Last Updated: November 17th, 2023

This Privacy Policy describes how JB Matteson, Inc., Matteson Management Services, Inc. and its affiliates (collectively, “JB Matteson”, “we”, “us”, or “our”) collects, uses, stores and discloses personal information if you visit jbmatteson.com, engage with our representatives over the phone or in our office, invest in any property or other investment entity managed by us, contact us, receive our communications, attend our events or otherwise engage with us in a business to business capacity. 

This Privacy Policy also describes how, while a “business” under the California Consumer Privacy Act (“CCPA”), we otherwise collect, use and disclose personal information about California residents who engage with us. It also describes how we have collected, used, stored and disclosed such information for the past 12 months.

By visiting this website made available by JB Matteson (the “Site”), you agree to be bound to the terms and conditions of this Privacy Policy, which may be updated by us at any time. Your continued engagement with the Site or our services to which this Privacy Policy applies after any revisions indicates that you accept and consent to them. If you do not agree, please do not use or access the Site or our services.

Personal Information We Collect

We only collect, use, store and disclose your personal information where we have a lawful basis to do so. We, including parties acting on our behalf or our affiliates behalf (such as our service providers), collect, use and disclose (for the purposes described below) several types of personal information, including:

  • Identifiers. We collect contact information, such as name, email, address, phone number and title, if you or your representative provide us with this information in connection with prospective services or if you work with us as a service provider or vendor to our business. We also collect contact information from those who register for or attend our sponsored events. We use this information to communicate with such persons and conduct our business relationships.

  • Information Collected Through Technology. We collect information you voluntarily provide us by email, by webform on the Site and any other electronic transmissions. We also collect information automatically on the Site through the use of cookies. When you visit websites, they may store or retrieve data in your browser. This storage is often necessary for the basic functionality of the website. The storage may be used for marketing, analytics, and personalization of the site, such as storing your preferences. You have the option of disabling certain types of storage that may not be necessary for the basic functioning of the website. For those who engage with us as an investor, we, or our service provider, collect your online identifiers, such as your username and password, to access restricted investor portals accessible from our Site.

  • Commercial Information. We may collect information needed for our operations, such as bank account information to process vendor invoices and payments, transaction history and signatures, as further described below.

  • Professional and Education Information. We may collect information needed for our operations, such as background or educational information, references, emergency contact information, information to identify conflicts of interest and similar information as needed to comply with our policies and procedures.

  • Other Electronic Network Activity Information. We maintain various security measures to protect our technology infrastructure. We monitor those who connect to our guest internet network or otherwise interact with our in-office technology infrastructure, such as by collecting browsing history, IP address or other unique identifier and information about the devices connected to our network.

  • Audio and Visual Information. We collect audio and visual recordings of our hosted events to support our marketing efforts. We maintain security measures to protect our premises, including video cameras, and to facilitate our operations, we may also collect audio recordings from those who leave us voice messages.

  • Physical Security and Biometric Information. We maintain various physical, technical and administrative security measures to protect our premises and operations, which capture personal information. These include badges to enter the building and access certain parts of the premises, health checks as may be recommended by public health authorities and signin processes for guests.

If you have provided us with non-personally identifiable information, including anonymous information and aggregate data, we may use such non-personally identifiable information to understand better how visitors use the Site. We may use this anonymous data and disclose it to our service providers for lawful business purposes, including to improve the Site and promote our business.

If you engage with us as an investor, we, including parties acting on our behalf or our affiliates behalf (such as our service providers), also collect, use and disclose:

  • Information you provide us or that your financial representative provides us on forms used in connection with your investments, in other electronic or written communications and during telephone or in person meetings (such information may include identifiers such as your name, residential and business addresses, citizenship, birthdate, email address, telephone numbers, household income and net worth, investment qualification and education background, sensitive personal information including your social security number or taxpayer identification number, passport information, driver’s license, information on your tax forms, and other information necessary for us to market our services to you or comply with laws and regulations that apply to our operations);

  • Information about the amounts you have invested with us, such as your initial investment, current account balances and any subscriptions or withdrawals;

  • Information about any bank account used to transfer funds between your investment with us and your bank, including information provided for wire transfers; and

  • Information we receive from other parties, including information from referral sources, and information that is generated by our service providers, such as administrators, accountants, bankers and custodians, to service our investors and accounts (such as account statements, tax information reports, transaction records, confirmations of contributions and withdrawals and similar information).

Sources of Personal Information

Much of the information referenced above will have been provided by you, but some may come from other sources, such as your representatives (including your broker-dealer or investment adviser), your business contact at JB Matteson or a mutual referral contact.

If you provide personal information about any person other than yourself, you must ensure they understand how their personal information will be used and that they have given their permission for you to disclose their personal information.

Use of Your Personal Information

We use personal information under this Privacy Policy to operate our business. For example, we may use personal information:

  • To evaluate and effect investment transactions and contracts, manage the services we provide and help maintain the administration, safety, security and integrity of our business and assets;

  • To comply with any applicable compliance, legal and regulatory obligations, lawful requests and legal processes (such as to respond to subpoenas and requests during government investigations) as we believe appropriate, and to comply with the compliance obligations required by our service providers;

  • To communicate with you about investments, our other services and products, and updates regarding our firm;

  • To improve the services provided to you, as well as understand your interests and personalize your experiences with us;

  • For marketing and promotional communications (as permitted by law and to the extent you do not opt out of receiving such promotional communications); and

  • On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.

If you do not provide requested information in connection with our operations and services, we may be unable in some circumstances to comply with our obligations or to pursue a relationship with you, and we will tell you about the implications of that decision at that time.

Who Receives Personal Information

It is our policy to not disclose your personal information, except we may disclose your personal information as permitted by law or as otherwise described in this Privacy Policy to the following types of parties:

  • Our affiliates, for our and our affiliates’ purposes consistent with this Privacy Policy;

  • Service providers and contractors that act on our behalf and help us with our operations (for example, administrators, solicitors or companies that assist us with hosting, analytics, database management services, marketing services, processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;

  • Our professional advisors, such as lawyers, bankers, accountants, auditors, brokers and insurers in the course of the professional services that they render to us;

  • Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;

  • Any third party as required to comply with a law, regulation, or legal request (including for anti-money laundering purposes, know your customer requirements, tax reporting, as we believe necessary or appropriate to comply with lawful requests and legal process, such as a request from a government authority, and in response to requests from self-regulatory organizations and non-governmental regulators), for fraud prevention, or to protect the property or rights of us or others (however, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information); and

  • Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

Children

Our Site and Investment Services are not directed to, and we do not knowingly collect personal information from anyone under the age of 16.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.

Do Not Track Signals.

Our Site is not designed to respond to “do not track” signals received from browsers.

Global Privacy Control

Our Site does not send any tracking technologies or cookies and, therefore, does not use Global Privacy Control.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will retain your personal information if deemed necessary for business purposes, including but not limited to satisfying any legal, accounting, or reporting obligations, or as may be necessary to resolve disputes. We specify retention periods by document type, which may include your personal information, in our Retention Policy and Schedule.

Information Security

We maintain physical, electronic and procedural safeguards to guard your personal information and the integrity and security of our databases. We have procedures in place for the disposal and protection against unauthorized access or use of your information. Except as described above, access to non-public personal information is restricted to our personnel who need to know such information. If we disclose your personal information, it is made available for limited purposes and under controlled circumstances.

Changes to this Privacy Policy

We reserve the right to change our Privacy Policy in the future. If we make changes that materially affect how we collect, use, store and disclose your personal information, we will notify you in connection with your engagement with us for services or otherwise by email.

Your California Privacy Rights

If you are a California resident, you may have certain rights if your personal information is protected by applicable California law, including the following rights (subject to certain exceptions and limitations):

  • Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.

  • Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.

  • Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are permitted or required by law to retain any record).

  • Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.

  • Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by CCPA regulations section 7027(m).

  • Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising. However, we do not sell or share any personal information for cross-context behavioral advertising.

 

California residents also have the right to not be discriminated against for exercising any of the rights described above. If you are a California resident and wish to exercise these rights, please contact 650.802.1800 or email at info@jbmatteson.com. There are circumstances where we are not required to comply with consumer requests, and we will let you know if one of those situations applies.

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact info@jbmatteson.com.

To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Contact Details

Please contact us if you are disabled and need a copy of this Privacy Policy prepared for you in a manner that is accessible. Any such request may be made via phone at 650.802.1800 or via email at info@jbmatteson.com.