Privacy Policy


This Privacy Policy sets forth guidelines concerning how B.E. Blank & Co LP (“B.E. Blank & Company”, “us”, “we” or “our”) gathers and uses information about your interaction with this Website (the “Website”). This Privacy Policy concerns only this Website, and does not concern any Website to which this Website may link.

This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Website, and how we use such information. Please read this Privacy Policy carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of this Website.

In the event that you have any questions or concerns about the guidelines set forth in this Privacy Policy please contact us at the following address:
B.E. Blank & Company
105 South Narcissus Avenue, Suite 800
West Palm Beach, FL 33401

A. The Types of Information We Collect About You

When you visit and browse the Website, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

  1. Information You Provide to Us

    In order to obtain access to certain services provided via the Website and request certain information regarding B.E. Blank & Company directly from the company via the Website, you may be required to provide personally identifiable information such as your name, postal address, e-mail address, telephone number, facsimile number and investor status. You can choose not to provide this information, but then you might not be able to gain access to such information and services.

  2. Information We Collect Through Technology

    We may collect information about you through technology. For example, when you visit the Website, we may collect your IP address. (An IP address is often associated with the portal through which you enter the Internet, like your ISP (Internet service provider), your company, or your university.) Standing alone, your IP address is not personally identifiable. At times, we may also use IP addresses to collect information regarding the frequency with which visitors browse various parts of the Website. We may combine this information with personally identifiable information.

    The Website may also use cookies. (Cookies are pieces of information that a Website sends to your computer while you are viewing the Website.) We and other companies use cookies for a variety of purposes. For instance, when you return to our Website after logging in, cookies provide information to the Website so that the Website will remember who you are. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your web browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to many features that may make your browsing of the Website smoother, like the features mentioned above, and some of our services may not function properly.

    The Website may also use other technical methods to track visitor usage, including web beacons. (“Web beacons” are small pieces of data that are embedded in images on the pages of a Website.) We may also use these technical methods to analyze the traffic patterns on the Website, such as the frequency with which our users visit various parts of the Website. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the Website to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that is personally identifiable. To the extent we are able to do so, we may link your non-personally identifiable information with your personally identifiable information.  We may also link information collected online with information we collect offline or that is collected online by third parties.

    Also, our third-party service providers may ask you voluntarily to provide personal information on their Websites and may share such personal information with us, as governed by their respective privacy policies.  Our use of information received from a service provider will be dictated by the service provider’s privacy policies and not this Privacy Policy.

    We may provide links on the Website to third parties. In addition, third parties may also provide links to the Website. Should you choose to visit these third party Websites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your personal information. We do not accept, and do disclaim, any responsibility for the privacy policies and information protection practices of any third party Website (whether or not such Website is linked on or to the Website). These links are provided to you for convenience purposes only, and you access them at your own risk.

B. How Personally Identifiable Information We Collect About You is Used

We may use personally identifiable information we collect about you when you visit and browse the Website in many ways. Representative examples of the ways in which we may use personally identifiable information we collect about you when you visit and browse the Website are set forth below.

  1. Use in Connection with Normal Business Operations

    Although, we do not sell your personal information to third parties, we may use or share certain personally identifiable information we collect about you when you visit and browse the Website as part of our normal business operations (such as processing your requests for forms or other literature or information, transactions, service, or to prepare investor disclosure materials), or to send you administrative communications either about your interactions with us or about features of our Website, including any future changes to this Privacy Policy.

  2. Use in Connection with Third Party Offers

    We may also share your information with third parties when you engage in certain activities on the Website that are sponsored by third parties, such as purchasing products or services offered by a third party, or electing to receive information or communications from a third party. When you participate in such, you will either be required or requested to agree that the sponsor or business associate may use your personal information (including, in some cases, your e-mail address) in accordance with the sponsor or business associate’s privacy practices.

  3. Other Uses

    Sometimes we hire companies to help deliver products or services, like a shipping company that delivers a package. In that instance, there is a need to share your information with that company. Sometimes we also work with other companies who help either gather your information or communicate with you. Except as separately permitted by the guidelines of this Privacy Policy, these companies are allowed to gather, receive, and use your information only for the purposes described in this paragraph or as required by law.

    Finally, we may take any personally identifiable information that we collect from you when you visit and browse the Website and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under the guidelines set forth in this Privacy Policy upon our right to aggregate or de-personalize your personal information, and we reserve the right to use and/or share with third parties the resulting non-personally identifiable information in any way.

C. Additional Ways Personally Identifiable Information May be Disclosed

We may share your personal information with our affiliates.  From time to time, we may partner with other organizations or companies to provide co-sponsored or co-branded promotions, services or events and may share your personal information with our co-sponsor(s) and partners.  We will also disclose personal information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request, or (b) will help to: enforce our Terms of Use; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of the Websites, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties. We may also transfer your information to any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of our assets.

D. The Security Measures We Take to Safeguard Your Personally Identifiable Information

The security and confidentiality of your information is extremely important to us. We have implemented commercially reasonable technical, administrative, and physical security measures to protect personal information from reasonably foreseeable intrusions by unauthorized third parties. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

E. Updating Your Contact Information

We will provide you an opportunity to update your contact information and/or modify your communication choices by sending you an e-mail or other communication that invites your response, or by providing a means to update that information via the Website.

F.  Children’s Information

The Website is intended for use by those over 18 and minors under the age of 13 may not use the Website.  We do not knowingly solicit or collect personal information on the Website from children under the age of 13 without prior verifiable parental consent. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Website, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

G.  Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking.  As we do not track users across time or over multiple Websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms.  As noted above, third parties, such as our advertising partners, may collect data that relates to you.  We cannot control third parties’ responses to do-not-track signals or other such mechanisms.  Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

H.  The California Consumer Privacy Act


California enacted the California Consumer Privacy Act, California Civil Code § 1798.100 et seq., (with any implementing regulations and as may be amended from time to time, “CCPA”), in 2018 and it is effective as of January 1, 2020. The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” under the CCPA means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or a household.

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.

  1. Business or Commercial Purpose for Collecting Personal Information
    In the preceding 12 months, we may have collected your personal information for the following business or commercial purposes. We may collect personal information for all or just a few of these purposes with regard to a particular California Resident.

    • Performing services on behalf of the fund, including, for example, maintaining or servicing accounts, providing customer service, processing transactions, verifying information, processing payments, or providing similar services on behalf of the fund.
    • Performing our contractual obligations to a California Resident as a subscriber to the fund, including, processing initial subscriptions and providing updates on the fund’s performance and other operational matters.
    • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, including, preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks.
    • Enabling or effecting commercial transactions, including, using your bank account details to remit funds and process distributions.
  2. Categories of Personal Information We Collect
    In the preceding 12 months, we may have collected the following categories of personal information from or about you. We may collect all or just a few of these categories with regard to a particular California Resident.

    • Identifiers such as, your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
    • Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
    • Characteristics of protected classifications under California or federal law, including, your sex or gender, national origin, or marital status.
    • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. For example, funds invested in the prior year, investments considered, or sources of wealth.
    • Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
    • Professional or employment-related information, including your current or former employer or your current professional title.
    • Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds based on various information.

    Personal information under the CCPA does not include deidentified information, aggregate consumer information or publicly available information that is lawfully made available from government records.

  3. Categories of Sources from Which Personal Information is Collected
    In the preceding 12 months, we may have collected personal information about you from the following categories of sources. We may collect personal information from all or just a few of these categories of sources with regard to a particular California Resident.

    • Directly from you or your representatives, including through forms or related documentation you complete when subscribing for shares or interests, in correspondence and conversations (including by email), through transactions with regard to funds, and when you provide remittance instructions.
    • From our service providers such as our fund administrator.
    • From law enforcement.
    • From government records and other publicly accessible directories and sources, including, bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities.
    • From credit reporting agencies, sanctions screening databases, and fraud prevention and detection agencies and organizations.
  4. Categories of Personal Information We Have Disclosed for a Business Purpose
    In the preceding 12 months, we may have disclosed for a business purpose personal information about you to our service providers or other entities that have agreed to limitations on use of your personal information. We may disclose all or just a few of these categories with regard to a particular California Resident.

    • Identifiers such as your name, address, date of birth, email address, social security number, driver’s license number, passport number, or other similar identifiers.
    • Personal information protected under California Civil Code Section 1798.80(e), including, for example, your signature or bank account or other financial information.
    • Characteristics of protected classifications under California or federal law, including your sex or gender, national origin, or marital status.
    • Commercial information for example, records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies. For example, funds invested in the prior year, investments considered, or sources of wealth.
    • Internet or other electronic network activity information, including, for example, information regarding your interaction with our website or use of certain online tools.
    • Professional or employment-related information, including your current employer or your current professional title.
    • Inferences drawn from any of the information identified above to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. For example, information on your potential interest in investing in new funds based on various information.
  5. Categories of Third Parties With Which We Share Personal Information
    In the preceding 12 months, we may have shared your personal information with the following categories of third parties. We may share personal information with none, all, or just a few of these third parties with regard to a particular California Resident. We do not sell your personal information except as permitted by the CCPA or other laws.

    • Law enforcement.
    • Regulators and other government agencies as required or permitted by law.
    • Individuals, entities, or regulatory bodies in connection with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons.
    • Individuals, entities, or regulatory bodies to exercise or defend legal claims on behalf of you.
    • Individuals, entities, or regulatory bodies at your direction or with your consent.
    • Other individuals, entities, or regulatory bodies as otherwise required or permitted by law.

    We may disclose all or just a few of the categories of personal information identified in the paragraph labelled “Categories of Personal Information We Share for a Business Purpose” to our service providers or other entities with which we have contracted to provide support and services and that have agreed to limitations on the use of your personal information for a business purpose or that fit within other exemptions or exceptions in the CCPA.

  6. California Residents’ Rights Under the CCPA
    If your personal information is subject to the CCPA, you may have certain rights concerning your personal information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“request to delete”); and (iv) request that we, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“request to know”): (a) the categories of personal information we have collected about you; (b) the categories of sources from which we have collected the personal information; (c) the business or commercial purpose for collecting or selling the personal information; (d) the categories of third parties with which we share personal information; (e) the specific pieces of personal information we have collected about you; and (f) the categories of personal information we have disclosed about you for a business purpose.

  7. How to Submit a Request Under the CCPA

    You may submit requests to know through the following telephone number: (561) 566-5110; or through our website at the following link: https://beblankco.com.

    You may submit requests to delete through the following methods: via email at inquiry@beblankco.com or via the “Contact Us” section of our website at https://beblankco.com/contact-us/.

    We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.

  8. Contact For More Information
    If you have any question or concerns about this California privacy policy, please contact as follows:
    B.E. Blank & Company
    105 South Narcissus Avenue, Suite 800
    West Palm Beach, FL 33401
    Phone: (561) 566-5110
    Email: inquiry@beblankco.com