Privacy Policy

Effective Date: March 4th, 2021

Last Reviewed on: March 3rd, 2021

Menin Investments LLC (collectively, “Company,” “we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This privacy policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide to us, including information we may collect when you visit a website, use a web application or use a mobile app operated now or in the future by or for Company, including, without limitation, https://www.bamfaminvestments.com/; all Company mobile apps and websites linked to this Privacy Policy now or in the future (each a “Website” and collectively the “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy also describes the rights and choices available to individuals with respect to their information.  We may provide additional or supplemental privacy policies to individuals for specific interactions at the time we collect personal information, such as employment interactions. Any such supplemental privacy policies will govern how we may processes the information in the context of the specific interaction. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Websites. By accessing or using our Websites, you agree to this Privacy Policy. This Privacy Policy may change from time to time.  Your continued use of any Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Sources of Personal Information

“Personal Information” is information that is not publicly available that identifies, relates to, describes or may be associated with you.  We may collect such Personal Information in any of the following ways:

·      Directly from You – We may collect information you provide to us, or that you authorize a third party to provide to us, including when you submit a rental application or any other form, whether electronic or paper; register on our Website; subscribe to receive alerts, newsletters, or event announcements; communicate with us by phone, e-mail or in person; register for or attend an event; or otherwise communicate with us.

·      Indirectly from You – We may use security and surveillance technologies, identity confirmation technologies (such as caller ID) or other data collection technologies, including those described under the heading Automatic Data Collection Technologies, below, to collect Personal Information about you when you visit our properties, use our Websites, or otherwise communicate or interact with our employees and service providers.

·      Third Parties – We may obtain Personal Information about you from third parties, including, without limitation, from credit reporting agencies, former employers, former landlords, social media platforms, rental listing companies, and other third party sources.

What Personal Information We Collect

When you visit our Website, we may collect, use and store Personal Information about you that falls into one or more of the following categories:

Identifiers.  Examples of identifiers may include your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).  Examples of Personal Information under the California Customer Records statute may include your name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Protected classification characteristics under California or federal law.  Examples of protected classification characteristics may include age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.

Internet or other similar network activity.  Examples of internet and network activity may include browsing history, search history, information on a consumer’s interaction with a Website, application, or advertisement.

How We May Use Personal Information That We Collect

We and our service providers may use Personal Information for the following purposes:

Provide Our Services.  We will use your Personal Information to respond to your inquiries and to provide you with the information, resources and support services you request.  We may use your Personal Information to better communicate with you, including to keep you informed about new developments and opportunities.  We may also use your Personal Information to understand how our services are used and to develop, evaluate and improve our programs and services.

Data Analytics.  We perform data analysis and research activities to gain a greater general understanding of visitors to our Website and the communities that we serve.

Other Business Purposes.  We may use your Personal Information when necessary to maintain the safety, security, and integrity of our Website, services, community and business.

Legal Obligation.  In rare cases, we may share your Personal Information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

With Your Consent.  In addition to the other uses described in this section, we may also use your information as you expressly authorize us to do so.

With Whom We May Share Your Personal Information

To provide our services, your Personal Information may be shared with:

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Website (such as customer support, hosting, analytics, email delivery, and database management services). These third parties may use your personal information only as directed or authorized by us and are prohibited from using or disclosing your information for any other purpose.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Governmental authorities. We may disclose your personal information to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Websites and our products and services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Your Consent. In addition to the other disclosures described in this section, we may also disclose your information as you expressly authorize us to do so.

No Sale of Personal Information.  Except to the extent California law treats services that help deliver interest-based ads as a “sale” of Personal Information, we do not sell, rent, or otherwise make Personal Information commercially available to any third party and we do not share your Personal Information with unaffiliated third parties for promotional or advertising purposes. 

Automatic Collection Technologies

We may collect information that does not reveal your specific identity or does not directly relate to an identifiable individual, referred to throughout this Privacy Statement as “Other Information,” including browser and device information, Website usage data, Internet Protocol address, information collected through cookies, pixel tags and other technologies.  Other Information also includes information that has been anonymized or aggregated in a manner that it no longer reveals your specific identity.

            We use the following automatic collection technologies to collect Other Information, which may or may not be combined with Personal Information:

·      Log Files: Most Internet browsers transmit certain information to websites that you visit, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files. We use this information to ensure that the Website functions properly.

·      Cookies: Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer or smartphone) when you visit a website. Cookies allow us to recognize your browsing device and preferences and generally help to improve your online experience, as well as to provide us with anonymous information to check the usefulness of, and make improvements to, our Website. Cookies may be placed on your computer and/or mobile device by both us and by third parties with whom we have a relationship, such as web analytics services. You may refuse cookies by activating the setting on your browser. However, if you select this setting, you may not have the same user experience. To learn more about how to manage cookies, visit www.allaboutcookies.org/manage-cookies/ (please note that this website is not connected to us and we are not responsible for its content).

·      Web Beacons and Pixel Tags: We may utilize a technology called a “web beacon” or “pixel tag”.  We may use web beacons to help determine which email messages sent by us were opened and whether a message was acted upon. Web beacons also help analyze the effectiveness of websites by measuring the number of visitors to a site or how many visitors clicked on key elements of a site. 

·      Third Party Analytics: We also use automated devices and applications, such as Google Analytics (more info https://support.google.com/analytics/answer/6004245?hl=en-GB) to evaluate the use of our Website. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Website with other information they have collected for their own purposes. This Privacy Policy does not cover such uses of data by third parties.

·      Do Not Track Signals: We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Your Choices About How We Use and Disclose Your Information

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

·      Marketing Communications. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending your request to info@bamfaminvestments.com. You can also always opt-out by following the opt-out or unsubscribe instructions at the bottom of the email.  Please note that such requests may take up to ten (10) business days to become effective.  You may continue to receive service-related and other non-marketing emails.  If you receive marketing text messages from us, you may be able to opt-out of receiving further marketing text messages from us by replying STOP to our marketing message, or by contacting us at info@bamfaminvestments.com.

·      Telephone Communications. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

·      Modify Your Information.   You may request to review, correct, update, suppress or otherwise modify any Personal Information that you have previously provided to us through the Website, or object to the use of such Personal Information by us.  For your protection, we will only implement requests with respect to the Personal Information associated with the particular individual if we can verify the identity of that individual (see Exercising Access, Data Portability, and Deletion Rights below for verification process). We aim to comply with requests as soon as reasonably practicable.

·      Targeted Interest-Based Advertising. Some of the business partners that collect information about users’ activities on or through the Websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.  You may stop or restrict the placement of cookies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.aboutads.info/choices/, https://youradchoices.ca/choices/,  www.networkadvertising.org/managing/opt_out.asp, and http://www.youronlinechoices.eu/. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Notice to California Residents

The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their Personal Information.  This section describes California residents’ CCPA rights and explains how to exercise those rights.  These rights are not absolute and, in certain cases, we may decline a request as permitted by law.

Information Rights.  California residents have the right to request the following information about how we have collected and used your Personal Information during the past 12 months: (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which we collected Personal Information; (c) the business or commercial purpose for collecting and/or selling Personal Information; (d) the categories of third parties with whom we share your Personal Information; (e) whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient; and (f) whether we have sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.

Access Rights.  California residents have the right to request a copy of the Personal Information that we have collected about them during the past 12 months.

Deletion Request Rights.  California residents have the right to ask us to delete any of their Personal Information that we have collected and retained, subject to certain limitations.  We may deny a Deletion Request and will provide notice of our legal basis for denying such request.

Non-Discrimination.  You are entitled to exercise the rights described above free from discrimination.  This means that we will not penalize you for exercising your rights by taking actions such as denying you services, increasing the price/rate of services, decreasing service quality, or suggesting that we may penalize you as described above for exercising your rights.

If you are a California resident and which to exercise one or more of your rights as provided above, please use one of the contact methods provided under “Contacting Us.” We will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity, and understand and respond to the request.

Third Party Sites 

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Website contains a link. Please read the terms, conditions and policies of such third party sites before accessing or using such sites. The inclusion of a link on the Website does not imply any endorsement of the linked site by us or by our affiliates.

Security

To prevent unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and to ensure the correct use of information, we employ physical, technical and administrative procedures to safeguard this Website and the personal information we collect. All of our employees and any third parties we employ to process your personal information are obliged to respect its confidentiality. However, transmission of information through the internet is not secure. Although we seek to protect your information as described above, we cannot guarantee the security of any information you transmit to the website or to us, and you transmit such information at your own risk.  Please do not send sensitive or confidential information to us by email or by any other means in connection with the Website. If you have reason to believe that your communications with us have been compromised in any way, please immediately notify us of the problem by contacting us as provided in the “Contacting Us” section below. 

Retention Period 

            We will retain your Personal Information and Other Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. 

Use Of Website By Minors 

            Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using the information provided in the “Contacting Us” section below.

Governing Law and Jurisdiction

            All matters relating to the Website and the Privacy Policy, and any dispute or claim arising therefrom or related thereto, shall be governed by and construed in accordance with the internal laws of the State of California without giving effect to any choice or conflict of law provision or rule (whether of the State of California or any other jurisdiction).  This Website is operated, in whole or in part, from the United States.  By using this Website, regardless of where you live in the world, you consent to have any Personal Information you provide through this Website transferred to and processed in the United States, and allow us to use and collect your Personal Information in accordance with this Privacy Policy.  Text on this Website may be published in languages other than English.  In all instances, the English language version of any text, including this Privacy Policy, controls the legal impact and interpretation of this Website and its use.

Cross-Border Transfer

            Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Website you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country. 

Sensitive Information

            We ask that you not send us, and you not disclose, any sensitive information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership), or other information you consider to be confidential, on or through the Website or otherwise to us. 

Contacting Us 

            If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 888-921-0116

Email: info@bamfaminvestments.com