Privacy Policy

 

Effective Date August 10, 2020

Our Commitment to Privacy

Your privacy is important to us at BBF Cooper Jack Ltd. (the “Company”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  This online privacy statement (the “Statement” or “Notice”) describes how we collect, use, disclose, and the security of the personal information we gather about you through our website, www.TheStrandTCI.com (the “Website”) or otherwise.  It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Please note that this Statement does not apply to data that does not classify as personal information, personal data, or personally identifiable information under various statutory and regulatory exemptions, including, but not limited to, information that has been aggregated, de-identified, or anonymized.  

This Statement doesn’t apply to any other website maintained by other companies or organizations to which we link.  The Company is not responsible for the content or activities provided on those websites.


You Consent to This Statement

You should read this Statement carefully.  We recommend printing and retaining a copy for your future reference.  By accessing, browsing, or otherwise using the Website, you confirm that you have read, understood, and agreed with this Statement.  If you do not agree to this Statement, you may not use this Website.

This Statement applies regardless of how the Website is accessed and will cover any technologies or devices by which the Company makes the Website available to you.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described below in the “How to Contact Us” section below.

 
The Information We Collect and How

We collect the information you voluntarily provide directly to us, such as when you complete a form or submit information to us.  We also collect information when you interact with the Website, for example, through our use of cookies.

Information You Provide

  • Completing Forms on Our Website. If you request to receive information or fill out any forms on our Website, we may ask you to provide information such as your name, e mail address, and/or mailing address.
  • When You Contact Us. If you send us an email, we will collect your email address and any information that you provide in the email.
  • When You Purchase a Property.  If you purchase a property or interest from us, we will collect various pieces of information about you. 
  • Social Media. If you interact with our Website by sharing on a social media platform, we may collect information that you post.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.
  • Job Applications.  If you apply for a job with us, we will collect various pieces of information about you.


Information That We Collect About You

We may collect information about you from third parties.  For example, we may receive information about you from third parties that believe you may be interested in our properties, interests, services, or other information. 

Information We Collect as You Navigate Our Website

We automatically collect certain information as you use the Website, such as the following:

  • Usage Information.  We may collect information automatically through your use of the Website, such as which of the pages on the Website you access, the frequency of access, and what you click on while on our Website.
  • Device Information.  We may collect information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.
  • Mobile Device Information.  In addition to the Device Information listed above, when you access our Website via a browser on your mobile device, we may collect mobile network information, including telephone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.
  • Location Information.  We may collect information about your actual location which may be determined from GPS and other sensors that may reveal information on or nearby devices, Wi-Fi access points, and cell towers.

How Do We Use “Cookies” and Other Tracking Technologies? 

We may send one or more Cookies to your computer or other device.  We also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Website.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Website.  This information allows us to understand how you use the Website.

What Are Cookies?

Cookies are small files created by websites, including our Website, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Website, we use Cookies and other tracking technologies to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Website according to your individual needs;
  • Contact you to provide you with information or services that you request from us;
  • Advertise new content, events, and services that relate to your interests;
  • Provide you with more personalized content that is most relevant to your interest areas; and
  • Recognize when you return to our Website


We set some Cookies ourselves and others are set by third parties.  You can manage your Cookies preference as described in the “
Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

These are the different types of Cookies that we and our service providers use on the Website:

  • Essential Cookies.  These Cookies are required for the operation of the Website and enable you to move around the Website and use its features.  Disabling these Cookies can negatively impact the Website’s performance.
  • Analytics, Performance and Research Cookies.  These Cookies allow us to analyze activities on the Website.  They can be used to improve the functioning of the Website.  For example, these Cookies recognize and count the number of visitors and see how they move around the Website.  Analytics Cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the Website’s content for those who engage with our advertising.
  • Functionality Cookies.  These Cookies are used to recognize you when you return to the Website.  This enables us to personalize content for you and remember your preferences.
  • Social Networking Cookies.  These Cookies are used to enable you to share pages and content that you find interesting on our Website through third-party social networking and other websites.  These Cookies may also be used for advertising purposes.


How Long Do Cookies Stay on My Device?

Some Cookies operate from the time you visit the Website until the end of that particular browsing session.  These Cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These Cookies are called “persistent cookies” and the length of time they will remain on your device will vary from Cookie to Cookie.  Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Website, how your use of the Website may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies.  If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Website.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Website, compile reports on the Website’s activity, and provide other services related to Website activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

We also use Google Remarketing features to collect data about visitors to our Website to, among other things, deliver advertising content on sites across the Internet in a manner that is specifically directed toward the interests expressed by the visitors while on our Website. Google uses Cookies to serve ads based on someone’s past visits to the Website. You can opt-out of Google’s use of Cookies to serve ads based on your past visits to the Website via the following link: Google Ad Settings.

Does the Website Respond to “Do Not Track” Signals?

There is currently no industry agreed-upon response to a Do Not Track signal.  At this time, our Website does not respond differently based on a user’s Do Not Track signal.

 
How We Use the Personal Information

We use personal information we collect about you or that you provide to us in the following ways:

  • To present our Website and its contents in a suitable and effective manner for you and your device;
  • To contact you to provide you with information or services that you request from us;
  • To advertise properties, activities, services, or special events that we think may be of interest to you;
  • To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
  • To carry out our obligations and enforce our rights arising from any contracts; and
  • To notify you about any additions, upgrades, or changes in our services.

How We Share the Personal Information We Collect

The Company may share your personal information:

  • With third parties who perform data services on our behalf (e.g., hosting, maintenance, backup, analysis, etc.).  Any such third parties will be under an obligation to us to maintain the confidentiality of your personal information.
  • To third-party service providers to prepare, deploy, and analyze advertising content;
  • To the extent that we are required to do so by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
  • To third-parties so that they can market products, information, campaigns, or services to you;
  • To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information;
  • To any third parties as part of any business or asset sale; 
  • In the event of bankruptcy or dissolution proceedings, as part of the sale or reorganization process; and
  • To any other person or entity where you consent to the disclosure.

Legal Bases for Processing Your Personal Information

If you are in a country in the European Union, you may be entitled to an explanation of the legal bases we rely on to process your personal information.  The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.

Consent

We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications.  You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Our Legitimate Interests

We may process your personal information if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests.  For example, when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Website.

To Perform a Contract

We may process your personal information to administer and fulfill contractual obligations to you.

To Enable Us to Comply with a Legal Obligation

We may process your personal information to comply with legal obligations to which we are subject.  This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims

If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

The Company is the Data Controller of all personal information collected from residents of the European Union.  If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “How to Contact Us” section below.

 
Advertising and Marketing Choice

The Company respects your rights in how your personal information is used and shared.  If you wish to opt-out of receiving marketing emails from us, please follow the instructions contained in each email you receive, which will allow you to “unsubscribe” from our marketing emails.  Please note, however, that we may still need to contact you regarding other matters.  

Please also feel free to contact us with any questions through the contact information provided below in the “How to Contact Us” section.

 
Your Personal Information and Your Rights – California 

If you are a California user, you have certain rights with respect to the collection, use, transfer, and processing of you “Personal Information,” as defined by the California Consumer Privacy Act (“CCPA”).  We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.  To exercise any of the rights below, please contact us via the contact information below.  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information.

What Information Do We Collect?

In the previous 12 months, the Company has collected the following categories of Personal Information:

Category: Identifiers

A 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.

Collected: Yes


Category: Personal Information

A 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. Some Personal Information included in this category may overlap with other categories.

Collected: Yes


Category: Protected Classification Characteristics Under California or Federal Law

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, genetic information (including familial genetic information).

Collected: Yes


Category: Commercial Information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected: Yes


Category: Biometric Information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No


Category: Internet or Other Similar Network Activity

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Collected: Yes


Category: Geolocation Dat.

Physical location or movements.

Collected: Yes


Category: Sensory Data

Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No


Category: Professional or Employment-Related Information

Current or past job history or performance evaluations.

Collected: No


Category: Non-Public Education Information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No


Category: Inferences Drawn of the Consumer

Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes


Categories of Personal Information are as defined in Cal. Civ. Code. § 1798.140(o)

The above examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.

The above does not relate to information collected in connection with an individual’s employment by or seeking employment from the Company.  


Sources From Which Personal Information Is Collected

We collect your Personal Information directly from you, from your interaction with the Website, and from third parties which collect the Personal Information directly from you.  


Business or Commercial Purposes for Which Personal Information Is Collected

Your Personal Information is used for the following purposes:

  • Furthering business operations and protections of business interests and security;
  • Compliance with legal obligations;
  • Direct or indirect marketing to customers;
  • Respond to your requests for services; 
  • Provide you with customer support and respond to your communications;
  • Send you transactional or administrative communications, as well as certain service-related announcements;
  • Personalize your experience on our website or mobile apps;
  • Send you information relating to other properties, services, activities, or special events that we believe may be of interest to you; and/or
  • Run website analytics to evaluate performance.


Third Parties With Whom Personal Information Is Shared

In the preceding 12 months, we have disclosed the following Personal Information about consumers for business purposes:

  • We share Personal Information in categories A (identifiers), B (personal), C (protected class), D (commercial), F (internet), G (geolocation), and K (inferences) with service providers.
  • We may share content posted on our social media platforms with other consumers (e.g., through a retweet or by sharing a consumer “comment” on a story).  Such posts may include Personal Information in categories A (identifiers) and B (personal), but the content depends on the individual post.
  • We allow certain companies to use Personal Information in categories F (internet), G (geolocation) and K (inferences) to enhance online experiences and customize advertising. 


In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.


Individual Rights

    a. Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that the Company disclose the Personal Information it collects, uses, and discloses about you to third parties.  There are two types of Rights to Know requests that you can make:

  1. Right to Know (Abbreviated Request):  If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

    1. Categories of Personal Information collected;
    2. Categories of sources from which Personal Information is collected;
    3. Business purpose for collecting; and
    4. Categories of third parties with whom shared.

  2. Right to Know (Specific Pieces of Information Request):  If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

    1. Specific pieces of Personal Information collected about you.


This information will be provided to you free of charge, unless the Company determines that your request is manifestly unfounded or excessive.  You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know.  The Company will state in its response if an exception applies. 

    b. Right of Deletion

You have the right to request that the Company and our service providers delete any Personal Information about yourself which the Company has collected from you upon receipt of a verifiable request.  This right is subject to certain exceptions.  The Company will state in its response if an exception applies.

    c. Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of your Personal Information by a business subject to certain laws and regulations.  

The Company does not and will not sell your Personal Information.  In the event that the Company intends to sell any Personal Information, we will update this Statement before selling such Personal Information.

    d. Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law.  The Company will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

    e. Submitting Requests

You may submit a request by sending us an email at marketing@thestrandtci.com.

    f. Verifying Requests

When the Company receives a request, it must verify that the person requesting information or deletion is the California consumer about whom the request relates in order to process the request.  To verify a California consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records.  We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.  

Making a verifiable consumer request does not require you to create an account with us.  

We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request.  The Company reserves the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

    g. Authorized Agents

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”).  If you choose to use an Authorized Agent, the Company requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with the Company.  Failure to do so may result in the Company denying your request. 

Contact for More Information

If you have any questions or concerns regarding your California Privacy Rights under this Privacy Policy, please feel free to send us an email at marketing@thestrandtci.com  

 

 

Last Updated:  August 10, 2020

Your Personal Information and Your Rights – Europe Only

If you are an individual in a country in the European Union, you have the right to make requests to:

  • Access the personal information we keep about you;
  • Rectify inaccurate personal information;
  • Place restrictions on our use of your personal information;
  • Object to our use of your personal information;
  • Ask us to delete the personal information about you we hold;
  • Have your personal information transferred to you or another party of your choosing; and
  • Make a complaint to the relevant supervising authority


We describe these rights more fully below.

Asking us to access your personal information

You have the right to obtain from us confirmation as to whether or not we are processing personal information about you and, if so, the right to be provided with the information contained in this Notice.  You also have the right to receive a copy of the personal information undergoing processing.

Asking us to rectify your personal information

You have the right to ask us to rectify any inaccurate personal information about you and to have incomplete personal data completed.

Asking us to restrict our use of your personal information

You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:

  • You contest the accuracy of the information that we hold about you, while we verify its accuracy;
  • We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
  • We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
  • You have objected to us using your information, while we check whether our legitimate grounds override your right to object.


Objecting to our use of your personal information

You have the right to object to our use of your personal information where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Asking us to delete your personal information

You can ask us to delete your personal information if:

  • We no longer need it for the purposes for which we collected it;
  • We have been using it with no valid legal basis;
  • We are obligated to erase it to comply with a legal obligation to which we are subject;
  • We need your consent to use the information and you withdraw consent;
  • You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.


However, this right is not absolute.  Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities.  We will retain information in accordance with the “
How Long Is Your Personal Information Kept” section below.

If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

The right to transfer your personal information to another service provider

You may request that we transfer some of the personal information you have provided to you or another service provider in electronic copy.  This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.

Making a complaint

If you have any concerns or complaints regarding our processing of your personal information, please contact us as described in the “How to Contact Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.

If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority.  The EU Commission has list of supervisory authorities here. 


Third-Party Links

The Website may contain links to third-party websites.  When the Company provides links, it does so only as a convenience and does not endorse any products or services and is not responsible for any content of any third-party website or any links contained within.  It is important to note that this Notice only applies to this Website.  We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting their website.  We also advise that you read the privacy notice of any third-party websites you choose to visit carefully.


How Long Is Your Personal Information Kept

The Company retains your personal information to the extent it is necessary for the purpose for which it was collected.  The Company will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation. 


Our Commitment to Data Security

The security of your personal information is important to us.  We take various reasonable organizational and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.  We have policies and procedures in place to ensure team members know what is expected of them in relation to personal information.  We have in place appropriate procedures for accessing our system and access it limited by role.  We have also put processes in place to address suspected breaches of your personal information.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the Internet.


Our Commitment To Children’s Privacy

Protecting the privacy of the very young is especially important.  This Website is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13.  In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information.  If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “How to Contact Us” section below.


How To Contact Us

Should you have other questions or concerns about these privacy policies, please feel free to send us an email at marketing@thestrandtci.com   


Changes to This Privacy Policy

This Notice may change from time to time. We will post any changes to the Notice on this page.        

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