Effective Date: August 5, 2019. Bulleit Group LLC (the “Company”) takes privacy matters seriously and wants you to be familiar with how we collect, use, and disclose data. The Company provides this Privacy Policy to explain our practices regarding the collection, use, disclosure, and protection of personal information that apply to our website at www.bulleitgroup.com, including, without limitation, our mobile websites, mobile applications, social networking or other interactive media sites, other online or mobile services, and any other platforms that link to this Privacy Policy (collectively, the “Site”), as well as your choices regarding the collection and use of your information. This Privacy Policy does not apply to information we collect by means (including offline) or from other sources other than through the Site. As part of our commitment, we strive to protect the privacy of visitors to the Site. You can navigate the majority of the Site without giving us any personal information which identifies you. However, sometimes we need additional information about you in order to provide you with information or services you want to receive from us. In this digital world, privacy is important to the Company and should be important to you. The Company believes in transparency and we provide this notice so that you can understand our online information practices and the choices you can make about the way your information is collected and used. The Information We Collect and Process The Company collects and processes two basic types of information: Personally identifiable information: This is information that personally identifies one individual from another or enables you to be individually contacted (for example, names, e-mail addresses, and other contact information) (“Personally Identifiable Information”). This information is voluntarily provided to us by Site visitors and is used by us for the purpose of responding to user submissions and fulfilling requests for further information about our services. The Company only collects Personally Identifiable Information that you voluntarily provide, for example, when you use our “Contact Us” feature. Under such circumstances, you consent to our use/processing of the information you provide consistent with this policy. Non-Personally Identifiable Information: We also collect and use information about your interactions with the Site in a manner and format that does not identify you as an individual (“Non-Personally Identifiable Information”). This information gives us insights on how Site visitors use our site. This data is anonymous and does not contain any personally identifiable information. We use this information to ensure that our website, e-mails, and marketing efforts continue to appeal to Site visitors and clients. Generally, we do not combine or associate Non-Personally Identifiable Information with your Personally Identifiable Information. If we do combine Non-Personally Identifiable Information with Personally Identifiable Information, we treat the combined information as Personally Identifiable Information. We may collect, use, and disclose Non-Personally Identifiable Information as set forth below. Other Information the Company Collects/Processes Our Site may use technologies such as “cookies” to provide visitors with tailored information upon each visit. Cookies are a common part of many commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard drive as recognition for repeat visits to the Site. Every time you visit the Site, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to the Site, and your browser and operating system. We may also use third-party analytical tools (e.g. Google Analytics) to analyze activities on the Site and use of the Site. You do not need to enable cookies to visit the Site; however, some parts of the Site and some services may be more difficult or impossible to use if cookies are disabled. Some Company cookie files remain on your computer’s hard drive unless and until you manually delete the file. The Company cookie files do not contain personally identifiable information. The Way We Use Information We store the personal information you provide in a secure database in order to provide you with the information, products, and/or services you request and may be used to provide you with additional information about the services we believe may be of interest to you. The information is stored for a time period and in a manner relevant to responding to your request unless you request that it be removed. The information you provide us will be shared with the Company employees and service providers to the extent necessary to administrate our systems and/or accommodate your request. For example, if you provide your name, mailing address, telephone and/or email address and request more information about the Company’s services, this information will be shared with appropriate Company personnel to fulfill your request. This information will not be shared with non-affiliated third parties without your consent. We use non-identifying and aggregate information about the use of the Site to improve the navigation, content, and design of the Site. This information may include, for example, the most and least requested pages, analyzing traffic regarding specific features, and the number of users from the U.S. and other countries, among other things. The Company will not sell or distribute personally identifiable information collected from you outside of the Company without your consent (subject to the limited exceptions stated in this policy). How Information May be Shared or Disclosed The Company may preserve and has the right to disclose any information about you or your use of the Site without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of the Company or its clients or their respective partners, employees, affiliates, other users of the Site, or the public; or (b) respond to claims related to your use of the Site. We may also disclose information as required by law or subpoena to satisfy any applicable law, regulation, legal process or lawful governmental request (including to meet national security or law enforcement requirements) or in the event of a sale or potential sale, merger, acquisition, bankruptcy, or dissolution of the Company or one of its business units or similar transactions or proceedings. Data Security The Company understands that the safety of your personal information is extremely important to you. Accordingly, the Company uses reasonable technological, physical and other measures to keep your information protected from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the personal information. Due to the nature of the Internet and related technology, we cannot guarantee the security of any information, including your Personally Identifiable Information, and the Company expressly disclaims any such obligation. Retention Period We will retain information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Children’s Privacy The Company understands the need to protect the privacy of children. The Site is not intended for use by individuals under 13 years of age. The Company does not knowingly collect or maintain personal information from children under the age of 13 at our Site. By using the Site, you are representing that you are not under the age of thirteen. If we obtain knowledge that a child under the age of thirteen has provided us with personally identifiable information, we will promptly delete such information. If you are a parent or guardian and discover that your child has provided any such Personally Identifiable Information to us, then you may contact us at the email or mailing address noted at the end of this Privacy Policy below and request that we delete that information from our systems. How You Can Access or Correct Your Information You may access, update or remove the information you provided to us by contacting us—see “How to Contact Us” below. Similarly, Site users who wish to subscribe or unsubscribe to our marketing and informational communications or limit our use of any Personally Identifiable Information in any way can do so by using the subscribe/unsubscribe options contained in our emails or by sending an email to info@bulleitgroup.com. Upon receiving your email with the request to update or remove your information, our privacy team will: 1) log the receipt of your request, including the date and time received; 2) take reasonable steps (including seeking additional information or documentation) to verify your identity, 3) evaluate the request (including, to the extent necessary, contacting the appropriate data holder); 4) once the evaluation is completed, take action consistent with the evaluation; and 5) respond to your request accordingly. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business. Information stored as part of this backup process will be deleted in due course on a regular schedule. Some information may be retained for longer periods as required by law, contract, or auditing requirements. Links to Other Websites Our Site contains links to other websites. The Company is not responsible for any websites that it does not own or operate. You should carefully review the privacy policies and practices of other websites that you link to from the Site, as we cannot control or be responsible for their privacy practices. International Users Information provided through this Site may be uploaded to a cloud and transferred to or accessed globally. By providing information to this Site, you consent to the transfer, processing and/or use of the information globally throughout the Company. Wherever the information is transferred or accessed within the Company it will be processed and used in accordance with this privacy policy. Your Rights If You Are a Resident of the European Union Subject to applicable data protection laws, customers and users have the following rights with respect to the Company’s handling of Personally Identifiable Information for which the Company is the data controller:
- Access. The right to request access to Personally Identifiable Information held by the Company.
- Objection. The right to object to certain processing of Personally Identifiable Information (unless the Company has overriding compelling grounds to continue processing), including the right to opt-out of receiving direct marketing. We will, however, continue to use Personally Identifiable Information for the limited purpose of communicating important notices relating to changes to the Service or policies, and other reasons permitted by law.
- Rectification. The right to request correction of Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated.
- Right to be Forgotten. The right to request erasure of all Personally Identifiable Information that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. The Company will do everything possible to erase Personally Identifiable Information if a user or customer so requests. However, the Company will not be able to erase all Personally Identifiable Information if it is technically impossible due to limitations of existing technology or for legal reasons, such as Fauna is mandated by applicable law to retain Personally Identifiable Information.
- Restriction of Processing. The right to request restriction of processing Personally Identifiable Information for certain reasons, such as the inaccuracy of Personally Identifiable Information.
- Data Portability. If requested, the Company will provide Personally Identifiable Information in a structured, secure, commonly used and machine-readable format.
- Right to Withdraw Consent. If Personally Identifiable Information is processed solely based on consent, and not based on any other legal basis, customers can withdraw consent at any time.
- Data Protection Contact. The right to contact the relevant data protection regulator regarding the Company’s handling of Personally Identifiable Information.
To exercise any of the above-listed rights, email the Company at info@bulleitgroup.com or mail to: The Bulleit Group, LLC 18 Bartol Street #1320, San Francisco, CA 94133, Attn: Privacy. The Company will process requests in accordance with applicable law, with reasonable efforts and within a reasonable period of time. Notification of Changes As we provide more services and/or functionality on our Site and as privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. We will put an “Updated” note on the link to the Privacy Policy on the Site’s home page so that you will be able to check regarding changes which may be of particular relevance to you. Do Not Track At this time, our Site does not support “Do Not Track” preferences that may be available in your browser for letting websites know that you do not want them collecting certain kinds of information. If you turn on the “Do Not Track” setting on your browser, our Site is not currently capable of following whatever Do Not Track preferences you set. For more information about Do Not Track, visit www.donottrack.us. California Privacy Rights Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents who provide Personally Identifiable Information in obtaining products and services for personal, family or household use are entitled to request and obtain from the Company, once per calendar year, information about Personally Identifiable Information the Company has shared, if any, with other businesses for their own direct marketing uses. The Company does not currently share your Personally Identifiable Information with other businesses for their own direct marketing uses. However, if applicable, this information would include the categories of Personally Identifiable Information and the names and addresses of those businesses with which the Company shared Personally Identifiable Information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information, please send an email to info@bulleitgroup.com with “Request for California Privacy Information” in the subject line, or via mail to: The Bulleit Group, LLC 18 Bartol Street #1320, San Francisco, CA 94133, Attn: Privacy. How to Contact Us If you ever have any questions about this Privacy Policy, please contact us at info@bulleitgroup.com or via mail at: The Bulleit Group, LLC 18 Bartol Street #1320, San Francisco, CA 94133, Attn: Privacy.