This webpage sets out when and how we use your personal information that you or others provide to us.
We are Brick Capital Club, LLC, a Florida Limited Liability Company (“The Bricks”).
Our registered address is 12800 US Highway 1, Juno Beach, Florida 33408
When we mention “The Bricks”, “we”, “us” or “our” in the privacy notice, we are referring to the relevant company in our group responsible for handling your personal information, Brick Capital Club, LLC. The Bricks is the controller and responsible for this website.
The Bricks is managed by Brick Capital Management, LLC, residing at the same registered address.
When you become a member
When you become a member of The Bricks, we will use your personal information to process your membership application and provide you with your membership information and benefits. The details we collect from you when you become a member include your name, e-mail, phone number, address, age, past professional experiences, investing experience, financial background, SSN/EIN information, payment information, and any current or critical criminal investigations, orders, findings, judgements, convictions, class actions filed or claimed against you.
We have a legal obligation to process your personal information in this way to register you as a member, render you eligible as an accredited club member and provide the ongoing membership services and benefits to you.
To complete your membership application, we share your personal information with our subcontractors who are involved in the membership application process, such as payment providers, as well as credit reference agencies who we use to assess fraud, credit and/or security risks.
When you attend one of our events
When you attend one of our events (such as a ‘Meet the Portfolio’, ‘Drop-ins’, or ‘Workshops’) we will collect the following information from you: name, address, email address and phone number. If you are already a member and register to attend an event, we will use the membership details we already hold on file for you to confirm your booking.
When you Opt-In for an investment opportunity (“Opportunity”)
When you opt-in to invest in an Opportunity, we will use your personal information to complete your investment subscription. The details we collect from you will include your name, address, email address, phone number, payment details, and the agreed investment amount.
In order to proceed with your investment subscription, we share your personal information with our subcontractors who are involved in the purchase process, such as payment providers, as well as credit reference agencies who we use to assess fraud, credit and/or security risks.
When you contact us by phone or email
When you phone us or contact us by email with general queries, we may also handle your personal information (your name, contact details and the other details you provide to us) in order to provide the services you have asked us to. This could be when you ask us to provide more information about an Opportunity, or explain how our your membership or online member dashboard works.
We rely on your consent to handle your personal information in this way. If you do not provide us with the personal information we request from you for membership services purposes, we may not be able to fully answer your queries.
When you have expressed an interest in a Bricks Club Membership
This section applies if you have opted in to receive marketing communications from us by submitting the ‘Contact Us’ form on our website, or have previously expressed an interest in The Bricks and not opted out.
We will handle your personal information (such as your name, email address, postal address, telephone number) to provide you with marketing communications in line with any preferences you have told us about.
When we send you marketing emails because you have opted-in to receive them, we rely on your consent to contact you for marketing purposes.
If you have not opted-in and we send you marketing emails, we do this because of our legitimate interest to promote the success of The Bricks, its members, and portfolio companies.
Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them.
You are not under any obligation to provide us with your personal data for marketing purposes.
You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at Compliance@brickcapital.co or, where relevant, by following the unsubscribe link shown in every marketing communication you receive from us.
To make our site better:
We will also use your personal information to provide you with a more effective user experience (such as by displaying an investment Opportunity, events, or news articles we think you will be interested in).
Our use of your information in this way means that your experience of our site will be more tailored to you.
We will also use your personal information for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our site is kept secure.
You can prevent us from using your personal information in this way by using the 'do not track' functionality in your internet browser. If you enable do not track functionality, our site may be less tailored to your needs and preferences.
If our business is sold:
We will transfer your personal information to a third party:
We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
In some circumstances we may also need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation.
Information we collect about you: When you visit our site we may automatically collect the following information:
Information we receive from other sources: We are also working closely with analytics providers, hosting providers and search information providers from whom we may also receive general aggregated anonymous information about you.
We will combine the information you provide to us with information we collect about you.
Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.
| Cookie | Purpose |
|---|---|
| RememberMe | This cookie stores your session in your browser, so that you can continue your session after it times out. |
| Antiforgery | This cookie prevents cross-website request forgery attacks, to prevent fraudulent hijacking of user sessions. |
| Application Insights | This cookie detects and tracks application performance issues |
Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We (and many of our external third parties) are based outside the European Economic Area (EEA) so their processing of personal information belonging to those of you who reside in the EEA will involve a transfer of data outside of the EEA.
Whenever we transfer your personal information outside of the EEA, we ensure it is protected by use of data encryption and secure connection via SSL to our data storage provider, Microsoft Azure. We further make sure at least one of the following safeguards is in place:
To keep this privacy policy as short and easy to understand as possible, we have not set out the specific circumstances when each of these protection measures are used. You can contact us at Compliance@brickcapital.co for the details as to how we protect specific transfer of your data.
Where you are a member of The Bricks we will retain your data for a minimum period of seven years, to ensure that we are able to assist you should you have any questions, feedback or issues in connection with your membership or if any legal issues arise.
Where we have used your personal information to contact you for marketing communications, if you have opted-in;
If you tell us that you no longer wish to receive marketing communications from us, we promise to stop sending them to you.
In some circumstances (such as marketing materials or press releases) we may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You have the right to object to us handling your personal information when:
You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email at Compliance@brickcapital.co.
Right of access
You are entitled receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information.
You also have the right to access your personal information which we are handling.
Right to rectification
You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.
Right to restriction
You can restrict our processing of your personal information where:
Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims.
Right to data portability
You have the right to receive your personal information in a structured, standard machine readable format and to send this to another organisation controlling your personal information.
This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.
Right to erasure
You have the right to require us to erase your personal information which we are handling in the following circumstances:
Right to complain
You have the right to lodge a complaint with your respective regional Data Protection and Supervisory Authority.
Our site may, from time to time, contain links to and from the websites of our partner networks, affiliates, or portfolio companies.
Our site connects you to different websites. If you follow a link to any of these websites or use our services, please note that you have left our site and these websites have their own privacy policies.
We do not accept any responsibility or liability for these policies or websites. Please check their policies before you submit any personal information to these websites.
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or post.
Please check back frequently to see any updates or changes to our privacy policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Compliance@brickcapital.co.
This privacy policy was last updated on July 27th, 2018.