Privacy Policy

1. Introduction

1331 Asby LLC ("we," "our," "us," or "Company") is committed to protecting your privacy and maintaining the confidentiality of your investment and property information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage our real estate asset management and investment advisory services.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our services. Your use of our services signifies your acceptance of this Privacy Policy.

2. Information We Collect

Investment and Property Information

• Personal Contact Information: Name, email address, phone number, mailing address, and identification information
• Investment Profile: Investment objectives, risk tolerance, financial capacity, and investment preferences
• Financial Information: Bank account details, credit references, financial statements, and investment capacity verification
• Property Information: Ownership details, property valuations, lease agreements, tenant information, and management records
• Transaction Data: Investment agreements, purchase documents, sale documentation, and transaction history
• Asset Management Data: Maintenance records, repair invoices, rental income, expense tracking, and performance metrics

Information Collected Automatically

• Website Usage Data: Pages visited, time spent, click patterns, navigation preferences, and browsing behavior
• Device Information: Browser type, operating system, IP address, device identifiers, and connection type
• Cookies and Similar Technologies: We use cookies to enhance user experience, maintain sessions, and analyze website performance

3. How We Use Your Information

We use the information we collect for the following purposes:

• To manage and administer real estate assets and investment portfolios
• To provide asset management and investment advisory services
• To coordinate property maintenance, repairs, and tenant management
• To process payments, rent collection, and financial transactions
• To maintain financial records and generate investment performance reports
• To comply with legal, tax, and regulatory requirements
• To communicate regarding property status, investments, and account matters
• To analyze investment performance and identify optimization opportunities
• To improve our services and website functionality
• To prevent fraud and protect against unauthorized access
• To respond to inquiries and provide customer service
• To market our services (with appropriate consent)

4. Legal Basis for Processing (CCPA Compliance)

Under California Consumer Privacy Act (CCPA) requirements, we process your information based on:

5. Information Sharing and Disclosure

We Share Information Only In These Circumstances:

• With Service Providers: Property managers, maintenance contractors, tax advisors, and financial institutions under confidentiality agreements
• With Tenants/Occupants: Limited information necessary for property operations and management (with appropriate authorization)
• With Your Consent: To third parties you explicitly authorize us to share information with
• Legal Compliance: When required by law, court order, regulatory authority, or tax authorities
• Protection of Rights: To prevent fraud, protect safety, enforce legal agreements, or protect our business interests
• Business Transitions: In connection with merger, acquisition, or sale of company assets

We DO NOT sell your personal information to third parties.

6. Real Estate Asset Privacy

1331 Asby maintains strict confidentiality regarding your real estate assets and investment information:

• Property ownership and holding information remains confidential and private
• Investment strategies and property holdings are protected from unauthorized disclosure
• Financial performance data and asset valuations are kept confidential
• Tenant information is managed with appropriate privacy protections
• Lease terms and rental rates are treated as sensitive information
• Purchase and sale negotiations are conducted with strict confidentiality

7. Data Security

We implement comprehensive security measures to protect your sensitive asset management and financial information:

• Encryption: Data encrypted in transit (TLS 1.2+) and at rest using AES-256 encryption
• Access Controls: Information access limited to authorized personnel with legitimate business need
• Secure Systems: Bank-grade security systems for sensitive financial and property data storage
• Regular Audits: Periodic security assessments, penetration testing, and vulnerability scanning
• Employee Training: Mandatory data protection and confidentiality training for all staff
• Multi-Factor Authentication: Available for account access and sensitive operations
• Document Management: Secure handling and storage of physical and digital property documents
• Secure Destruction: Secure deletion protocols for information no longer needed

Note: While we implement robust security measures, no method is 100% secure. We cannot guarantee absolute security of information transmitted over public networks.

8. Your Privacy Rights (CCPA)

As a California resident or individual whose data is processed by us, you have the following rights:

How to Exercise Your Rights

To exercise any of these rights, contact us at the address provided in Section 10. Include "Privacy Request" in your subject line and specify which right you are exercising. Provide sufficient information to allow us to verify your identity. We will respond within 45 days and may request additional information to confirm your identity or clarify your request.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to:

• Maintain user sessions and authentication
• Remember account preferences and settings
• Analyze website traffic and usage patterns
• Improve website functionality and user experience
• Detect and prevent fraudulent activity
• Measure campaign effectiveness

Types of Cookies:

• Essential Cookies: Required for website functionality and account security
• Analytics Cookies: Help us understand how visitors use our site
• Preference Cookies: Remember user choices and preferences
• Marketing Cookies: Track advertising effectiveness (optional)

You can control cookie settings through your browser preferences. Disabling cookies may affect website functionality and your ability to access certain features.

10. Contact Information for Privacy Requests

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on this page and updating the "Last Updated" date. Your continued use of our services following such modifications constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Third-Party Links and Services

Our website may contain links to third-party websites and services. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices of other sites. We encourage you to review the privacy policies of any third-party websites or services before providing personal information or conducting business.

13. California Privacy Rights Summary

Under CCPA, California residents have specific rights regarding personal information:

14. Real Estate-Specific Privacy Considerations

1331 Asby recognizes the sensitive nature of real estate ownership and investment:

• Ownership Privacy: Your property ownership is protected and disclosed only to necessary parties
• Valuation Confidentiality: Property valuations and appraisals are kept confidential
• Financial Privacy: Rental income, expenses, and financial performance are protected
• Tenant Confidentiality: Tenant information is managed with appropriate privacy protections
• Investment Strategy: Your investment objectives and strategies remain confidential
• Transaction Privacy: Property transactions and negotiations are conducted confidentially

15. Compliance Standards

1331 Asby LLC commits to compliance with:

• California Consumer Privacy Act (CCPA): Protection of California consumer privacy rights
• California Real Estate Law: Compliance with state real estate and property management regulations
• Federal Tax Requirements: Compliance with IRS regulations for investment property reporting
• Industry Best Practices: Following established standards for data protection and privacy

16. Data Breach Notification

In the event of a data breach or unauthorized access to your information, 1331 Asby will:

• Notify affected individuals without unreasonable delay
• Provide detailed description of the breach and information involved
• Recommend steps to protect yourself from potential harm
• Comply with all California and federal data breach notification laws
• Conduct thorough investigation and implement remediation measures

17. Questions or Concerns

If you have questions about this Privacy Policy or our privacy practices, please contact us at the address provided above. We are committed to working with you to resolve any privacy concerns and maintaining your trust in our asset management services.