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.
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.
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 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.
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.
Use in Connection with Normal Business Operations
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.
C. Additional Ways Personally Identifiable Information May be Disclosed
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
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”) imposes certain obligations on the Fund (“we” or “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. The Fund is 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 California resident or a household. It does not include deidentified information, aggregate consumer information or publicly available information, as those terms are defined in the CCPA.
Purposes for Collecting and Using Personal Information
We may collect or use your personal information for the following business or commercial purposes: (i) performing services on behalf of a fund, including maintaining or servicing accounts, providing investor relations services, processing subscriptions and withdrawals, verifying information, processing payments or providing similar services; (ii) performing our contractual obligations to a California Resident as a subscriber to a fund, including providing updates on a fund’s performance, providing tax reporting and other operational matters; (iii) detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; and (iv) enabling or effecting commercial transactions, including using bank account details to remit funds and process distributions.
Personal Information We Collect
In the preceding 12 months, we may have collected the following categories of personal information from or about a California Resident: (i) identifiers and similar information, such as name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers or other similar identifiers; (ii) additional information subject to Cal. Civ. Code § 1798.80(e), including your education, credit card number, state identification card number, signature, or bank account or other financial information; (iii) characteristics of protected classifications under federal or certain state laws, including gender, national origin, or marital status; (iv) commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth; (v) internet or other electronic network activity information, including interactions with our website or use of certain online tools; (vi) professional or employment-related information, including occupation, compensation, employer, and title; and (vii) inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.
In the preceding 12 months, we may have disclosed for a business purpose all of the above categories of personal information to all of the categories of third parties discussed below in “Sharing Personal Information with Third Parties.”
Sources of Personal Information
We may collect personal information about you directly from you and/or your intermediaries through sources such as: (i) account applications, subscription agreements, and other forms or related documentation; (ii) written, electronic, or verbal correspondence with us or our service providers; (iii) investor transactions; (iv) an investor’s brokerage or financial advisory firm, financial advisor, or consultant; or (v) from information captured on applicable websites. In addition, we may collect personal information from different sources, such as: (i) our affiliates, our service providers, or our affiliates’ service providers; (ii) public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; or (iii) credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.
Sharing Personal Information with Third Parties
We do not sell your personal information. We may disclose personal information to third parties in circumstances where we believe in good faith that disclosure is required or permitted under law, to cooperate with regulators or law enforcement authorities, or to protect our rights or property. We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.
For these reasons, we may disclose any of the categories of personal information discussed above in “Personal Information We Collect” to any of the following categories of third parties: (i) investors and investors’ intermediaries in connection with investments and transactions; (ii) third parties who deliver our communications, including postal services; (iii) third parties who assist with our information technology and security programs; (iv) third parties who assist with fraud prevention, detection and mitigation; (v) third parties as needed to complete a transaction, including financial institutions; (vi) third parties in connection with legal or regulatory matters, including government or regulatory agencies, courts, opposing counsel and parties to litigation; (vii) third parties in connection with the sale or transfer of all or any relevant portion of our business or assets; (viii) our lawyers, accountants, auditors, and consultants; and (ix) other third parties as permitted or required by law.
We also may disclose your personal information to our service providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that 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, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); and (v) 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 the personal information; (d) the categories of third parties to which we disclosed personal information about you for a business purpose; (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.
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. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request under the CCPA
You may submit a Request to Know, as described above, through the following telephone number: (561) 566-5112, or through our website at the following link https://beblankco.com/contact-us/.You may submit a Request to Delete, as described above, through the following telephone number: (561) 566-5112, or by email to email@example.com.
We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your authorized agent. Any information gathered as part of the verification process will be used for verification purposes only.
In order to verify Requests to Know and Requests to Delete, we will contact you via your telephone number to verify your identity by asking you questions specific to the account in question.
If an authorized agent seeks to submit a request on behalf of a California Resident, the authorized agent may do so by the aforementioned methods, however, they must provide: (i) signed authorization from the California Resident authorizing them to act on the California Resident’s behalf, unless they can provide proof that the California Resident has granted them power of attorney pursuant to California Probate Code sections 4000 to 4465; and (ii) proof of their registration with the California Secretary of State to conduct business in California. We also require that the California Resident directly verify their own identity with us and directly confirm with us that they provided the authorized agent permission to submit the request.
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