Privacy policy.

This Privacy Policy is effective as of November 27, 2024

This Privacy Policy (“Privacy Policy” or “Policy”) applies to the information and data that Klocke Estate Holdings, LLC (together with its subsidiaries and affiliates) collects when you visit and/or use our website, any mobile applications, (collectively “Website”), our products and services as well as information we may collect offline. We respect your privacy and understand that you have a right to know why we collect certain information about you, and what we do with it.

Summary

This Policy applies to:

  • Visitors to our Website

  • Customers

  • Users of our products and services

“Personal Information” is any information that relates to you, identifies you personally, or could be used to identify you. The purpose of this Privacy Policy is to let you know how we collect, use, store, share, retain, transfer and process your Personal Information.  This Policy also describes your choices and rights with respect to your Personal Information and how to exercise those rights.

We may amend this Policy from time to time. We encourage you to review this Policy periodically, as changes will be posted on this page. If we make any material changes to this Policy we will provide a prominent notice. If you do not agree with this Policy, you should not use our Website, products or services.
 

What Personal Information We Collect

We collect various types of information depending on how you interact with us and what products or services you use. Among the types of Personal Information that our Website collects, by itself or through third parties: Usage Data; Tracker; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); billing address, shipping address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy.

 

Personal Information you provide to us

If you fill out a form on our Website that requires contact information such as signing up for a newsletter, submitting a request for information or products and services, we will collect and process that information to provide you with the communication, products or services.  These types of Personal Information may include your name, email address, age and/or birthdate, company name, job title, your physical address, payment and billing information.

 

Personal Information collected when you visit our Website

When you use our Website, we may automatically collect Personal Information such as IP address, user - agent information (which is automatically sent by your web browser and may include device type) and information collected by cookies and other similar technologies.  Our Cookie Policy contains further information.

 

Personal Information collected when you use our products or services

When you use our products and services, we collect other types of Personal Information.  These types of Personal Information may include:

  • Username

  • IP Address

  • Name

  • Email address

  • Street Address

  • Telephone Number

  • Age and or birthdate

  • Gender

We may also collect usage data regarding your use of our products and services and this data may contain Personal Information.  We also collect payment and billing information when you register for the use of our products and services.  For example, we may ask you to provide a billing address for your account and payment information.  We use this information solely to process payments and deliver our products and services. Unless otherwise noted in this Policy, we act as the “controller” of personal data that we collect and process.

How We Collect Information

We collect Personal Information from you when you visit our Website or use our products and services.  Some of this information is provided by you and some is collected automatically.  We collect Personal Information in the following ways:

Information We Automatically Collect. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with our Website. We may collect the following types of information automatically from you:

  • Usage Data. When you browse our Website, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data. 

  • Device Information. When you use your desktop or mobile devices to access our Website, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID

  • Location Information. When you use our Website, we may infer the generic physical location and geographic regions of your device from your WiFi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

  • Aggregate and Analytic Data. We may also combine the information we collect among our products and services and across your devices for analytic, security and fraud prevention purposes. For example, we use algorithms that analyze your account status and payment information to detect the unsafe and unsecured payment. We may also use analytic data to assess your account security and provide you suggestion for improvement.

We may collect Personal Information from other sources, such as: 

Information We Collect from Third Parties. From time to time, we may obtain information about you from third party sources as required or permitted by law. These sources may include:

  • Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the third-party website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on our services and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

 

How We Use Your Information 

We process your Personal Information for the following purposes: 

  • Provide Services. To provide our services that you request, including managing your request as a registered user of our Website and any applications and ask for information. 

  • Respond to Requests for Information. To respond to your requests for information.

  • Maintain Legal Compliance. To the extent certain laws and regulations impact our services which may require us to process your Personal Information to fulfill our business obligations, fulfill contractual obligations, and to manage risk as required under applicable law.

  • Enforce Compliance with Applicable Law. Subject to applicable law, we may process your Personal Information to investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners. 

  • Fraud Prevention. We may process your Personal Information to help monitor, prevent and detect fraud and abusive use of our Service, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities or other security risks that might result in financial loss.

  • To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your Personal Information, we cannot respond to you or ensure your continued use and enjoyment of our services.

  • Service-Related Communications. To contact you with updates about our services.

  • To analyze and improve our Website and services.

  • To Provide Marketing Communication (e.g., SMS, Email) and Advertise Our Services. We may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you choose to participate in our promoting activities or subscribe for marketing communications. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages. We may also collect and use your mobile advertising identifiers for the purpose of marketing campaigns. Please see our Cookies and Other Tracking Technologies section for more information.

Targeted Advertising and Remarketing. You may see advertisements for our products/services on other websites and mobile applications because we work with third party advertisers to engage in remarketing and retargeting activities. Through our relationships with these advertisers, we can target messaging to our users by interest-based, demographic, contextual, and other means. These third-party advertisers track your online activities over time and across websites and mobile applications by collecting information through automated means, including through the use of third-party cookies, web server logs, and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites and mobile applications that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites or apps. This data collection takes place both on our Website and on third-party websites and mobile applications that participate in the advertising networks. This process also helps us track the effectiveness of our marketing efforts. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies (www.networkadvertising.org). You may also opt-out of targeted advertising by clicking here.

  • To Research and Develop Our Services. We may process your Personal Information and derive analytical and statistical data to better understand the way you use and interact with our services. For instance, analyzing where, on which types of devices and how our Website is used, how many visitors we receive, and where they click on the Website may help us improve our existing services and to build new services. Please see our Cookies and Other Tracking Technologies section for more information.

  • To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to interact with our services more easily across platforms and devices. We also use it to remember you in case you re-visit our site, so we will know if you have already been served with surveys, or (where Website content is undergoing testing) which version of the content you were served. Please see our Cookies and Other Tracking Technologies section for more information.

  • With Your Consent. For any other purpose disclosed to you prior to you providing us your Personal Information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction. 

We may also aggregate or deidentify any Personal Information that we collect in connection with our services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated or de-identified information for our own business purposes without restriction.

 

How We Share Information

We share Personal Information with our affiliates and partners, as needed to provide our services. We share Personal Information with service providers such as accountants, payment processing companies, and other vendors we use to operate our website and provide our products and services. 

Our vendors and service providers are not permitted to use your Personal Information for any other purpose than to provide contracted services. Vendors are not permitted to use your Personal Information for their own marketing, and are not allowed to share your information for marketing purposes.

To the extent required by applicable law, we may share Personal Information in response to a legal summons or subpoena, or if required by law enforcement agencies.

 

How Long We Retain Your Information

How long we keep Personal Information that we have collected depends on the type of information and the purpose for which it was collected.  After a reasonable period of time or the completion of the purpose for which it was collected, we will either delete or anonymize Personal Information.

We retain your Personal information for as long as it is needed to provide our services to you and where we have an ongoing legitimate business purpose to do so (i.e., to fulfill any legal obligations and for a reasonable period of time after such services are completed).

 

Cookies and Other Tracking Technologies

Cookies are small files stored on your web browser when you visit our Website. Some cookies last only as long as you remain on our Website; others, called “persistent cookies” may be stored for longer periods of time. These cookies can make browsing easier by storing your preferences regarding how you use our Website. Cookies collect information such as the IP address of your computer, your browser settings, and information about how you use our Website. Your general location may be estimated from your IP address. Some cookies track users’ activity on our Website, and services in order to deliver personalized advertising to you on this and other websites.

If you would like to opt out of cookies, you may change the settings on your web browser to reject or delete cookies. You may also find more information about cookies, including how to opt out of interest-based advertising, at www.cookiesandyou.com.

More information about how we use cookies may be found in our Cookie Policy.

Your Rights Regarding Access to and Control over Personal Information

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your Personal Information. If any of the rights listed below are not provided to you under the law that governs the processing of your Personal Information, we have absolute discretion in providing you with those rights. 

Your rights in relation to your Personal Information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

 

  1. Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the Personal Information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information. 

  2. Right to Correct. You may have the right to correct any of your Personal Information in our records and systems. You may request us to rectify, correct or update any of your Personal Information held by us that is inaccurate. 

  3. Right to Delete. Under certain circumstances, you may have the right to request that we delete the Personal Information that we hold about you. This right is not absolute, and we may refuse your right to delete if it is reasonably necessary for us to provide a service requested by you; to perform a contract between us; to maintain functionality and ensure security of our systems; to enable solely expected internal uses of your Personal Information; to exercise a right provided by law; or to comply with a legal obligation.

  4. Right to Portability. Under certain circumstances, you may have the right to receive Personal Information we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal information to another entity.

  5. Right to Opt Out of Sale. You may have the right to opt-out of sale of your Personal Information. We generally do not sell your Personal Information for profit, but like many websites, we use cookies, pixels, and similar technology, and we share personal information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under the broad definition of “sell” contained in certain jurisdictions’ privacy laws, this could be considered a sale. 

  6. Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of the sharing of your Personal Information for behavioral advertising purposes. Like many websites, we use cookies, pixels, and similar technology, and we share certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. You have the right to direct us not to share or use your personal information for targeted advertising purposes. 

  7. Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your privacy rights.

  8. Right to Limit Use of Sensitive Information. If you are a California resident, to the extent applicable, if your sensitive Personal Information (as that term is defined under California privacy law) is used to infer characteristic about you, you have the right to direct us to stop such processing of your sensitive Personal Information for such purposes. We do not process any sensitive Personal Information to infer characteristics about you without your consent.

  9. Right to Object to Automated Decision-Making. You may have the right not to be subject to a decision that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement) which significantly impacts your rights. No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

  10. Right to Appeal.  In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.

  11. Shine the Light. If you are a California resident, to the extent applicable, you may have the right to ask us for a notice describing what, if any, categories of Personal Information we share with third parties or affiliates for those third parties’ or affiliates’ direct marketing purposes. That notice will identify the categories of Personal Information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such Personal Information.

 

Information for California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA) applies to information collected from California residents. Residents of California have the following rights with regard to their Personal Information: 

  • The Right to Know and Access Information

            The categories of Personal Information we collect is described above in the section entitled “What Information We Collect”. To the extent applicable, California residents may submit a verifiable request regarding the information collected, the types of sources from which Personal Information is collected, the purposes for which information is collected, and the specific Personal Information collected about them.

  • The Right to Have Personal Information Deleted

  • The Right To Portability

  • To the extent applicable, California residents may request a copy of their Personal Information in a format that can be transferred to another person or entity.

  • The Right to Non-Discrimination.  We will not discriminate against you if you exercise your privacy rights. 

You may be asked for more information in order for us to verify your identity when you make a request. You may exercise your rights by contacting us at info@klocke-estate.com.

 

Categories of Personal Information Collected, Used, and Disclosed

In the preceding 12 months, depending how you interact with our services, we may have collect the following categories of Personal Information (as defined under Cal. Civ. Code  §1798.140(v)(1)):

  • Identifiers, such as your name, shipping and billing address, unique personal identifier, email, phone number

  • Characteristics protected under state and federal law, such as your age, gender and other demographic information.

  • Commercial information, such as your purchase history, transaction records, payment information, wish list, customer appreciation program participation, 

  • Internet or other electronic network activity information, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including your browsing history, search history, the webpage visited before you came to our Website, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, and system configuration information.

  • Geolocation data, such as geolocation, to the extent you have configured your device to permit us to collect such information.

  • Inferences drawn from any of the information listed above, such as your shopping preferences, characteristics, and behavior.

For more information about the Personal Information we collect and how we collect it, please refer to the sections above, “What Personal Information We Collect” lists the categories of Personal Information we have collected in the preceding 12 months.

For more information about the business purposes for which we collect your personal information, please refer to Section 3 above, “How We Use Your Personal Information.” 

To learn the categories of third parties with whom we may share your Personal Information, please refer to the section above, “How We Share Information.”  For more information on how long we retain information refer to the “How Long We Retain Your Information” section.

 

Do Not Sell or Share My Information

We use technologies, such as cookies, that gather information on our Website. That information is used for a variety of purposes such as to understand how visitors interact with our Website, or to serve advertisements on our Website or on other websites. The use of technologies, such as cookies, may constitute a “sale” of personal information under the CCPA. In addition, we may use your personal information in a way that may constitute “sharing” under the CCPA.  You can opt out of the “sale” or “sharing” by clicking on the “Do Not Sell or Share  My Personal Information” link at the bottom of our Website and selecting your preferences below, or broadcasting the global privacy control signal. Note that due to technological limitations, if you visit our Website from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences and/or rebroadcast the signal.

Your Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia Rights 

If you are located in Colorado, Connecticut, Montana, Oregon, Texas, Utah and Virginia, you may have certain applicable rights regarding your Personal Information. The section describes how we collect, use, and share your Personal Data under the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“PDPOM”), the Montana Consumer Data Privacy Act (“MCDPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy Act (“TDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”), and any applicable rights with respect to that Personal Information.  

As a Colorado, Connecticut, Montana, Oregon, Texas, Utah or Virginia resident, you may have some or all of the rights listed below based on applicable law. However, these rights are not absolute, and we may decline your request as permitted by law. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

  • Right to Access and Portability. You have right to access your Personal Information and/or receive a copy of the Personal Information that we have collected about you.

  • Right to Correct. You have the right to correct inaccurate Personal Information that we have collected about you.

  • Right to Delete. You have the right to delete the Personal Information we have obtained about you or that you have provided to us with certain exceptions.

  • Right to Opt-out of Tracking for Targeted Advertising Purposes. You have the right to opt-out of certain tracking activities for targeted advertising purposes.

  • Right to Opt-out of Profiling. If we process your Personal Information for profiling purposes as defined by the CPA, PDPOM, MCDPA, OCPA, TDPA, UCPA, and VCDPA, you can opt-out of such processing.

  • Right to Non-discrimination. You have the right to be free from discrimination as prohibited by the CPA, PDPOM, MCDPA, OCPA, TDPA, UCPA, and VCDPA.

 

Information for International Residents Outside the United States

If you reside in the EU/EEA, you may have the following rights with regard to your Personal Information:

  • Right of information and access - You have the right to access your Personal Information we have about you and to be provided with a copy of your Personal Information.

  • Right to rectification - You have the right to correct or update your inaccurate or out of date Personal Information.

  • Right of erasure - You have the right to request that your Personal Information be permanently erased/deleted.

  • Right to restrict processing - You have the right to restrict the processing of your Personal Information.

  • Right to object to processing - You have the right to object to specific types of processing of your Personal Information.

  • Right to portability - You may ask to receive a portable copy of your personal information in a format that may be transferred to another organization.

  • Right not to be subject to decisions based solely on Automated Decision Making - You have the right not to be subject to decisions based solely on automated processing.

  • Right to complain to a data protection authority - You have the right to complain to a supervisory authority in the country in which you reside, details of which can be provided upon request.

  • Right to withdraw consent - If you have given us consent to collect or process your Personal Information, you may withdraw that consent at any time.

  • The Right to Non-Discrimination - We may not discriminate against you if you exercise your privacy rights.

We may charge a reasonable fee if your request is not valid under applicable law, repetitive or excessive.  We may also request additional information from you in order to verify your identity before processing your request.

 

Security

We take all reasonable steps to protect the information we receive from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, but no security measures are perfect; the risk of a data breach is possible.

 

Children’s Privacy

We do not knowingly collect or solicit Personal Information from children under age 13 without parental consent, unless permitted by law.  If we become aware that we have collected Personal Information from children under the age of 13 without parental consent (or as permitted by law), we will delete it.  If you believe that a child may have provided us with Personal Information without such parental consent, please contact us.

California consumers:  We will not sell the information of California consumers who are 16 years old or younger unless we have prior parental authorization. 

EU residents: We do not collect or process Personal Information of data subjects in the EU under the age of 16 without explicit consent from a parent or guardian.

 

Sensitive Information

Unless specifically requested and/or required by law, we ask that you not send us, and you not disclose on or through our Website or otherwise to us sensitive Personal Information. 

 

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@klocke-estate.com