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FACTS |
WHAT DOES MARCUS INVESTMENTS, LLC (“MARCUS”) DO WITH YOUR PERSONAL INFORMATION? |
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Why? |
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
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What? |
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
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How? |
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Marcus chooses to share; and whether you can limit this sharing. |
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Reasons we can share your personal information |
Does Marcus share? |
Can you limit this sharing? |
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For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
Yes |
No |
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For our marketing purposes – to offer our products and services to you |
Yes |
No |
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For joint marketing with other financial companies |
No |
We don’t share |
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For our affiliates’ everyday business purposes – information about your transactions and experiences |
Yes |
No |
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For our affiliates’ everyday business purposes – information about your creditworthiness |
No |
We don’t share |
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For our affiliates to market to you |
Yes |
No |
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For our nonaffiliates to market to you |
No |
We don’t share |
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Questions? |
investors@marcusinvestments.com |
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Who we are |
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Who is providing this notice? |
Marcus Investments, LLC |
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What we do |
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How does Marcus protect my personal information? |
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
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How does Marcus collect my personal information? |
We collect your personal information, for example, when you
We also collect your personal information from other companies. |
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Why can’t I limit all sharing? |
Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. |
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Definitions |
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Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies.
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Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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Joint Marketing |
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
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Other important information |
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California and Vermont Residents: We will not share information we collect about you with companies outside of Marcus (including with our affiliates) except as permitted by law and as described in this Privacy Policy. |
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MARCUS INVESTMENTS PRIVACY POLICY
Effective Date / Date of Last Revision: January 14, 2022
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Marcus Investments, LLC (“Marcus Investments,” “Marcus,” “we,” “our” or “us”) is an investment vehicle for the Marcus family and its approved partners. Marcus Investments operates a partially publicly available website at https://marcusinvestments.com (“Site”), where we provide information and opportunities to accredited investors (“Services”). When providing our Site and Services, we collect data from certain categories of individuals, such as our accredited investors, prospective customers and web site users.
Some of the data we collect may be considered “personally identifiable information,” “personal information” or “personal data” under applicable law (collectively referred to in this Privacy Policy as “Personal Data”). Generally, Personal Data is information that can be reasonably connected to an identified or identifiable individual. It does not include deidentified or anonymized data.
The purpose of this Privacy Policy is to plainly and transparently disclose to you how we collect, use and share information, and how we attempt to safeguard the data you provide to us. We are committed to securing data that we collect concerning you (“you”) and complying with applicable data protection and privacy laws.
2.HOW TO CONTACT US.
If you have any questions regarding data protection or your rights, please contact us:
Marcus Investments, LLC
301 N. Broadway, Suite 300
Milwaukee, WI 53202
(414) 585-8840
investors@marcusinvestments.com
3.WHY AND HOW WE COLLECT DATA.
We collect, process and use Personal Data to allow you to utilize the functionality and features we provide on our Site, to provide you with Services, and to communicate with you. The legal basis for our collection of Personal Data is with your consent, for our legitimate business purposes and/or to comply with our legal and contractual obligations. We obtain Personal Data directly from you, through cookies and other technologies, and from third parties as described in this Policy and any other privacy notices we may provide to you when you interact with us.
4.PROTECTING YOUR PRIVACY GENERALLY.
5.CHILDREN’S PRIVACY.
We do not intentionally collect any Personal Data from children under the age of sixteen (16). We do not sell the Personal Data of children under the age of sixteen (16).
6.TYPES OF INFORMATION WE COLLECT.
We use Cookies to: (a) estimate audience size and usage patterns; (b) understand and save your preferences for future visits, allowing us to customize the online experience to your individual needs; (c) advertise new content, events and services that relate to your interests; (d) keep track of advertisements and search engine results; (e) compile aggregate data about website traffic and website interactions to resolve issues and offer better online experiences and tools in the future; and (f) recognize when you return to our websites.
The Cookies we use collect the following types of Personal Data:
We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our sites, to conduct advertising, and to analyze the effectiveness of advertising.
Google Analytics
We may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
7.HOW WE USE YOUR PERSONAL DATA.
We use the Personal Data we collect to:
8.INFORMATION WE SHARE WITH THIRD PARTIES.
We do not sell personal data. We may share the information that we collect about you in the following limited ways:
9.HOW TO ACCESS & CONTROL YOUR PERSONAL DATA
We respect your privacy and provide ways for you to choose whether to share your information with us or any third parties.
You may decline to provide information. You have the right to decide not to share information with us.
Request deletion. You may submit a request to update or delete your personal data by contacting us at us at investors@marcusinvestments.com
PLEASE NOTE, HOWEVER, THAT IF YOU CHOOSE NOT TO PROVIDE US WITH CERTAIN INFORMATION OR ASK US TO DELETE YOUR INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH SOME OF OUR OPPORTUNITIES OR SERVICES. IN ADDITION, IN SOME CIRCUMSTANCES, WE MAY NOT BE ABLE TO MODIFY OR DELETE DATA DUE TO OUR OWN OBLIGATIONS.
Review and request changes to your personal data. You may use your account to access, correct, or view certain personal data we have collected which is associated with your account. You may also contact us at investors@marcusinvestments.com to request information or changes.
Marketing communications. You can always choose whether you wish to receive communications we send via email, SMS messages, telephone calls and postal mail. To do so, contact us at investors@marcusinvestments.com.
Control Cookies. You can learn more about which entities have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
1.SECURITY.
Where we have given you (or where you have chosen) a password which enables you to access our website or applications, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to or through our websites or applications; any transmission is at your own risk.
11.DATA RETENTION.
We will store your Personal Data for as long as: Personal Data is stored in our back up servers and/or services.
12.ACCESSIBILITY.
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternate format, or would like to report an issue you are experiencing, please email us at investors@marcusinvestments.com You expressly agree to attempt to resolve any and all issues with accessibility directly with us and in good faith prior to instituting any legal action against us.
13.NOTICE TO NEVADA RESIDENTS
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to investors@marcusinvestments.com
14.NOTICE TO CALIFORNIA RESIDENTS
THE CALIFORNIA CONSUMER PRIVACY ACT (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this does not apply to you.
This Notice to California Residents (“Notice”) applies to “Consumers” as defined by the CCPA and is a supplement to the other sections of our Privacy Policy. This Notice covers our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA through our website, as well as through all other websites, applications, products, services and other offerings we provide. Some of the data we collect and process is not subject to CCPA consumer rights because the data we collect and process is: (a) business-to-business information; (b) employee or personnel information; and/or (c) publicly available information (as defined by the CCPA).
A.COLLECTION AND USE OF PERSONAL INFORMATION
As set forth in Section 6 above, we collect certain categories of Personal Information from individuals, including individuals who reside in California. We collect Personal Information described in Section 6 from California residents for the purposes set forth in Sections 3 and 7, and may have disclosed such data to the categories of recipients set forth in Section 8.
B.SOURCES OF PERSONAL INFORMATION
We receive Personal Information from the information that you and others provide, your device(s), and from our partners. The categories of sources from which we’ve collected or received Personal Information include:
C.YOUR RIGHTS. Under the CCPA, you have the following rights:
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Number |
Description of your right |
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Right 1 |
The right to know what personal information we collect about you. |
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Right 2 |
The right to know whether we sell or disclose your personal information, and if so, to whom. |
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Right 3 |
The right to say no to the sale of personal information. |
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Right 4 |
The right to access your personal information. |
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Right 5 |
The right to receive equal service and pricing from us, even if you exercise your privacy rights. |
Right to Know: You have the right to request that we disclose to you the Personal Information we collected about you in the 12-month period preceding your request. This right includes the right to request: (1) specific pieces of PI we have collected about you; (2) categories of PI we have collected about you; (3) categories of sources from which the PI was collected; (4) categories of PI that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom your PI was sold or disclosed for a business purpose; and (6) the business or commercial purpose for collecting or, if applicable, selling your PI.
Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you. Note that if you request that we delete your information, we may be unable to provide you with certain programs or services, and you may become ineligible for some of our programs and services.
Right to Opt-Out of the Sale of Personal Information: The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration. We do not sell personal information.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
How to Exercise Your Rights: To exercise your “right to know”, “right to opt-out of sale” or your “right to request deletion,” email us at investors@marcusinvestments.com or call us at (414) 585-8840.
Please note that to protect your information, we may need additional information from you to verify your identity before processing your request.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We reserve the right to request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
SHINE THE LIGHT LAW: If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute). Compass Tours does not sell or disclose information to third parties for their direct marketing purposes.
15.NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA.
The General Data Protection Regulation (“GDPR”) applies to individuals located in the European Economic Area (“EEA”). The GDPR allows us to collect and use personal information from individuals within the EEA only for one or more of the following reasons:
We do not operate in the EEA or target our services to individuals in the EEA. However, we recognize some of our website users, investors, and prospective investors may be located within the EEA. If you reside in the EEA, you have a number of rights under data protection laws in relation to the way we process your Personal Data. To the extent the GDPR may apply to you, you have certain rights, which are set forth below. You may contact us directly to exercise any of these rights, and we will respond to any request received from you within one month from the date of the request. In exceptional circumstances we may need to extend this timescale, but we will always tell you in advance if we do, and our reasons why.
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Number |
Description of your right |
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Right 1 |
A right to access personal data held by us about you, as well as information about how we are using your data. |
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Right 2 |
A right to require us to rectify any inaccurate personal data held by us about you. |
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Right 3 |
A right to require us to erase personal data held by us about you, and where the personal data has been made public, for other controllers processing the personal data to also erase links to, or copy or replication of, such personal data. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below). |
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Right 4 |
A right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims. |
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Right 5 |
A right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to require us to transfer this personal data to another organization, at your request. |
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Right 6 |
A right to object to our processing of personal data held by us about you (including for the purposes of sending marketing materials to you). |
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Right 7 |
A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products). |
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, please get in touch with our team through the contact information provided in Section 2 of this Privacy Policy. You may also reach out to your applicable Data Protection Authority (“DPA”) for more information. There is a DPA located in each EU Member State.
Marcus Investments, LLC, a Wisconsin limited liability company (“Marcus,” “we” or “us”), is committed to protecting your privacy. This Privacy Policy applies to all Marcus websites for which Marcus owns directly or owns a license for and which relate to invest.marcusinvestments.com and marcusinvestments.com (each a “Site,” individually and collectively) and governs data collection and usage. By using the Site, you consent to the data practices described in this Privacy Policy.
We will collect Personal Information (as more particularly described below) that you submit or which we collect through your use of the Site. We may disclose this Personal Information to Marcus’ affiliates and third parties as described in more detail below. If you have questions or concerns about our privacy policy or practices, please contact us in the first instance in accordance with our contact information set forth below.
Please read carefully through all sections of this Privacy Policy. Your access to and use of the Site is subject to this Privacy Policy and all applicable laws. By registering with, creating an account, accessing and/or otherwise using the Site, you consent to Marcus’ use of the Personal Information as set forth below in this Privacy Policy. If you do not agree to this Privacy Policy, then you may not use the Site and you should not register with or submit your contact information to the Site.
We reserve the right, at any time, to add to, change, update or modify this Privacy Policy by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. Accordingly, it is your responsibility to review the Privacy Policy from time to time to ensure that you continue to agree with its terms. Each time you access or the Site, you agree to be bound by the then-current Privacy Policy.
Notice to California, U.S.A residents
Except as expressly identified below, we do not disclose a user’s Personal Information to any third party for such third party’s direct marketing purposes. Thus, under California Civil Code Sections 1798.80-1798.84, we have no obligation to a California resident to provide further information regarding our use of the California resident’s Personal Information.
Notice to Utah, U.S.A residents
Except as expressly identified below, we do not disclose a user’s Personal Information to any third party for such third party’s direct marketing purposes.
What this Privacy Policy Covers
This Privacy Policy covers our treatment of Personal Information that we collect when you are on the Site and when you use Services provided on the Site. This policy does not apply to the practices of companies that we do not own and/or control or to people that we do not employ or manage.
Information We Collect
We collect from you certain non-personally identifiable information as well as personally identifiable information (collectively, “Personal Information”) in connection with your use of the Site. Our collection and use practices with respect to Personal Information are set forth below.
Non-Personally Identifiable Information. We may collect information through technology that does not identify you personally in order to make the Site more interesting and useful for you and the other users. This information may also be used to make your experience on the Site better by optimizing website performance.
User Identifier. We may log all connections to our web servers. Those log files may include a unique user identifier, including, but not limited to your IP address and/or you mobile operating system (OS), our embedded, or other commonly used mobile device identifier (a “User Identifier”). A User Identifier is not personally identifiable information, but general information about your location, connection to the Internet, and your Internet or mobile phone service provider. We use your User Identifier to help diagnose problems with our server and to administer the services of the Site. Additionally, we may use your User Identifier to track your navigation of the Site.
Cookies. We may use a standard feature in browser software called “cookies” to enhance your experience with our Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help us identify how many unique users visit the Site and track user trends and patterns. Cookies also benefit your use of the Site and save you time by storing and making easily available information required to use the Site. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that deleting our cookies or disabling future cookies may negatively affect the continuity and user experience when you use the Site.
Clear Gifs. We may also employ a software technology called clear gifs (also known as web beacons) that help us better manage content on the Site by informing us what content is effective and of interest to our users. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Site users. Clear gifs and cookies are not tied to your personally identifiable information and may be used to improve your user experience when using the Site.
Other Tracking Technologies. We may also employ other tracking technologies common in the mobile industries, including UDID, OpenUDID, ODIN, MAC Address, device fingerprinting, or other technology. These technologies help us better manage content on the Site by informing us what content is effective and of interest to our users. These technologies are similar in function to cookies, and are used to track the online movements of Site users and are not tied to your personally identifiable information.
Log Files. Like most standard website servers, we may use log files. Information collected in log files may include internet protocol (IP) addresses, your User Identifier, browser type, internet service provider, mobile network provider, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the Site, track your movement in the aggregate, and gather broad demographic information for aggregate use. This information is not personally identifiable and may be used to improve your experience with the Site.
PERSONALLY IDENTIFIABLE INFORMATION. We may also collect information that identifies you personally through your submission of the information to us. For example, to access certain functionality on the Site, you may be asked to register and provide your personal contact information to use the Site (such as your name, email, username, phone number, address drivers license number, social security number, federal and state tax identification numbers, investment preferences, bank account information, or other similar information).
Information Sharing and Disclosure
Except as otherwise described in this Privacy Policy, we will not share your Personal Information with any other person or company. We will share Personal Information about you to other companies or people when:
• We need to share your information to provide the products or service you have requested;
• We need to send the information to companies who work on behalf of Marcus to provide a product or service to you;
• We find that your actions on our Site violate the Terms of Use or other agreements between us such that we desire the assistance of third parties to enforce our rights; and
• As required to respond to or initiate subpoenas, court orders, or legal process.
In the event you voluntarily share personal or sensitive information on a publicly available product or service review, on a message board, or in a chat room offered by the Site, please be advised that such information may be collected and used by the other users of the Site who have access to such message boards and chat rooms. Marcus shall have no liability resulting from the misuse of information you voluntarily share during your use of the Site or for information submitted to third parties for purposes of verifying status as an Accredited Investor (under 17 C.F.R.§ 230.501) or otherwise.
How We Use Personal Information
We may use your Personal Information for the following purposes: (1) to provide you with goods or services through the Site; (2) to administer and operate the Site and to conduct our business operations related thereto; (3) to send you information about the Site or goods and services; (4) to contact you; (5) to derive analytics about our Site operations and your preferences; (6) to enforce or protect our rights or the rights of third parties under applicable contract or law; (7) to provide information to our affiliates, service providers, business partners, or contractors as necessary in connection with any of the foregoing uses; and (8) as required by law or in response to a request from a law enforcement agency or authority. We may purge your Personal Information stored on our servers after a significant period of non-use.
Online Tracking
The Site does not treat browsers with a DNT signal differently from those without one. The Site will not automatically collect personally identifiable information, but will collect non-personally identifiable information over time and across third-party web-sites or online services if it receives a DNT.
Protection of Children’s Privacy
In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C., §§ 6501-06 and 16 C.F.R., §§ 312.1-312.12, our Site does not permit children under 18 years of age to become users, and we do not collect information from children. By using our Site, you represent that you are 18 years of age or older. If you believe a child under the age of eighteen (18) has accessed the Site or submitted Personally Identifiable Information to the Site, please contact us immediately at Chris.Nolte@marcusinvestments.com.
International Visitors
If you choose to access the Site from outside of the United States, please understand that your local laws governing date collection and use might differ from U.S. laws. Upon accessing the Site from outside of the U.S., you are transferring your personal information outside of such region(s) to the United States and by doing so consent to that transfer.
Ability to Review and Edit Your Information
You may review and approve the contact information about you that was stored in our database and obtained through your use of or registration on the Site. Upon your written request, we will remove that information from our database or change or correct Personal Information that you state is erroneous within applicable regulatory or other legal requirements. You should understand, however, that information about you in our database might come from a number of sources.
Security
We will maintain reasonable safeguards designed to promote the security, integrity and privacy of your Personal Information. However, no electronic storage method, site operation or data transmission over the Internet can be guaranteed to be 100% secure. The Site is built on a secure platform and uses industry standard encryption technologies to safeguard your Personal Information. Users are required to identify and authenticate themselves prior to accessing restricted portions of the Site, generally through logging in with a user name and password. You are responsible for keeping your user name and password safe. We have security procedures in place designed to prevent unauthorized access to your account, and a key aspect of these procedures requires that your Personal Information on record with the Site remains current and up to date. If you ever discover inaccuracies in our data, or if your personal information changes, please contact us at chris.nolte@marcusinvestments.com immediately. The transmission of information via the internet is not 100% secure and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of an unauthorized breach of our system, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Policies of Other Sites
The Site may contain links to third-party site not owned or controlled by Marcus. Marcus is not responsible for the privacy policies of any third-party site which user may access through a third-party link. Marcus is also not responsible for the privacy policies of any third-party site through which users obtained access to this Site, including www.crowdstreet.com. Further, these third-party sites may have privacy policies that differ from this Privacy Policy. Marcus disclaims all responsibility for the privacy practices of such other third-party sites. You should read the privacy policies of each site you visit to determine what information that site may be collecting about you and how they intend to use such information.
Opting Out.
You are never obligated to provide us with any personal information. At any time, if you would like to cease receiving communications from us or limit our ability to share your information with third parties, you may “opt out.” If you do not want to receive communications from us in the future or have personal information shared with third parties, email Christopher Nolte at Chris.Nolte@marcusinvestments.com or call 414-585-8840 and indicate your preference.
Questions
If you have any questions about Marcus, the Site, or this Privacy Policy, you may contact us at:
Marcus Investments, LLC
Attn: Christopher Nolte
414-585-8840
contact@marcusinvestments.com;
301 N. Broadway, Suite 300
Milwaukee, WI 53202