Effective Date:  November 1, 2023

This privacy policy (“Privacy Policy”) describes how BBR Partners, LLC and its affiliates (collectively, “BBR”) protects the privacy of personal information of users of our website (the “Site”). 

By using the Site, you consent to the collection and use of your personal information by BBR in accordance with this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use the Site.

If we decide to change our Privacy Policy, we will advise you of the changes through postings on our Site.  Your continued use after we provide notice will mean that you accept the changes. 

What does this Privacy Policy cover?

This Privacy Policy covers how BBR treats personal information that it collects and receives through the Site.  Personal information is information that can identify you specifically (e.g., your name, address, e-mail address or phone number), including information related to you that is collected through our Site and identified with those identifiers.  For California residents, personal information is broadly defined to include, among other things, nearly all information that reasonably can be directly or indirectly linked to an individual or household.  In all cases, personal information does not include deidentified information, aggregate information that cannot be linked to a particular individual, or pseudonymized information.

Personal Information – What we Collect and Why, and Sharing

For the 12-month period prior to the date of this Privacy Policy, the table below shows the categories of information we have collected, the purpose for the collection and, if the information was shared, with which categories of categories of third parties.

 

Data Category

Purpose and Sharing

Identifiers (e.g., name, signature, social security number, copies of identification, email address, street address) 

BBR may use this data in order to identify you, answer questions for you, improve the content of the Site, communicate with you about products and services, market to you or to exclude you therefrom, personalize services for you, associate other data with you, analyze other data we collect, consider new product offerings, and for security and fraud prevention.

Personal characteristics (e.g., date of birth, state of residence, self-identified gender, and marital status, and background information, such as information learned during know-your customer and anti-money laundering due diligence)

We may use this data in order to identify you, answer questions for you, communicate with you about our products and services, market to you or to exclude you therefrom, personalize our services for you, associate other data with you, analyze other data we collect, conduct due diligence and comply with legal obligations. 

Commercial Information (e.g., investment strategies, goals, history and trust and estate information, financial information such as assets, income, net worth, account information, beneficiaries, tax information) and investor accreditation and consents

We may use this data in order to answer questions for you, communicate with you about our products and services, market to you or to exclude you therefrom, personalize our services for you such as by adding investment restrictions to your account, associate other data with you, analyze other data we collect, and for security and fraud prevention. We also may use this information to make, maintain, manage and dispose of investments, conduct due diligence, evaluate and develop opportunities, and to manage our business and investor accounts.

Internet and other online activity, and device information (e.g.,  IP address, device ID, browser information and history, cookie information, operating systems, the pages you request, the path you take on the Website, user settings, your use of our Site)

We use this data to determine how people use parts of the Site or services so that we can make the Site as appealing as possible, and improve our services. We may share this data with service providers that host our Site.

Geolocation data

We may use this data in order to identify you, answer questions for you, customize content you see, communicate with you about our products and services. 

Professional or employment related information

We may use this data in order to identify you, market to you or to exclude you therefrom, personalize our services for you, associate other data with you, analyze other data we collect, and consider new product offerings. 

Educational information

We may use this data in order to identify you, market to you or to exclude you therefrom, personalize our services for you, associate other data with you, analyze other data we collect, and consider new product offerings. 

Insurance policy information

We may use this data in order to identify you, answer questions for you, communicate with you about our products and services, market to you or to exclude you therefrom, personalize our services for you, associate other data with you, analyze other data we collect.

Inferences drawn from other information

We may use this data in order to identify you, market to you or to exclude you therefrom, personalize our services for you, associate other data with you, analyze other data we collect, and consider new product offerings.

 

We will continue to collect the same categories of information and for the same purposes as listed in the chart above.  We also in the future may use the information we collect from you in the following ways: 

  • To respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
  • To investigate, prevent, or take action regarding alleged or actual illegal activities, violations of agreements with BBR, or as otherwise required by law.
  • To respond to regulatory requests and to comply with applicable laws and regulatory requirements, including laws pertaining to taxes on sales, and to monitor and audit compliance with internal policies and procedures.
  • To administer a promotion, survey or other Site or services feature.
  • We may also share information about you for any other purposes disclosed to you at the time we collect your information or with your consent.

Sharing with Third Parties in the Future.  We will continue to share information with third parties, as listed in the chart above.  We may also release your personal information when we believe release is appropriate to comply with the law, enforce our policies, or protect ours or others’ rights, property, or safety.  In addition, we may choose to buy or sell assets.  In these types of transactions, customer information is typically one of the business assets that are transferred.  If BBR, or substantially all of its assets were acquired, or in the unlikely event that the company goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party.  You acknowledge that such transfers may occur, and that any acquirer of BBR or its assets may continue to use your personal information as set forth in this policy.

Source of Personal Information.  We collect personal information that you provide to us.  We also collect personal information from third parties, including from advisors, vendors and publicly available sources.  We also may automatically collect certain information about the devices you use to access our Site, as well as information on how you interact with the Site, through cookies, web server logs, and other similar tracking technologies.

We use Google Analytics to monitor activity on our Site. To learn how Google Analytics collects and processes data, please visit, “How Google uses data when you use our partners’ sites or apps” available at: https://www.google.com/policies/privacy/partners/. 

No Sales of Personal Information

We have not sold personal information to third parties during the 12 months prior to the Effective Date of this Privacy Policy, and do not plan to do so without further notice (with the exception of a sale in connection with the sale or transfer of the business or our assets, as noted in the section above about sharing). 

Minors

If you are under 18, you should always get permission from your parents before providing any personal information (such as your name or email address). We do not knowingly allow anyone under the age of 13 provide personal information to us.

Do we use “cookies” or other tracking technology?  

We may use cookies. Cookies are small files that a Site or its service provider transfers to your computer’s hard drive through your browser (if you allow) that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we may use cookies to help us remember items you have searched for in the past. Cookies can also help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding visitors to our Site. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

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 browser (such as Chrome, Safari, Mozilla Firefox, Internet Explorer or Edge) 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 may not have access to features that make your Site experience more efficient and some of our services may not function properly, and registered users may not be able to login properly.

We (and our third party service providers) may also use technologies such as beacons, scripts, tags and clear gifs. These technologies may be used to analyze trends, administer our Site, track users across the Site, and gather demographic information about our user base on the whole. We may receive reports based on the use of these technologies on an individual and aggregate basis.

“Do not track” signals / Collection of data across sites and over time

Some Internet browsers include the ability to transmit “Do Not Track” signals.  We do not process or respond to “Do Not Track” signals.  We do not intentionally allow other parties to collect personally identifiable information about your online activities over time and across different websites when you use the Site or our services. 

Does this Privacy Policy cover third party links?

This Privacy Policy does not apply to third party links.  In an attempt to provide you with increased value, we may include third party links on our Site.  These linked websites have separate and independent privacy policies.  We therefore have no responsibility or liability for the content and activities of these linked sites.  Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these linked websites (including if a specific link does not work).

Does this Privacy Policy apply to offline or other information?

Except as provided below for California residents, this Privacy Policy applies only to information collected through our Site and not to information collected offline.

For California residents, this Privacy Policy applies to all personal information that we collect that can be linked directly or indirectly with you to the extent required under the California Consumer Privacy Protection Act (“CCPA”), the California Privacy Rights Act (“CPRA”) and other California privacy laws.  It should be noted that most of the provisions of the CCPA and CPRA do not apply to certain types of information, including information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.  We provide notices to customers and consumers as required by those laws separately.  We note also that all of the rights afforded to consumers under the CCPA and CPRA do not apply to personal information collected in certain contexts (such individuals acting as job applicants, employees or contractors). 

How do you ask questions and provide feedback?

If you have questions about this Privacy Policy or any feedback, please contact our privacy team at privacy@bbrpartners.com.

How do you make a request under the CCPA and CPRA?

You can make a request to (i) know; (ii) delete; (iii) opt-out; (iv) opt-in; (v) correct and (vi) limit by contacting BBR by electronic-mail at privacyrequest@bbrpartners.com or sending a written request to:

BBR Partners, LLC

Attention: Chief Compliance Officer

55 East 52nd Street, 18th Floor

New York, NY 10055

However, we will maintain copies of your information to the extent retained as part of our standard backup/archive process.  In addition, these procedures will not remove any of your information that you have provided to other users or third parties, or that has been collected from you by third parties linked from the Site.

Your California Privacy Rights

If you are a California resident, you have certain rights with respect to your personal information.  Those rights and how you may exercise them are described below.  Those rights are not absolute and BBR reserves all available rights in this regard.  It should be noted that most of the provisions of the CCPA and CPRA do not apply to certain types of information, including information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

Right to Know.  Under the CCPA and CPRA, you or your authorized agent may request that we provide you a list of the categories of personal information we have collected about you over the last 12 months, the categories of sources from which it was collected, the business or commercial purpose for collecting or selling the information, the categories of third parties to whom we disclosed or sold that information and the categories of information that the business sells or discloses to third parties.  You may also request that we provide you a copy of the specific pieces of personal information we have collected about you in the past 12 months.  You may make a request to know up to two times in a 12-month period, subject to limitations described in the law.  For a list of general categories of information that we have collected and shared in the past 12 months, see the table above.  This right does not apply to information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

Right to Opt-Out.  Under the CCPA and CPRA, you may opt-out of the sale or sharing of personal information.  BBR will respond as soon as reasonably possible to your request, up to a maximum of 15 business days from the date BBR receives your request to opt-out.

Right to Opt-In.  Under the CCPA and CPRA, BBR can only sell the personal information of a child that BBR knows to be under the age of 16 if BBR gets affirmative authorization (“opt-in”) for the sale of the child’s personal information.  For children under the age of 13, the opt-in must come from the child’s parent or guardian.  For children who are at least 13 years old but under the age of 16, the opt-in can come from the child.

Right to Delete.  Under the CCPA and CPRA, you or your authorized agent may request that we delete any personal information that we have collected from you, with the exception of information that the law allows us to keep.  When we respond to your request to delete, we will explain what (if any) information we have kept and why.  This right does not apply to information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations, other applicable federal laws or regulations or the California Financial Information Privacy Act.

Right to Correct.  Under the CCPA and CPRA, you or your authorized agent may request BBR to correct inaccurate personal information BBR has about you.

Right to Limit Use and Disclosure.  Under the CCPA and CPRA, you or your authorized agent may direct BBR only to use your sensitive personal information (e.g., your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

Non-Discrimination.  Under the CCPA and CPRA, you have the right to be free from discrimination for exercising your rights [to know or delete].  We will not deny you products or services, charge you different rates, or give you different discounts because you availed yourself of any of these rights. 

Right to Initiate a Private Cause of Action.  Under the CCPA and CPRA, you may have a right to bring private cause of action against BBR.

How to Make a Request Under the CPPA and CPRA.  Under the CCPA and CPRA, you or your authorized agent may make a request to (i) know; (ii) delete; (iii) opt-out; (iv) opt-in; (v) correct and (vi) limit by (a) emailing: privacyrequest@bbrpartners.com or (b) submitting a written request via mail to: BBR Partners, LLC, Attention: Chief Operating Officer, 55 East 52nd Street, 18th Floor, New York, NY 10055.  When you make a request, we will take steps to verify your identity before responding.  This is to protect your information.  At our discretion, such steps may include asking you to provide us your email and physical address.  If you maintain an account with us, these must match the address connected to your account.  We may then send you a physical letter to this address with a one-time code.  You must email us this code from the email address you provided to us.  Once you do, we will respond to your request.

Authorized Agent.  Under the CCPA and CPRA, you may designate an authorized agent to make requests on your behalf.  We will require verification that you did, in fact, authorize the agent.  Unless the law requires otherwise, your authorized agent must provide contact details for you.  We will contact you to confirm that you authorized the agent.  Once you confirm, we will promptly respond to the rights request. 

How Long Does BBR Have to Respond to my Request to Know, Correct and Delete?  Please allow up to 45 calendar days, which may be extended by another 45 days (90 total) if BBR notifies you, for BBR to process your request.  You may submit a request up to two times in a 12-month period.