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Disclaimer & Privacy Policy

TERMS OF USE

By using this website, www.brentmoorcap.com (the "Website"), you are knowingly and willingly agreeing to be bound by these Terms of Use (defined as the "Disclaimer" and  "Privacy Policy" collectively) and understand that these terms of use shall constitute a binding and enforceable contract between you and Brentmoor Capital Group LLC ("BCG").

These "Terms of Use" set forth the terms and conditions under which you may access and use the Website. If you do not agree to these terms of use, you may not use this Website. BCG may change the Terms of Use from time to time, so we encourage you to review our Terms of Use whenever you use the Website to make sure you understand how you may use the Website. Your continued use of the Website following the posting of changes to the Terms of Use will signify your acceptance of the then current Terms of Use. The Terms of Use will include the date we last updated the Terms of Use.

LAST UPDATED: July 1, 2020

CONTACTING BCG

You may contact us if you any questions about the Terms of Use, the practices of this Website, or your dealings with the Website by utilizing the following contact information:

 

Brentmoor  Capital Group LLC

Phone: (917) 621 - 7895

info@brentmoorcap.com

Securities transactions conducted through Mid-Market  Securities, LLC,Member FINRA, SIPC

11 East 44th Street, 19th Floor New York, NY 10017

DISCLAIMER

BCG intends that this Website will be viewed for informational purposes only. This should not be viewed as a solicitation or offer of services in any jurisdiction in which BCG is not qualified to do business. It is provided for informational purposes only. The information contained in this website does not constitute an offer to sell any advice or provide any professional services. Although the Website may provide information concerning potential legal issues, it is not a substitute for legal advice from qualified counsel. You should not and are not authorized to rely on the Website as a source of legal advice. 

The material on this website is for the general information of our clients and visitors.This website does not constitute an offer to sell or a solicitation of an offer to buy or sell any security or investment product, and may not be relied upon in connection with any offer or sale of securities. Nothing on this website is a recommendation that you purchase, sell or hold any security, or that you pursue any investment style or strategy. Nothing on this website is intended to be, and you should not consider anything on the website to be, investment, accounting, tax or legal advice. 

Customer Identification Program
 
To help the government fight the funding of terrorism and money-laundering activities, and to verify your identity, federal law may require BCg to obtain your name, date of birth, address and a government-issued identification number before opening your account. If you are acting on behalf of a corporate entity, we may be required to obtain your name and title, and the corporation’s address and government-issued identification number. In certain circumstances, BCG may obtain and verify this information with respect to any person(s) authorized to effect transactions in an account. Your account may be restricted and/or closed if BCG cannot verify this information. BCG will not be responsible for any losses or damages (including but not limited to lost opportunities) resulting from any failure to provide this information, or from any restriction placed upon, or closing of, your account.

Conflicts of Interest
 
BCG and its affiliates may from time to time engage in activities that are in conflict with their securities customers. The employees of BCG, its contract consultants, and its affiliates are bound to the customer’s best interests and are required to notify BCG of any possible or potential conflict of interest which may result from their other activities, and may commence such other activities only after the prior, written approval of BCG, which may not be unreasonably withheld. 

Risk
 
IMPORTANT: All investing is risky, and no investor should decide to commit funds without first consulting with a competent professional adviser. Some or all invested funds can be lost.  The past performance of any investment, investment strategy or investment style is not indicative of future performance. Future results may vary, and are not guaranteed. The value of investments and their income may increase or decrease, and a loss of principal - including all principal - may occur.

Private Placements
 
Mid-Market Securities, LLC. (MMS) is a full service  broker-dealer offering private placements. A private placement is the sale of registered or unregistered securities to a limited number of qualified private investors, including institutional investors, accredited individuals, and entities that meet certain investor eligibility requirements. Securities purchased through private placements typically fall into the category of alternative assets - investments that often have a low correlation to public markets and offer essential diversification to portfolios dominated by traditional stocks and bonds. However, private placements generally are highly illiquid, and are not subject to public disclosure obligations. Investors should consult professional advisers, perform deep due diligence, and engage in careful deliberation before investing.

Qualified Investors

Investing in private placements requires high risk tolerance, low liquidity concerns, and long-term commitment. Investors must be able to afford to lose their entire investment. For those reasons, these offerings may be made available only to certain institutional investors and high net worth individuals and entities. As with all alternative investments, investors must meet certain eligibility tests to qualify as purchasers. Currently, entities must have assets of at least $5 million (or all individual owners meet accredited investor tests). Individuals must have a net worth of more than $1 million or gross income for each of the last two years of at least $200,000 ($300,000 with spouse) with the expectation of the same income in the current year, excluding one’s residence.

Securities Investor Protection Corporation (SIPC)

 

Mid-Market Securities, LLC. is a member of the Securities Investor Protection Corporation (SIPC), which provides protection for owners of securities accounts.  MMS does not hold securities; all accounts and assets are held by the issuers, sponsors, or their clearing brokers or qualified custodians. No coverage protects against a decline in the market value of securities.  An explanatory brochure about the SIPC protection is available upon request through the Securities Investor Protection Corporation, www.sipc.org.  

Forward Looking Statements

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS. Certain of the information contained herein may be based upon forward-looking statements. Forward-looking statements are inherently uncertain and factors affecting the markets in general or industries or issuers in particular may cause events or results to vary from those described herein. Accordingly, you should not rely on or draw conclusions from forward looking statements.

Use of the Website

You agree and acknowledge that the Website and the content, including but not limited to graphics and information, provided on the Website (the "Website Content"), is the sole and exclusive intellectual property of BCG or is licensed by BCG and shall not be copied, reproduced, displayed, sold or otherwise distributed without the express prior written consent of BCG provided you may print a single copy of the Website Content solely for your personal, non-commercial use. BCG hereby grants you a license to access and use the Website and the Website Content in accordance with the terms and conditions of these Terms of Use.

You agree that you will not use the Website for any illegal purpose. In addition, you agree that:

  • you will not harvest, collect, or otherwise use contact information made available on the Website for the purpose of sending unsolicited improper communications, including without limitation, unsolicited bulk email (collectively, "spam") and that you will not use any BCG communications facility to deliver or attempt to deliver spam;

  • you will not attempt to gain unauthorized access to the Website or the servers and network associated with the Website;

  • you will not circumvent or attempt to circumvent any security or access control technology implemented on the Website, or the servers and network associated with the Website;

  • you will not use the Website in any manner designed to degrade the performance or functioning of the Website, including, without limitation, launching Denial-of-Service ("DoS") attacks against the Website.

 

Copyright

BCG claims a copyright in its works presented at this Website. BCG authorizes you to view, copy, download and print BCG documents on this Website, subject to the following conditions:

  • The documents may be used solely for personal, noncommercial and informational purposes.

  • The documents may not be modified.

  • The following copyright notice and permission notice must appear in each document: "© Copyright 2020 Brentmoor Capital Group LLC and Affiliates. All rights reserved. BCG documents available from this Website are protected by the copyright laws of the United States and international treaties. All use subject to Terms of Use set forth at www.brentmoorcap.com

Commercial Use of BCG Web Site Materials and Screen Shots

Reproduction, copying or redistribution of materials on the BCG web site for commercial purposes is prohibited without the express written permission of BCG. To obtain permission to copy portions of this site, please send email to info@brentmoorcap.com and provide the following information in the body of the email:

  • the BCG content you wish to use

  • where and how it will be used (for example, a book cover, magazine article, a brochure)

  • where and how copies will be distributed and to what audience

  • how many copies will be produced and distributed

  • when you intend to publish

  • what other non-BCG materials will be associated with the BCG content

  • your name, title, company, address, email address and phone number

We will evaluate your request and advise you as soon as possible. BCG reserves the right to refuse permission to copy, distribute, broadcast or publish any of its copyrighted material, including text and images on our Website.

Links to Third Party Sites

 

As a convenience to you, BCG may provide, on this Site, links to websites operated by other persons or entities. If you use these sites, you will leave this site. BCG makes no warranty or representation regarding, and does not endorse, any linked websites or the information appearing thereon or any of the opinions, ideas, products or services described thereon. Links do not imply that any linked website is authorized to use any of BCG's trademarks, trade names, logos or copyright symbols. In addition, these websites may be governed by a different privacy policy or security practices from this Website so it is important that you read the policies of those sites before sharing your personal information.

 

External Links to This Site

 

BCG shall have no liability for third party content or websites linking to or framing this Website. All links to this Website must be approved in writing by BCG, except that BCG consents to links in which: (i) the link is a text-only link containing only the name "Brentmoor Capital Group"; (ii) the link "points" only to www.brentmoorcap.com and not to deeper pages; (iii) when activated by a user, the link displays that page full-screen in a fully operable and navigable browser window and not within a "frame" on the linked website; and (iv) the appearance, position, and other aspects of the link neither creates the false appearance that an entity or its activities or products are associated with or sponsored by BCG nor damages or dilutes the goodwill associated with BCG's name or trademarks. BCG reserves the right to revoke this consent to link at any time.

 

Service Marks

Permitted use of BCG service marks

BCG service marks identify BCG products and services and let the public know the source of those products and services. You may make fair use of our service marks in advertising and promotional materials, and in referencing our products and services (for example, in a magazine article) without our permission, provided you follow standard trademark usage practices and provide proper attribution. Other uses require our written permission. If you are in doubt as to whether you need our permission for a specific type of use, please ask us.

Prohibited use of BCG service marks

You may not use BCG logos or "design" service marks (as opposed to our service marks consisting solely of words) under any circumstances without our prior written authorization.

In addition, you may not use BCG service marks, whether design or word marks, in the following ways:

  • in a non-BCG service name or publication title;

  • in, as, or as part of, your own service or trademarks;

  • to identify products or services that are not BCG's;

  • in a manner likely to cause confusion;

  • in a manner that implies inaccurately that we sponsor or endorse, or are otherwise connected with, your own activities, products and services;

  • as hidden or embedded text in web pages in an effort to cause a search of BCG marks to result in a hit on a page not maintained by BCG in a manner disparaging of BCG;

Privacy

BCG's privacy policy contains additional information about how your information (including information that will not be publicly viewable) will and will not be used.

Information Provided By You

Do not send any confidential or proprietary information to BCG via the Website. No information or materials that you provide to BCG via this Website will be considered or treated as confidential or proprietary. By providing any such information or materials to BCG, you grant to BCG an unrestricted, irrevocable, worldwide, royalty-free, non-exclusive license to use, reproduce, modify, publicly display, publicly perform, transmit and distribute such information and materials, and you further agree that BCG is free to use any ideas, concepts or know-how that you or individuals acting on your behalf provide to BCG. You agree not to use the Website to distribute, email or post any advertising, promotion or solicitation without our prior approval. You agree not to use the Website to upload, display or distribute any materials that are defamatory, threatening, obscene, harassing, or otherwise unlawful, or that incorporate the copyrighted, confidential or proprietary material of any other person or entity.

 

Indemnity

 

You agree to defend, indemnify and hold harmless BCG, its subsidiaries, affiliates, officers, directors, employees, agents, licensors and licensees from any claims, losses, damages, expenses, demands, and costs (including without limitation reasonable attorneys’ fees), arising out of or relating to your use of the Website.

 

Jurisdiction; Choice of Law

 

This Agreement and your use of the Website shall be governed by the laws of the State of New York, without regard to its conflict of laws provisions.

Severability

 

If any provision of this Agreement is found to be void or unenforceable, such provision shall be severed and all other provisions shall remain in force.

Representations & Warranties

(a) Disclaimer of Warranties: THE WEBSITE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. BCG EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. BCG MAKES NO WARRANTY THAT (i) THE WEBSITE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (ii) THE RESULTS OBTAINED FROM THE WEBSITE WILL BE ACCURATE OR RELIABLE, OR (iii) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE WEBSITE WILL MEET YOUR EXPECTATIONS. ANY MATERIAL DOWNLOADED FROM OR OTHERWISE OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA RESULTING FROM SUCH DOWNLOAD OR USE.

(b) Limitation of Liability: UNDER NO CIRCUMSTANCES, INCLUDING NEGLIGENCE, WILL BCG, ITS SUBSIDIARIES, AFFILIATES, OFFICERS, DIRECTORS, ADVISORS, LICENSORS, LICENSEES OR CONTENT PROVIDERS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR CONSEQUENTIAL DAMAGES THAT RESULT FROM YOUR USE OF OR INABILITY TO USE THE WEBSITE, INCLUDING BUT NOT LIMITED TO RELIANCE ON INFORMATION OBTAINED ON THE WEBSITE, MISTAKES, OMISSIONS, INTERRUPTIONS, DELETION OF FILES OR ELECTRONIC MAIL, LOSS OF OR DAMAGE TO DATA, ERRORS, DEFECTS, VIRUSES, DELAYS IN OPERATION OR TRANSMISSION, OR ANY FAILURE OF PERFORMANCE, WHETHER OR NOT RESULTING FROM ACTS OF GOD, COMMUNICATIONS FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO THE WEBSITE. YOU HEREBY ACKNOWLEDGE THAT THIS PROVISION WILL APPLY WHETHER OR NOT BCG IS GIVEN NOTICE OF THE POSSIBILITY OF SUCH DAMAGES AND THAT THIS PROVISION WILL APPLY TO ALL CONTENT, MERCHANDISE OR SERVICES THAT MAY BE AVAILABLE FROM TIME TO TIME FROM BCG OR ITS SUBSIDIARIES AND AFFILIATES. NOTWITHSTANDING THE FOREGOING, ANY LIABILITY RESULTING FROM YOUR USE OF THE WEBSITE SHALL BE LIMITED TO ONE HUNDRED DOLLARS, IN THE AGGREGATE FOR ALL CLAIMS.

(c) Exclusions and Limitations: Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for incidental or consequential damages. Accordingly, some of the above limitations may not apply to you. In any event, the foregoing limitations shall apply to the greatest extent permitted by law.

Warning Against Hackers

It is possible that other users or unauthorized "hackers" may post or transmit offensive or obscene materials on the Website and that you may be involuntarily exposed to such materials. It may also be possible for other users or "hackers" to obtain personal information about you. By using the Website, you assume the risk of such occurrences.

Miscellaneous Terms

By accessing the Website, you agree that the laws of the State of New York, without regard to principles or conflict of laws, will govern these Terms of Use and any dispute of any sort that might arise between you and BCG or its affiliates. If any provision of these Terms of Use is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be enforced to the maximum extent permissible so as to affect the intent of these Terms of Use, and the remainder of these Terms of Use shall continue in full force and effect. The failure by either you or BCG to exercise or enforce any rights or provisions of these Terms of Use shall not constitute a waiver of such right or provision. All provisions in these Terms of Use regarding representations and warranties, indemnification, disclaimers and limitations on liability shall survive any termination of these Terms of Use.

PRIVACY POLICY

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.   Please note this policy continues to use the defined terms as stated in the "Terms of Use" section of the "Disclaimer".  The following privacy policy is intended to apply only to personally identifiable information you provide to BCG from time to time via this Website.

How We Collect Information About You

 

When you visit our Website, our web servers collect the details of your operating system, browser version, domain name and IP address and the details of the web site you linked from to the Website. Our web servers may seek to place a "cookie" (a small data file) on your computer's hard drive, which allows the server to recognize your computer when you visit again. If you prefer not to accept cookies, you can set your browser to reject them or to alert you before one is placed.

 

There are parts of this Website where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our website (for example, in a request for general information or through the submission of a business proposal), we may record and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications. If you do not provide all the information we need, we may not be able to give you the information you request.

 

Please also note we have certain responsibilities under the Money Laundering Regulations 2007, the FSA Rules and the DFSA Rulebook to verify the identity of clients and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.

Uses of Collected Information

The principal purposes for which we process and store your personal information are, or may in the future be:

 

  • to monitor, improve and administer the Website and the services provided on the Website;

  • to enable us to conduct surveys and aggregate user profiles;

  • to provide you with information on selected products and selected services that we think may be of interest to you (unless you have asked us not to do so); and

  • to enable us to comply with our legal and regulatory obligations.

 

Disclosures of Your Personal Information Within BCG

 

In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. For this purpose, we may transfer the information you provide outside your country to another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers.  We have taken certain measures outlined below to try to ensure the security of your information.

 

Disclosures of Your Personal Information to Third Parties

 

We may share your personal information with other companies we have hired to provide services for us. These companies - our vendors - are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that BCG has hired them.

We may also release information about you if you direct us to do so, or if we are required or authorized by law to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

 

Security of Collected Information

 

We use all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect your personal information from unauthorized or inappropriate access but we note that the Internet is not a secure medium. We restrict access to information about you to those BCG personnel who need to know the information to respond to your inquiry or request.

 

Access to Collected Information

 

You have certain rights under applicable laws to access your personal information held by us. You can contact us as described below to request a review or update of that information.

Contacting Us

 

If you have any questions about this privacy policy, or if you wish to access your personal information or make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us via email at info@brentmoorcap.com. We welcome your questions and suggestions about our privacy policy.

BUSINESS CONTINUITY PLAN 

Brentmoor Capital Group, LLC has developed a Business Continuity Plan ("BCP") as part of our ongoing contingency planning efforts to mitigate the impacts of business interruptions. Since disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

We plan to quickly recover and resume business operations after a Significant Business Disruption and respond by safeguarding employees’ lives and firm property, protecting the firm’s books and records, and allowing our clients to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses:

  • data back up and recovery;

  • mission critical systems;

  • financial and operational assessments;

  • alternative communications with customers, employees, and regulators;

  • alternate physical location of employees;

  • critical supplier, contractor, bank and counter-party impact; and regulatory reporting

 

Significant business disruptions can vary in their scope. For example, an SBD could affect only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe.

 

In any situation, we plan to continue in business, and notify clients and prospective clients through our website or our main contact number regarding how to contact us. This plan is reviewed periodically and subject to modification without notice. A written copy of the summary of this plan is provided to clients at account opening, posted on the firm’s website, and provided to clients upon request. If you have questions about our business continuity planning, please contact us at your convenience.

Disclaimer
Privacy Policy
Business Continuity Plan
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