Purpose and Scope
This Privacy & Data Protection Policy (the “Policy”) describes how Bravo Property Trust LLC and its affiliates (“Bravo”) collect, use, share, retain, and protect personal data in compliance with applicable United States federal and state privacy laws.
This Policy applies to personal data of investors, prospective investors, borrowers, counterparties, employees, contractors, and other individuals. It promotes responsible data governance, privacy, and compliance with data protection laws. This Policy does not apply to information that is publicly available, lawfully obtained from government records, de-identified, aggregated or otherwise exempt under applicable privacy laws.
Personal Data Collected and Approach
“Personal data” (also referred to as “personal information” under certain U.S. state laws) means information that identifies, relates to, describes, or could reasonably be linked to an individual or household. Personal Information does not include information excluded from the scope of applicable privacy laws.
Bravo may collect personal information directly from individuals, from third parties (such as data brokers, credit bureaus, public records, or business partners), and automatically through our systems and websites. The categories of personal information Bravo collects, which may vary depending on the individual’s relationship with Bravo, include:
- Identification and contact information
- Professional or business-related information
- Financial, transactional, or investment-related information
- Information provided in connection with compliance, onboarding, due diligence, or regulatory processes, including Social Security numbers, tax identification numbers, government-issued identification, and background check information
- Communications and correspondence
Bravo collects personal data reasonably related to or necessary for legitimate business purposes.
Personal data is processed where Bravo reasonably determines is lawful and appropriate, including for legitimate business interests, contractual obligations, legal compliance, or where otherwise required or appropriate.
Bravo does not use or disclose personal information for purposes materially different from those disclosed at the time of collection, except as permitted or required by law or with appropriate notice and consent where required.
SMS / Text Messaging Communications
Where Bravo communicates with individuals via SMS or text message, Bravo may collect mobile telephone numbers and related contact and consent information. Bravo uses this information to send conversational and informational messages, such as responding to inquiries and providing account, transaction, servicing, onboarding, or compliance-related notifications, and does not use SMS to send unsolicited marketing. Text messages are sent only where consent has been obtained as required by applicable law. Individuals may opt out of receiving text messages at any time by replying STOP, and may reply HELP for assistance. Message and data rates may apply, and message frequency may vary. Mobile opt-in and text message consent are not shared with third parties for marketing purposes. Bravo may share mobile information with service providers and carriers solely as necessary to deliver messaging services and as otherwise described in this Policy. Bravo’s SMS/text messaging program is governed by the SMS/Text Messaging Terms & Conditions set forth in Appendix A to this Policy.
Data Sharing, Disclosure, and Use of Service Providers
Bravo may share personal data for legitimate business purposes, subject to applicable legal requirements.
Personal data may be shared internally with authorized personnel.
Bravo may share personal data with third-party service providers, advisors, and counterparties (including administrators, legal and accounting advisors, technology providers, and other vendors) to the extent Bravo reasonably determines necessary or appropriate in connection with services or contractual and legal obligations.
Where appropriate and commercially reasonable, Bravo implements contractual and confidentiality arrangements to protect personal data shared. Bravo does not sell personal data or authorize service providers to use it for unrelated purposes, except as required or permitted by law.
Bravo may disclose personal information to regulators, governmental authorities, law enforcement, litigation counterparties, legal process, subpoena, court order, or where necessary to establish, exercise, or defend legal claims, protect rights and property, or prevent fraud or other illegal activity, or other third parties where required or permitted by law.
Employee Data and Workplace Privacy
Bravo collects employee and contractor personal data reasonably related to or necessary for employment administration, legal compliance, payroll and benefits, and business operations and security.
Bravo may monitor Bravo systems, communications, devices, and networks to the extent necessary for business, operations, security, compliance, and risk management, consistent with applicable law.
Data Retention
Bravo retains personal data as long as necessary to fulfill collection purposes, support legitimate business or operational needs, and comply with legal, regulatory, and contractual obligations. Retention periods vary based on data type, processing purpose, retention practices and policies, and legal requirements.
Data Security and Incident Response
Bravo seeks to protect personal data through reasonable administrative, technical, and physical safeguards appropriate to Bravo’s size, operations, and risk profile. These safeguards are designed to help protect personal data against unauthorized access, disclosure, alteration, or destruction.
Data security practices and controls are addressed in further detail in Bravo’s Information Security Policy. Personnel are expected to comply with applicable information security practices and to take reasonable steps to protect personal data in the course of their duties.
Suspected data security breaches or unauthorized and unlawful disclosures involving personal data must be promptly reported and addressed in accordance with Bravo’s incident response practices. Bravo seeks to respond to such incidents in a timely and appropriate manner, including taking steps to mitigate potential harm and to comply with applicable legal or regulatory requirements.
Individual Rights
Where required under applicable data protection laws, individuals whose personal data is processed by Bravo may have certain rights with respect to their personal data. Such rights may include the right to request access to, correction of, or deletion of personal data, or to object to or restrict certain processing activities.
Cross-Border Transfers
Bravo may transfer personal data internationally. Such transfers shall comply with applicable data protection requirements, including implementing appropriate safeguards where required by law.
Responsibilities and Oversight
Bravo expects all personnel to handle personal data in a manner consistent with this Policy and Bravo’s related policies, including the Code of Ethics and Information Security Policy. Personnel are responsible for understanding their obligations with respect to personal data and for raising questions or concerns where appropriate.
Senior management or designated personnel oversee privacy and data protection matters, with support from legal, compliance, and operational resources.
Amendments and Review
This Policy is reviewed periodically and may be amended by Bravo from time to time, including to reflect changes in Bravo’s business, regulatory environment, or internal practices.
Appendix A — SMS/Text Messaging Terms & Conditions
Overview
These SMS/Text Messaging Terms & Conditions (the “Terms”) govern text messages sent by or on behalf of Bravo Property Trust LLC and its affiliates (“Bravo,” “we,” “us,” or “our”). By providing your mobile telephone number and consenting to receive text messages from Bravo, you agree to these Terms. If you do not agree, do not opt in to our messaging program.
Program Description
Bravo uses SMS/text messaging to communicate with investors, prospective investors, borrowers, counterparties, and other business contacts. Messages are conversational and informational in nature and may include responses to your inquiries, account and servicing notifications, transaction and loan-related updates, onboarding and due-diligence communications, and compliance or regulatory notices. Bravo does not currently use text messaging to send unsolicited advertising or marketing.
Consent
You may receive text messages from Bravo where you have provided consent, including by initiating a conversation with us by text, or by providing express verbal or written consent (for example, during onboarding or by providing your mobile number in connection with our services). Consent to receive text messages is not a condition of receiving any product or service from Bravo.
Message Frequency
Message frequency varies and depends on your interactions and relationship with Bravo.
Costs
Message and data rates may apply, depending on your mobile carrier and plan. Bravo is not responsible for charges imposed by your carrier.
Opt-Out
You may opt out of receiving text messages by replying STOP to a message. After you reply STOP, we will send a confirmation message and will no longer send you text messages unless you opt in again. You may continue to receive communications from us through other channels.
Help
For assistance, reply HELP to any message or contact us at (212) 258-1000 or voicemail@bravocapital.com.
Privacy
Your information is handled in accordance with this Privacy & Data Protection Policy. Mobile opt-in and text message consents will not be shared with third parties for marketing purposes.
Carrier Disclaimer
Carriers are not liable for delayed or undelivered messages. Delivery of messages is subject to effective transmission by your mobile carrier and is not guaranteed.
Changes to These Terms
Bravo may modify these Terms from time to time. Changes are effective when posted or otherwise made available. Your continued participation in the messaging program after changes are made constitutes acceptance of the updated Terms.
Contact
Bravo Property Trust LLC
780 3rd Avenue
New York, NY 10017
Phone: (212) 258-1000
Email: voicemail@bravocapital.com