provided by such BAER Client to, or collected by, us. Private Information may include, among other things, a BAER Client’s name, purchase history, residential or business mailing address, residential and business phone numbers, email addresses, credit card information and banking information. Private Information does not include any information that cannot be linked to an individual or business, and any other anonymous information.

2. Use Of Private Information
Private Information will be collected, used and disclosed by us only as set forth in this Privacy Policy, and we will obtain a BAER Client’s consent before collecting, using or disclosing its, his or her Private Information in a manner that conflicts with this Privacy Policy. We collect, use and disclose Private Information only as reasonably appropriate for the following purposes:
  • Protect against, identify, and remediate fraud and errors;
  • Perform services requested by a BAER Client;
  • Record and analyze services received by a BAER Client;
  • Bill, collect and otherwise account for all amounts payable by a BAER Client;
  • Offer additional services on our behalf or on behalf of third parties that may be of interest to a BAER Client;
  • Personalize a BAER Client’s use of our services;
  • Communicate with a BAER Client to ensure BAER Client satisfaction or otherwise for any legitimate business purpose;
  • Improve services offered to our BAER Clients;
  • Performing our obligations under contracts or otherwise;
  • Respond to any situation in which the safety, property or rights of a BAER Client or third party may be at risk;
  • Comply with all applicable laws; and
  • Any other legitimate business purpose that is communicated to a BAER Client after its, his or her Private Information is received by us.
We may also disclose Private Information to our affiliates, agents, employees, and suppliers, plus third parties deemed appropriate by us, for the purposes set forth in this Section or as otherwise permitted by law. If we, or all or substantially all of our assets, are being acquired by a third party, a BAER Client’s Private Information may be transferred to such third party prior to and after such acquisition.

3. Storage
Private Information will be stored at our office located at 252 7th Avenue, #7N, New York, New York, 10001 and/or on servers used by us and located in the City of New York or elsewhere.

4. Consent
Except as set forth in this Privacy Policy, we do not collect, use or disclose a BAER Client’s Private Information without the consent of a BAER Client. In using our services, BAER Clients have consented to the collection, use and disclosure of their Private Information as set forth in this Privacy Policy. A BAER Client may withdraw his or her consent at any time, subject to our then-existing contractual or other legal obligations and our having a reasonable opportunity to implement such withdrawal. If a BAER Client chooses to withdraw his or her consent, he or she is required to do so in a writing sent to Butter and Egg Road USA Inc., 252 7th Avenue, #7N, New York, New York, 10001, Attention: Chief Compliance Officer, or by e-mail to Any such withdrawal of consent by a BAER Client may result in, among other things, an inability to access or use the Site by such BAER Client.

5. Retention
Private Information is only retained as long as may be necessary for the purposes for which it was collected by us and set forth in this Privacy Policy, as required by applicable law, or as provided in any document retention policy adopted by us from time to time, whichever is longer. After the expiration of the retention period described in the immediately preceding sentence with respect to any Private Information, we will destroy, erase, or rendered anonymous such Private Information.

6. Safeguards
We use security safeguards designed to protect against loss, theft, and unauthorized access, disclosure, copying, use or modification of Private Information. The nature of such safeguards depends on the sensitivity, format, location and storage of Private Information, and may include, among other things, the use of locked cabinets, computer passwords, software firewalls, encryption software, restricted access and contractual obligations of confidentiality from third parties to whom Private Information is disclosed. Since no transmission of information over the Internet or storage of electronic information is completely secure, it remains possible that a BAER Client’s Private Information could be compromised, even though such safeguards are used by us.

7. E-mail
A BAER Client may from time to time send an e-mail message to us in connection with such BAER Client’s use of our services. Upon our receiving such a message, the e-mail address, as well as the contents of such message, will be used and stored by us to respond to such BAER Client, to improve our services and for other legitimate business purposes.

8. Access
Upon the written request of a BAER Client, we will (a) provide such BAER Client with access to his or her Private Information, and (b) correct any inaccuracies in such BAER Client’s Private Information that are identified to us in writing by such BAER Client. All such inaccuracies should be sent to us at Butter and Egg Road USA Inc., 252 7th Avenue, #7N, New York, New York, 10001, Attention: Chief Compliance Officer, or by e-mail at A request for access to Private Information may be refused by us for any one of the following reasons:
  • If the information is protected by legal privilege;
  • If the information is confidential information of a third party;
  • If granting access would reasonably be expected to threaten the safety, security or property of a third party;
  • If the information was collected for purposes relating to the detection, remediation or prevention of fraud;
  • If the information was generated in the course of a formal dispute resolution process;
  • If the information would likely reveal Private Information of another BAER Client;
  • If providing the information is no longer in our possession or under our control or providing the information is overly burdensome to us or a third party;
  • If the request is vexatious or frivolous; or
  • To protect our rights and property.
If the request of a BAER Client for his or her Private Information is denied, such BAER Client will be informed in writing of the reasons for such denial.

Access to BAER Client’s Private Information will be at no cost to such BAER Client. Nominal charges may apply, however, for the reproduction or transmission of Private Information in response to a BAER Client’s request for access to Private Information.

9. Changes
We reserve the right to change this Privacy Policy at any time and from time to time. Any such change will be effective upon our posting it to our website. No such change affecting the use or disclosure of Private Information will apply to any Private Information collected by us prior to the effective date of such change, unless we receive a BAER Client’s consent to such change. All BAER Clients are encouraged to check our website from time to time to determine if any changes have been made to this Privacy Policy.

10. Applicable Law 
This Privacy Policy will be governed by the law of the State of New York, without regard to principles of conflict of laws.

11. Additional Information
We have appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy laws and the terms of this Privacy Policy. The Chief Compliance Officer will investigate and respond to any questions or concerns regarding a BAER Client’s Private Information or this Privacy Policy. He or she may reached by mail at Butter and Egg Road USA Inc., 252 7th Avenue, #7N, New York, New York, 10001, Attention: Chief Compliance Officer, or by e-mail at

Dated: February 18, 2014