Requests for Information.  When you request additional information related to our products, services or properties, we will request your name and contact information such as street address, telephone number and email address.  Please note that our ability to respond to online requests may depend on the legal requirements of the state in which you reside.

We may ask you to give us contact and demographic information when you register (“Personal Information”). We use Personal Information to send to this Site’s users like you information about this Site or the products and services we and our subsidiaries and affiliates offer.  We may use Personal Information to contact you both online and offline when needed; to respond to your requests for information, products, properties or services; to administer your account if you register online; or for legal compliance, such as enforcing our rights.

Contacting Us.  When you send us an email from one of our online services with comments or questions, we may retain information such as the content, your email address, our response and the text of any follow-up questions you may have. This information may also be used to measure how effectively we are able to address customer concerns, to personalize your experience and to improve our products and services.

Online Surveys.  From time to time, we may conduct online surveys to better understand the effectiveness of our websites or our performance in providing services. Your participation in these surveys is voluntary. Information collected by us when you participate in a survey may include name, telephone, street address and email address.

Employment.  If you choose to apply for employment online or to be notified of future employment openings, you will be required to provide your name, street address, telephone number, email address and certain other additional information. You will also have the opportunity to input and/or attach your resume and samples of your work. We may have a separate privacy notice for job applicants and its employees as required under applicable law.

Investor Relations.  You may be offered an opportunity to subscribe to our investor relations email alert service to learn when new investor information including earnings releases, financial reports and SEC filings have been added to our website. If you subscribe, we will require your email address. If available you may request investor information mailed to you, in which case we will ask that you provide your name, street address, email address, phone number and fax number (if any).

We may also collect information that does not identify you (“Other Information”), such as the date and time of website session, movements across this Site, and information about your browser. We do not tie Other Information to Personal Information. This Other Information may be used and stored by the Company or its agents. Other Information we collect may include your IP Address (a number used to identify your computer on the Internet) and other information gathered through our weblogs, cookies or by other means (see below). We use Other Information to administer and update this Site and for other business purposes. The Company reserves the right to maintain, update, disclose or otherwise use Other Information, without limitation.

This Site may use a technology known as web beacons (sometimes called single-pixel gifs) that allow this Site to collect web log information. A web beacon is a graphic on a web page or in an e-mail message designed to track pages viewed or messages opened. Web log information is gathered when you visit this Site by the computer that hosts this Site (called a “webserver”). The webserver automatically recognizes some non-personal information, such as the date and time you visited this Site, the pages you visited, the website you came from, the type of browser you are using (e.g., Internet Explorer), the type of operating system you are using (e.g., Windows 10), and the domain name and address of your Internet service provider (e.g., Comcast). We may also include web beacons in promotional e-mail messages in order to determine whether messages have been opened.

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. Instead, we collect, use, and share information as described in this Privacy Notice regardless of a “do not track” choice.

This Site may use a technology called a “cookie.” A cookie is a piece of information that our webserver sends to your computer (actually to your browser file) when you access a site. When you return to this Site, our webserver will detect whether you have one of our cookies on your computer. Our cookies help provide additional functionality to this Site and help us analyze Site-usage more accurately. For instance, our Site may set a cookie on your browser that keeps you from needing to remember and then enter a password more than once during a visit to this Site. With most Internet browsers or other software, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. Please refer to your browser instructions to learn more about these functions. If you reject cookies, functionality of this Site may be limited, and you may not be able to take advantage of many of this Site’s features.

We use three types of Cookies on our website.

1. Essential Cookies – These Cookies enable you to use our website. They are essential to enable you to browse our website. If you disable these essential Cookies, that may prevent you from using parts of our website. These Cookies also help us keep our website safe and secure.
2. Temporary Cookies – We also use temporary cookies for authentication and for active session information that expires once your user session terminates. The expiring session cookie is used to connect your browser’s session with other information that is saved on our server throughout that browser section.
3. Preference, Persistent and Analytics Cookies – These Cookies store information about you. Without these Cookies, our website may not be able to remember certain choices that you have previously made or personalize your browsing experience. These Cookies can also be used to recognize your device so that you do not have to provide us with the same information more than once. These long-term cookies are saved on your browser to allow the websites to recognize you as the same visitor on your return visits. [We use cookies from Sitecore Analytics and Google Analytics.]

This Site also collects and uses Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that the IP address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP address doesn’t change (it is “static”) and could be associated with your personal computer. We do use your IP address for aggregate information on use and to help improve this Site.

Information we collect from Third Parties

We may supplement, improve and/or enhance personally identifiable information that we collect from you with other information that we obtain from third parties and our affiliates. In addition, we may obtain information about individuals who are not yet our customers or users of our websites. Moreover, when we associate information that we obtain from third parties or affiliates with personal information that we have collected under this Privacy Notice, we will treat the acquired information the same as the information that we collected ourselves, and, except as permitted by this Privacy Notice, we will not share the information with third parties.

How We Use and Share your Information

1. We may share your information with our affiliates
   We may share your information, in whole or in part, with our affiliates, i.e. the companies that are controlled by the Company, in order to send you promotional materials about our products and services.
2. We may share your information with third party service providers
   We may share your information, in whole or in part, with the following third party service providers: (i) companies that provide marketing and sales services on our behalf, (ii) companies that process and service your accounts, (iii) companies that help us protect and secure your information and the confidentiality of our records and (iv) other companies with whom we have a business relationship. Occasionally, we may partner with other companies to provide co-sponsored or co-branded promotions, products and services and may share your information with our co-sponsor. For example, we may co-sponsor a sweepstakes on our site with other companies, or we may provide prizes for sweepstakes sponsored by other companies. If you enter one of these sweepstakes, we may share your information with the co-sponsor or third party sponsor. All of these third party service providers have contractual obligations with us to maintain the confidentiality of your information. Additionally, these third party service providers are only permitted to use your information for the purposes specified by the sweepstakes or promotion as specified by us or our affiliates, or as allowed by law.
3. We may disclose your information to non-affiliated third parties
   We may disclose your information, in whole or in part, to the following types of non-affiliated third parties: (i) companies with whom we have joint marketing agreements; (ii) non-financial organizations, such as direct marketing companies and consumer reporting agencies, (iii) financial service providers, such as companies engaged in banking, credit card business and consumer finance, and (iv) others, such as non-profit organizations and third parties with whom we have a business relationship.
4. Other circumstances in which we may share your information
   We may share your information when you specifically request it or give us permission to do so. We may also share your information when we suspect criminal or fraudulent activity, and when we are required by law such as when we receive a subpoena or a court order. We may also share your information in the event that we sell a particular line of business or function.

We may amend this privacy policy from time to time.

To the extent that the Company is subject to the laws of the European Union when processing personal data (“Personal Data”), it shall be deemed a “data controller” under such laws.

Legal Basis for Data Processing. We collect Personal Data as described above and process it for the purposes set out in this Privacy Notice. Our legal basis to process Personal Data includes processing that is:

1. Necessary for our performance of our services to you (for example, to provide you with notices regarding the accommodations you purchase, or to resolve billing or customer service inquiries);
2. Necessary to comply with legal requirements (for example, to comply with applicable accounting rules or make mandatory disclosures to law enforcement);
3. Necessary for our legitimate interests (for example, to manage our relationship with you and to improve the website and any other services);
4. Necessary to protect the vital interests of you and another person (for example, if we connect Sensitive Personal Information from you to provide you with special accommodations);
5. When legally required, and we have no other valid legal basis to process Personal Data, we will use consent by our customers (for example, to provide you with marketing information or share information with third parties), which may subsequently be withdrawn by you at any time, by submitting that request via our secure contact form found on our website (without affecting the lawfulness of processing based on consent before its withdrawal.)

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you with all of our services, or for you to use all of the features of our website.

Data Retention. We will retain Personal Data for only so long as is reasonably necessary for the purposes we have described above, considering the criteria such as applicable rules on statutes of limitations and other legal requirements of the various jurisdictions that govern the Company, and the duration of your use of our website and other services, if applicable.

International Transfers of Personal Data. The nature of our business means that Personal Data that we collect through our website or otherwise through our services, from individuals in the EU, may be transferred to the United States. Our goal is to ensure that recipients of your Personal Data are bound to duties of confidentiality, and we seek to implement measures to ensure that any transferred Personal Data, remains protected and secure.

Your Rights. You may be entitled to exercise the right to:

1. Object to the processing of your Personal Data (for instance, where the basis of our processing is our legitimate interests, see section above for “Legal Basis for Data Processing”)
2. Request to restrict the processing of your Personal Data
3. Request that we update your Personal Data, if you believe that it is not accurate, or is incomplete
4. Request access to your Personal Data, if you want to retrieve a copy of it, or to receive confirmation from us that we are processing your information, and how You may request access to your Personal Data, but we cannot provide you with information relating to others that you did not provide to us, or information from others who have not consented to our disclosing their information to you, or
5. Request erasure of your Personal Data to the extent possible. We cannot erase certain data, for example, if we must retain it for legal purposes.

Requests to Exercise Your Rights. To exercise any of your rights, contact us using the information above. When we receive a request from you to exercise one of the rights enumerated above, we will indicate the Personal Data that we need from you to validate your identity, and provide you with information on what actions, if any, we intend to take on your request. We will respond to your request as quickly as possible, but no later than 30 days after we receive your request. In certain circumstances, we might have to extend the time by an additional two months, if your request is a complex one. If you consider that our processing of your data infringes upon applicable law, you may submit a complaint to a supervisory authority as provided in the applicable laws.

Categories of personal information we collect.
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household (“personal information”). In particular, we have collected one or more data types from the following categories of personal information from consumers within the twelve (12) months preceding the effective date of this Privacy Notice:

Category Collected

1. Identifiers such as 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.
   Yes
2. Any categories of personal information described in Cal. Civ. Code § 1798.80(e), such as 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.
   Yes
3. Characteristics of protected classifications under California or federal law.
   Yes
4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
   Yes
5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
   Yes
6. Internet Provider geolocation data.
   Yes
7. Audio, electronic, visual, thermal, olfactory, or similar information.
   Yes
8. Professional or employment-related information.
   Yes
9. Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
   Yes

For additional information, see The Types of Information We Collect.

Categories of sources of personal information

We obtain the categories of personal information listed above from the following categories of sources:

• The consumer.
• Third-party data providers.

For additional information, see The Types of Information We Collect.

Our business and commercial purposes for collecting personal information

We use the personal information we collect for our operational purposes or other purposes set out in this Privacy Notice (see How We Use and Share Your Information). Those purposes may include:

1. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing for legal or other compliance purposes.
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
3. Debugging to identify and repair errors that impair existing intended functionality.
4. Short-term, transient use, provided the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
5. Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
6. Undertaking internal research for technological development and demonstration.
7. Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
8. Performing marketing activities and data analysis.
9. Servicing guest or owner accounts.
10. Performing background or credit checks.
11. Communicating with consumers regarding any of the above.

In the twelve (12) months preceding the effective date of this Privacy Notice, we have disclosed the following categories of personal information of California consumers for a business purpose:

Category Third Parties Disclosed to

Identifiers

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Any categories of personal information described in Cal. Civ. Code § 1798.80(e)

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Characteristics of protected classifications under California or federal law.

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Commercial information

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Internet or other electronic network activity information

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Geolocation data

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

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

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

Professional or employment-related information.

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

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

• Vendors that provide services to us
• Business partners
• Financial institutions
• Professional-services entities (such as auditors or legal counsel)

We also use the personal information we collect for our own commercial or economic purposes, such as attracting consumers to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

For more information on where we share personal information, see How We Use and Share Your Information.

Your rights under California law

• You have the right to ask us to send you the following information:
  1. The categories of personal information we have collected about you.
  2. The categories of sources from which we collected the personal information.
  3. Our business or commercial purpose for collecting personal information.
  4. The categories of third parties with whom we share personal information.
  5. The specific pieces of personal information the business has collected about you.
• You have the right to ask us to delete the personal information about you we have collected.

Non-discrimination

Your privacy rights are important. If you exercise your privacy rights under California law, we will not do any of the following in retaliation:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through the use of discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How California residents can submit requests

If you are a California resident and you want to submit a request to us regarding your California rights, you can contact us at info@bbxcapital.com or call us at 954-940-4000. You do not have to create an account with us to submit a request.

We can only respond to your request if it is verifiable. In order to verify your identity, we need the following information from you when you submit your request:

• Name
• Address
• Phone Number

We will match that information against information you have previously provided us as part of the verification process. We may ask you to provide additional information that will help us verify your identity. We will only use that additional information in the verification process or for security or fraud-prevention purposes, and not for any other purpose.

You may also submit a request through an authorized agent. But before we can process that request, we may require one of the following:

• A copy of your signed permission authorizing the agent to make the request;
• That you verify your identity directly with us, as described above; or
• Direct confirmation that you provided the agent permission to submit the request

If your authorized agent has a valid power of attorney under California Probate Code sections 4000 to 4465, we may request proof of the power of attorney instead of the foregoing.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

California Shine the Light Requests

Effective January 1, 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at:

BBX Capital, Inc.
Attention: Director of Operations
201 East Las Olas Boulevard Suite 1900
Fort Lauderdale, FL 33301

Please indicate that you are making a “Shine the Light” request.