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Baleen Research

Client & Subscriber Privacy Notice

Effective June 2025

Baleen Research, LLC (“we,” “us,” or “our”) is committed to protecting the privacy of individuals and institutions who receive our investment research. This Privacy Notice explains how we collect, use, and safeguard limited contact information in accordance with applicable privacy laws, including U.S. federal and state privacy laws, the General Data Protection Regulation (GDPR), and relevant Asia-Pacific data protection regulations.

This notice applies to recipients of our research publications, including institutional clients such as hedge funds and asset managers with global operations.

Note on scope. This notice covers personal data we collect and process in connection with subscriptions, contracts, distribution, and client relationships. Where individuals also access our website or authenticated platform, additional data (such as authentication logs, usage events, and technical information) may be collected. That processing is described in our Website & Platform Privacy Policy, which is provided separately and applies in addition to this notice for those interactions.

1. Scope of This Notice

This Privacy Notice applies to:

  • Individuals at institutional clients who receive our research
  • Group email inboxes designated by client firms
  • Visitors to our public website (to the extent applicable, and as further described in our Website & Platform Privacy Policy)

We do not engage in advertising, cross-site tracking, or behavioral profiling. Limited engagement data may be collected through our website and platform as described in our Website & Platform Privacy Policy.

2. Data We Collect

We collect only the following limited business contact information:

  • Email address (individual or group inbox)
  • Physical business mailing address
  • Telephone number
  • Job title

3. Purpose of Processing

We use this limited contact information solely to:

  1. Deliver our investment research publications;
  2. Maintain accurate distribution lists;
  3. Respond to institutional inquiries or requests;
  4. Comply with legal and regulatory obligations.

We do not use business contact information for advertising, profiling, or automated decision-making. Sign-up flows on our website that involve any automated processing are addressed in our Website & Platform Privacy Policy.

4. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) or United Kingdom, our legal bases for processing are:

  • Legitimate Interests: To deliver research to institutional clients in a manner that does not override individual rights;
  • Consent: Where required, such as for opt-in communications;
  • Legal Obligation: To comply with applicable laws and regulatory requirements.

5. International Data Transfers

In the event we transfer contact information to jurisdictions outside your own, including the United States and Asia-Pacific regions, where required, we implement safeguards such as:

  • Standard Contractual Clauses (SCCs) for EU/UK data transfers;
  • Local compliance measures in jurisdictions such as Singapore, Japan, and Hong Kong.

6. Data Sharing

We do not sell or commercially share contact information. We may share it with:

  1. Service providers (e.g., secure email delivery platforms);
  2. Legal or regulatory authorities as required by law (see Section 7 regarding Compliance and Protection);
  3. Affiliates or successors in the event of a business transition.

All third parties are contractually bound to use the data only for specified purposes and to maintain confidentiality of the information.

7. Compliance and Protection

We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

8. Data Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. We may retain it for a period of time after an engagement ends. You may request removal at any time.

9. Designated Third Parties

We may share your personal data with third parties where you have instructed us or provided your consent to do so.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access or correct your contact information;
  • Object to or restrict processing;
  • Withdraw consent (where applicable);
  • Lodge a complaint with a supervisory authority.

To exercise these rights, contact us at mb at baleenresearch dot com.

11. Security Measures

We implement appropriate technical and organizational safeguards to protect contact information, including:

  • Access controls;
  • Secure email infrastructure;
  • Periodic reviews of distribution lists.

12. Changes to This Notice

We may update this Privacy Notice periodically. Material changes will be communicated via our website. Please review this site for updates.

13. Contact Us / Questions

For questions or to exercise your rights, please contact:

Marshall Bush at mb at baleenresearch dot com

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