PRIVACY POLICY

Last Updated February, 2020

This Privacy Policy (the “Privacy Policy”) only applies to websites which are owned, controlled and/or operated by or on behalf of Luxury Asset Capital LLC and/or its subsidiaries (together, (“LAC” or “we,” “our,” or “us”)  (however accessed and/or used, whether via personal computers, mobile devices or otherwise, collectively, the “Websites”), or other interactive features or protocols that are owned or operated by LAC and are available through the Websites or that interact with the Websites and post this Privacy Policy.  Unless otherwise defined herein, capitalized words shall have the meanings assigned to such terms set forth in the Terms of Service available at Terms of Use, which incorporates this Privacy Policy. This Privacy Policy does not apply to websites, applications or other services that do not display or link to this Privacy Policy or that display or link to different privacy statements.

 This Policy uses the following definitions:

“Personal Information” is data as that is reasonably linked to a particular person, computer, or device.

“Anonymous Information” is data and information that is not reasonably linked to a particular person, computer, or device.

“Affiliates” are companies related to LAC by common ownership or control. They can be financial and nonfinancial companies.

“Non-affiliates” are companies not related by common ownership or control. They can be financial and nonfinancial companies.

“Joint marketing” is a formal agreement between nonaffiliated financial companies that together market financial products or services to you.

The purpose of this Privacy Policy is to disclose to you the Personal Information we may collect through the Websites, how we may collect it, how we use it, with whom we may share it, and how we protect it.

 What Information We Collect

We collect Personal Information that you submit to us voluntarily through our Websites, our services, and through your online and offline communications with us.

Information you provide to Us. We may collect your name, email address, mailing address, phone number, credit card information, driver’s license number, passport number, social security number and other Personal Information when you use our Websites and services. This information may be collected when you register on any of our Websites, place an order, subscribe to a newsletter, respond to a survey, fill out a form, use Live Chat, open a Support Ticket, enter information on our Websites, or utilize our services.

When you use our Websites and/or services, you may be asked to provide additional information, including your birthdate, photo identification information, a description of personal property related to your use of our services, and a signed Declaration of Ownership of such property. If you wish to use an automated clearinghouse (ACH) service to receive payments, we collect your bank account number and routing information from you through an electronic form on the Websites or by mail, if you send us a voided check.

Information from Social Networking Sites. Our Websites include interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Websites or if you access our Websites through a SNS, you authorize us to access, use and store the information that you agreed the SNS could provide through your settings on that SNS. We will access, use and store that information in accordance with this Privacy Policy. You can revoke our access to the information you provide through the SNS by amending the SNS settings in your SNS account through the applicable SNS.

Information You Disclose Publicly. If you volunteer information or create a public profile in the course of your participation in our community features such as our blog or other forms of public communication and interaction (“Website Forums”) or submit comments, photographs, text or other content to us (“User Generated Content”), it may be published online or offline (including on-air, on a CD or DVD, through wireless distribution and transmission of soft copies, or any other media or format currently existing or hereafter developed), and we may publish your name, voice, likeness and other Personal Information in connection with publishing the content or a portion of the content, and we may use the content and any excerpt from the content in connection with advertising, marketing, publicity and promotional activities. Please be aware that when you share Personal Information in a public Website Forum, we cannot ensure the security of that information and it will be publicly available and you may receive unsolicited messages from other parties. Please exercise caution when disclosing Personal Information through the Website Forums. Your use of any Website Forum and submission of any User Generated Content is subject to our Terms of Use. Please note that the terms in this paragraph governing User Generated Content may not apply to information provided to us under a separate agreement, such as a Repurchase Agreement or offline contract entered into by you and LAC (“Contract”). To the extent that any of the terms set forth herein conflict with the terms of any Contract, the terms of such Contract shall govern.

Information Provided by Third Parties. We may also get information about you from third parties, for example, from companies that collect data and customer lists.

Information Collected Through Cookies, Pixels, Web Beacons and Other Technologies. When you visit our Website, we may collect information through about your usage and activity on our Websites through the use of cookies, pixels and other technologies. Cookies are small text files stored on your browser by a website to recognize that browser and remember user preferences and other information. Cookies help us to improve our Websites and your experience. For example, we use cookies to:

• Remember and process your orders and use of our services.
• Understand and save user preferences for future visits.
• Compile aggregate data about site traffic and site interactions in order to offer better experiences on our Websites and to develop tools in the future.

A pixel is a line of code that is used on the Websites to attribute online activities to a device or browser. The use of a pixel allows us to record, for example, that a device or browser has visited a particular page on our Website.

Web beacons are small graphic images or other web programming code, also known as “1×1 GIFs” or “clear GIFs”. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Since this information may be collected when you are signed in to our services, this information may be associated by us with Personal Information that we have collected from you.

Personal Information from Other Sources. Where permitted by applicable law, we may collect information about you from other sources and we may add it to the information that you provide to us through the Websites. For example, we may receive identity verification information from our service providers to confirm your identity as part of the registration process. Please note that all of the information we collect about you may be combined, including to help us tailor our communications to you and to develop or improve content and services across the Websites. This Privacy Policy does not cover the practices of third parties, including those that may disclose information to LAC. If we combine information we receive from those other sources with Personal Information we collect through the Websites, we will apply this Privacy Policy to any Personal Information received, unless we have disclosed otherwise.

 How We Use Information We Collect

We only use payment and identity verification information that you provide to us, such as credit card numbers, bank account numbers and driver’s license numbers, as necessary for completing the transaction and for performing the services for which it is expressly provided. We generally use other information we collect from or about you:

• To personalize your experience and to allow us to deliver the type of content and product offerings that we believe are likely to be of most interest to you;
• To improve our Website, services and security in order to better serve you;
• To respond to your comments, questions, and customer service requests;
• To communicate with you about and enable you to participate in contests, sweepstakes, promotions, rewards, upcoming events, and other news about products and services offered by LAC, its Affiliates, and our selected partners;
• To quickly process your transactions;
• To request ratings and reviews of services or products;
• To follow up with you after previous correspondence (live chat, email or phone inquiries); and
• To link or combine it with other information we receive from third parties, to help understand your needs and provide you with better service.
• To prevent potentially prohibited or illegal activities; and
• For marketing and advertising purposes.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

 How We Share and Disclose Your Personal Information

Except as otherwise disclosed at the time you provide your information; the following outlines the ways in which your information may be shared with others:

With Your Consent. With your consent, we may share your Personal Information with Affiliates, joint ventures and other business partners. For example, the Websites may offer access to relevant services if you agree to have your information shared with third parties so they can contact you about related products and services.

Authorized Third Parties Providing Services on our Behalf. We may use third party service providers to assist us in processing your information and/or to support our services and/or the Websites, such as customer support services, clearing and processing credit card payments, e-mail and text message deployment services, data hosting services, data processing services, business analytics services, marketing services, and to provide certain products or services that you have requested. These authorized third parties shall be permitted to collect and process your personal information for the purpose of performing their contracted function(s) and for no other purpose.

Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions through the Web Sites that may require registration. If you choose to enter a sweepstakes, contest or other promotion, subject to the terms and conditions of such promotion your personal information may be disclosed to third parties who help design administer and implement such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and aggregated analysts and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.

Administrative and Legal Reasons. We may transfer and disclose your information, including Personal Information and Anonymous Information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to protect and/or defend the Websites’ Terms of Use or other policies applicable to the Websites; or (iv) to protect the personal safety, rights, property or security of LAC or any individual. We may also use IP address or other device identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion. To the extent permitted or required by law, such disclosures may be carried out without notice to you.

Other LAC Businesses. We may share information we collect about you within the family of LAC Websites and with other LAC-affiliated entities, so we can provide you with information about products and services that might interest you. 

Business Transfers. LAC shares information collected through the Websites with and among the Websites and our corporate family. We may buy or sell a company, some of a company’s assets, a Website or Websites or several of the companies in our corporate family may merge with one another, be otherwise reorganized or be acquired by another company. If we negotiate and/or complete such a corporate transaction, we may share or transfer some or all of your information and we reserve the right to disclose and transfer your information, including Personal Information, in connection with such corporate transactions and other corporate changes.

 Information Retention

We will keep your information for a reasonable period for the purposes set out above.

 How to Opt-Out of Cookies, Promotional Emails, Text Messages

Cookies. You can adjust your browser settings to refuse or remove cookies. However, by doing so, you may not be able to access or use certain features on the Websites or take advantage of all services.

If you choose to block or delete cookies, you can still place orders over the telephone by contacting customer service at info@borro.com Personal Information provided over the telephone to customer service is subject to the terms of this Policy.

Emails. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences and changes to your information including requests to opt-out of sharing your Personal Information with third parties by emailing info@borro.com

Text Messages. If you have provided us with your prior express written consent to receive marketing telephone calls and text messages made using an automatic telephone dialing system (auto-dialer) and/or an artificial or prerecorded voice, you may opt out at any time.  If you do not wish to receive marketing telephone calls and/or text messages, including calls or texts made using an auto-dialer or an artificial or prerecorded voice, you may express your choice to opt-out by emailing info@borro.flywheelsites.com. You may also opt out of such calls and texts by texting STOP in response to a marketing text from us. Following your STOP text message, you will receive one additional confirmation text message stating that you’ve opted out.

 Choices Regarding Your Personal Information

 Limit Information Sharing. If you are a customer of LAC, you have the right to limit how we share some of your Personal Information. Upon request, you can limit how we share your Personal Information: (1) For our Affiliates’ everyday business purposes —Information about your creditworthiness; (2) For our Affiliates to market to you; (3) For our Non-affiliates to market to you. The following chart provides details about your choices:

To limit information sharing, please call us at 720.230.0820. If you limit sharing, your choices will apply to everyone associated with your account.

Also, please note that if you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Accessing, Correcting, and Deleting Your Information. You may change certain of the Personal Information in your customer account (if any) by logging in to your account and editing it, provided that it remains accurate, complete, and up to date. Additionally, you are entitled to know what Personal Information we hold about you and to have any inaccuracies in your Personal Information corrected. For these purposes, please contact us at info@borro.com. Please allow 30 days for a response.

You may also request that LAC delete or destroy your Personal Information. We will delete or destroy any Personal Information that we have collected about you, provided there is no ongoing transaction and solely to the extent permitted by law. For these purposes, please contact us at info@luxuryassetcapital.com. Please allow 30 days for a response.

 Your California Privacy Rights

Data Collection. We do not knowingly allow third parties to collect Personal Information about your online activities when you use our Websites and services for purposes of online behavioral tracking.

 Do Not Track. California law requires us to disclose how we respond to browser “Do Not Track” signals or other similar choice mechanisms relating to online behavioral tracking. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

 Links and Third-Party Websites

We may include or offer third-party products or services on our Websites or link to third-party websites. We do not control those third-party sites and are not responsible for the technology, content, privacy policies or practices in connection with those sites. You should carefully review the privacy policies that apply to any third-party sites you access from our Websites.

 How We Protect Your Information

We have implemented reasonable organizational, technical, physical and administrative steps designed to protect Personal Information against loss, misuse, unauthorized access or disclosure. Despite our efforts, no method of transmission of information over the internet or storage of information is guaranteed to be completely secure. While we strive to protect your information, we cannot guarantee its security and shall not be liable for any breach of security in regards to your information. FOR THE AVOIDANCE OF DOUBT, EXCEPT AS REQUIRED BY APPLICABLE LAW OR THE PCI STANDARDS, WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR PERSONAL INFORMATION.

 Children’s Privacy (Children’s Online Privacy Protection Act)

Neither our services nor Websites are developed for or directed at children under the age of 13. We do not knowingly collect information from children under the age of 13. If you believe a child has provided us with Personal Information and you would like to have the information removed, please contact us at info@borro.com.

 Changes to This Policy

We may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above. If we make any material change(s) to the Policy, we will post a notice on our Websites prior to such changes(s) taking effect.

 Contact Us

Should you have any questions or concerns regarding this Privacy Policy, please contact us at info@luxuryassetcapital.com, 720.230.0820, or:

Luxury Asset Capital LLC

4100 E Mississippi Ave, Suite 1850

Denver, CO 80246

 Privacy Policy Updates

If we make any changes to this Privacy Policy, we will change the “Last Updated” date above. If we make any material change(s) to the Privacy Policy, we will post a notice on our Websites prior to such changes(s) taking effect.