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Berraco Capital LLC, Series 3 (“we”, “us” and “our”) is sensitive to your concerns about how we use the personal information we collect from you and about you. We take your privacy seriously, and have implemented this privacy policy (the “Privacy Policy”) and internal policies and practices to keep your personal and financial information secure. The Privacy Policy covers our treatment of the Personally Identifiable Information we collect about you. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy is incorporated into our Terms of Use and Additional Terms of Service , and therefore governs your use of the Online Services. By using our site, applications and services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, please contact us at support@brrrrinvest.com.
Traffic Data – We may collect a variety of visitor data such as IP addresses, browser settings, internet service provider (ISP) information, referring/exit pages, operating systems, date/time stamps, and clickstream data (collectively “Visitor Data”). Our internal servers and software may automatically recognize Visitor Data. Our website (the “Site”) may use Visitor Data to compile traffic data about the types of visitors who use the Site at specific intervals (collectively “Traffic Data”). We may use Traffic Data to analyze Site traffic, but this information is not examined for Personally Identifiable Information. We may also use Traffic Data to diagnose problems with our server, administer our Site, or display content according to your preferences. Visitor Data and Traffic Data may also be shared with business partners, affiliates, or advertisers on an aggregated and anonymous basis.
Cookies and Similar Technologies – We and our partners may use the standard cookie feature of major browser applications and third-party providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow us to store a small piece of data on a visitor’s computer, or any other device a visitor uses to access Online Services, about his or her visit to the Site or use of other plug-ins exchanging information with us (“Applications”). (The Site and Applications are sometimes collectively referred to as “Online Services” for simplicity.) Similar technologies, such as java scripts or etags, are also used to analyze trends, administer the website, track users’ movements around the Site, and to gather demographic information about our user base as a whole. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such order forms, may be limited.
Web Beacons – We may employ a software technology called clear gifs (a.k.a. web beacons), that help us track referrals from our partners and affiliates and better manage content on our site. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ Personally Identifiable Information.
3rd Party Tracking –The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media links) on the site is not covered by our Privacy Policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers’ or Users’ Personally Identifiable Information.
Personal Information – We require each customer to provide us with personal information (collectively “Personally Identifiable Information”) to access and use our products and services. Personally Identifiable Information is captured when a visitor accesses Online Services, or emails or speaks on the phone with one of our representatives, and willingly discloses that information. This disclosure may occur when a visitor registers with an Online Service, engages in transactions, contacts customer service, or participates in contests, promotions, surveys, forums, content submissions, requests for suggestions, or other aspects of services that we offer.
Personally Identifiable Information includes but is not limited to: (i) “Contact Data” (such as your name, address, city, state, zip code, phone number, and email address); (ii) “Financial Data” (such as your credit card number, expiration date, and verification code or bank account information and investment transaction data); (iii) “Demographic Data” (such as your zip code and sex); and (iv) other “Legal Data” (such as your social security number, EIN number, mortgage information, automobile information, marital information, trade secrets, inventions, and idea submissions and other sensitive information necessary to generate legal documents).
We may also receive information about our customers or potential customers from other sources, including from employers who have purchased our products on behalf of their employees, from publicly available sources, and through other commercially available sources of information. In some instances we may combine this data with information we already have or that we later receive from our customers. This helps us to update, expand, and analyze our records, and to provide better service to our customers and potential customers. Other than information obtained from publicly available sources, we will only use this information for the specific reasons that it was provided to us, which may include marketing related uses. Examples of the types of Personally Identifiable Information that we may receive from third parties include Contact Data and Legal Data.
We may collect information from you about third party individuals in order to provide you service. For example, we may ask you for information about the beneficiaries in your will, shareholders of a company, or authorized contacts to access your account. We use this information for the sole purpose of administering services to you, and do not use such information for any other reason.
If you are not a customer of ours but believe that we have your personal information that you would like to be deleted, please contact us at support@brrrrinvest.com. If you are a customer of ours, please refer to the section “Accessing and Changing Your Account” for information about accessing and deleting your account.
Certain personal information becomes public record when documents are filed with the federal or state government, or with a court. For example, a corporation’s name, business address, and registered agent name become public information when its articles of incorporation are filed. A Secretary of State may publish this information to its website or provide this information to third parties for a fee. The U.S. Patent and Trademark Office publishes the names and addresses of trademark registrants. In some states, fictitious business names, including the name and address of the business owner, must be published in a newspaper. This Privacy Policy does not cover these or similar third-party actions.
Testimonials and Reviews – We display personal testimonials of satisfied customers received through email surveys. We ask for your specific consent as part of the survey. If you wish to update or delete your testimonial, you can contact us at support@brrrrinvest.com. We also display customer reviews. If you provide a review that we display and wish to update or delete it, you can also contact us at support@brrrrinvest.com.
Calls/Electronic Communications – In the regular course of our business, we may monitor and record phone conversations or email communications between you and our representatives for training and quality assurance purposes. We may receive a confirmation when you open or click on content in an email from us, which helps us make our communications to you more useful and interesting. If you do not wish to receive email from us, you may unsubscribe from our mailing list by following the instructions in any of the emails we send.
We use information we collect to communicate with you, process your orders, facilitate your transactions with our third-party marketing partners, for research into how to improve our product offerings, and inform you of offers and discounts. For example, you may receive a welcome email that confirms your username and password, and later receive communications responding to your inquiries, providing services you request, and managing your account. We occasionally send service-related announcements, for example, to alert you if we need to temporarily suspend the Site for maintenance.
Opting Out – We send promotional emails and newsletters from time to time to users who have registered on the site and to those who have opted in to receive such emails. Generally, you may not opt-out of service-related or transactional communications, which are not promotional. If you do not wish to receive service-related communications, you may terminate your account by contacting us at support@brrrrinvest.com. However, you can opt-out of promotional communications by using the “Unsubscribe” or similar link and following the unsubscribe instructions in any electronic communication or by emailing us at support@brrrrinvest.com.
You may choose not to provide us with Personally Identifiable Information or you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to use the Online Services and browse its pages. However, we cannot process orders without Personally Identifiable Information.
Surveys, Sweepstakes, and Contests – We may provide you the opportunity to participate in surveys on our site, to measure customer satisfaction. If you participate, we may request certain personally identifiable information from you. Participation in these surveys, sweepstakes, or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes name, email address, and mailing address.
We use this information to notify contest winners and award prizes, to monitor site traffic or personalize the site, and/or to send participants an email newsletter.
We may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personal information for any other purpose. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.
We share customer information with third parties only as follows:
Order Processing – We, sometimes with the assistance of a third party, may use your Personally Identifiable Information to process your payment through merchant account services, and to generate the products and services you order. Your Contact Data may be used to follow up with you on transactions you initiate, respond to inquiries, inform you of changes to Online Services, and send you additional information about us and our products and services.
Registered Agent Requests – If you have a person or company that serves as the registered agent for your business entity, we may provide your name and contact information to that party, if the designee requests.
Third Party Marketing – Unless specifically authorized by you, we do not provide Personally Identifiable Information to third parties for their marketing purposes. If you express interest in a third party offer, we may provide your Personally Identifiable Information to that third party solely in connection with the offer you have selected. In addition to sharing your Contact Data, we may also share details regarding your purchase from us, as well as your Financial, Demographic, or Legal Data with these third parties. If you later decide to opt-out from allowing us to share your Personally Identifiable Information with third parties for their marketing purposes, you may do so by contacting us at support@brrrrinvest.com. To the extent that we have already shared your Personally Identifiable Information with third parties for their marketing purposes prior to your decision to opt-out, you may opt out from future marketing by contacting the Third Parties directly.
Required by Law – We may also disclose your personal information: as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.
Visitor Demographics – Contact Data and Traffic Data are used to gather general statistics about our customers and visitors. We may use Demographic Data to generate collective information about our users, but not in a way that identifies any user specifically. For example, we may inform third parties about the number of registered users and unique visitors, and the pages most frequently browsed.
Legal Plan Attorneys and Attorney-Assisted Products – As a convenience to you and your attorney, we may share your Personally Identifiable Information, information about your order, and your order history with your legal plan attorneys and with attorneys who service our attorney-assisted products. We will notify you prior to sharing this information and, where the information is not necessary to complete your order, give you the opportunity to opt-out.
Service Providers – We may share your Personally Identifiable Information with companies that provide support services to us (such as a printer or email service provider), help us market our products and services, or for training purposes. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.
Business Partners – When you purchase a product from us that is bundled with a product offered by one of our business partners, we will share your Personally Identifiable Information with those business partners so that they can provide you with the product or services included with your purchase. These companies are not authorized to use the information we share with them about you for their own marketing purposes without first asking for your permission.
Partner and Affiliate Tracking – Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect non-personally identifiable information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visits to our Site. Together with our partners and affiliates, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to our site.
If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://aboutads.info/choices. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by contacting us at support@brrrrinvest.com. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also visit Google Analytics’ Ads Settings to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web.
Blogs and Forums – The Site includes a publically accessible blog and interactive forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You should use caution when deciding whether to disclose your personal information in these areas of the site. To request removal of your personal information from our community forums, contact us at support@brrrrinvest.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Other Transfers – We may share Personally Identifiable Information and other data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer Personally Identifiable Information and other data in connection with the associated transactions.
Bankruptcy – In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. If such an event occurs, your Personally Identifiable Information may be treated like any other of our assets and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Third-Party Websites – We may maintain links to other websites and other websites may maintain links to the Online Services. This Privacy Policy applies only to our Site and not to other websites accessible from our Site or that you use to access our Site, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, we are not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of such other websites to confirm that you understand and agree with them. Social Media Widgets. Our website includes social media features, such as the Facebook “like” button and widgets, such as the “Share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Social Media Widgets – Our website includes social media features, such as the Facebook “like” button and widgets, such as the “Share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Upon request we will provide you with information about whether we hold any of your personal information. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service. Please review the information below to access, correct, or request deletion of your personal information.
User and Authorized Contact Access to Order Information – We will give you, or anyone listed as an authorized contact for your account, information about your order. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list them as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on “My Account”, and then on “Account Information”. We may send a confirmation email to your authorized contact(s), alerting them that they have been added as an authorized contact. For some products, we may provide information about your order to other individuals named in the order, such as executors named in a last will. For product-specific information about who may request information about your order, please contact us at support@brrrrinvest.com.
User Access to and Ability to Update Personally Identifiable Information – You may visit your personal account profile at any time. Through your account, you may: (i) review and update your Contact Data; (ii) complete pending orders; and (iii) begin new orders. If you no longer desire our services, or if you want to remove your Personally Identifiable Information from our Site, you may terminate your account by contacting us at support@brrrrinvest.com. We will respond to your request within 30 days.
Data Retention – At minimum, we will retain your information for as long as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may maintain some or all of this data in our archives even after it has been removed from the Site.
In some instances, we may process Personally Identifiable Information on behalf of third party affiliates. We acknowledge that in these instances, you have the right to access your personal information. Where we have no direct relationship with the individuals whose personal data it processes, individuals seeking access, or seeking to correct, amend, or delete inaccurate data, should direct their inquiry to the third party affiliate (the data controller). If requested to remove the data, we will respond within a reasonable timeframe.
WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SITE, APPLICATIONS, AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES PLEASE CONTACT US IMMEDIATELY AT support@brrrrinvest.com.
Enforcement. We periodically review this Privacy Policy and our compliance with it to verify that both are accurate. We encourage you to contact us with any concerns, and we will investigate and attempt to resolve any complaints and disputes about our privacy practices.
For California Residents, we intend to comply if so legally required with the requirements provided for in the California Consumer Privacy Act (CCPA) effective January 1, 2020, including the provision of all information required to be provided under that act and its opt-out procedures. Please contact us at support@brrrrinvest.com for all requests arising under that Act.
Changes to this Policy – We may update this privacy policy to reflect changes to our information practices. If we make any material changes a notice will be posted on this page along with the updated Privacy Policy prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us – If you have any questions regarding our Privacy Policy, please contact us at support@brrrrinvest.com.
If you are located in the EU, this section provides information regarding your rights, and our responsibilities, regarding the processing of your personal data.
EU User Rights – If you are located in the EU, you have the following rights with respect to how we process your personal data.
To exercise any of these rights, please contact us at support@brrrrinvest.com.
If you are located in the EU, you also have the right to raise any objections regarding the processing of your personal data and to raise any concerns you may have about our processing of your personal data. You may make an objection or raise any other concerns by contacting us at support@brrrrinvest.com.
While we hope that we can resolve any of your privacy concerns to your satisfaction after you contact us directly, you also have the right to file a complaint regarding our handling of your personal data with the Information Commissioner’s Office, the UK’s independent Data Protection Authority. Their contact information is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
https://ico.org.uk/global/contact-us/email/
+44 1625 545 700
Updated: October 1, 2019
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