Privacy Policy

1. Introduction

Brickhouse Capital LLC ("we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

We operate in compliance with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable data protection laws. This policy applies to all visitors, clients, and business contacts who interact with our services.

By using our website or services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

2. What Data We Collect

We collect several types of information from and about users of our website and services:

2.1 Personal Information

• Identity Data: Full name, title, date of birth, gender
• Contact Data: Email address, telephone numbers, mailing address
• Financial Data: Income information, investment history, financial goals, net worth (when provided for services)
• Professional Data: Job title, employer name, business contact information
• Identification Data: Government-issued ID numbers (for KYC/AML compliance when required)

2.2 Technical Data

• IP address, browser type and version, device information
• Time zone and location settings
• Browser plug-in types and versions
• Operating system and platform
• Website usage patterns and navigation data

2.3 Communication Data

• Correspondence sent via contact forms
• Email communications with our team
• Phone call records and notes
• Meeting records and consultation notes

2.4 Cookies and Tracking Data

We use cookies and similar tracking technologies to collect and track information. See our Cookie Policy for detailed information about how we use cookies.

3. How We Collect Data

We collect information through various methods:

3.1 Direct Collection

• Contact Forms: When you fill out forms on our website
• Service Applications: When you apply for our financial services
• Email Communications: When you email us directly
• Phone Conversations: When you call our office
• In-Person Meetings: When you visit our office or meet with our team

3.2 Automated Collection

• Cookies: Small data files stored on your device
• Web Analytics: Tools that track website usage patterns
• Server Logs: Technical data automatically recorded by our servers

3.3 Third-Party Sources

• Public Records: Information from publicly available sources
• Business Partners: Data shared by referral partners
• Verification Services: Information from identity verification services

4. Why We Collect Data (Legal Basis)

We process your personal data for specific purposes and rely on the following legal bases:

4.1 Service Delivery

We use your information to:

• Provide and manage our financial services
• Process your service requests and applications
• Communicate with you about your account and services
• Provide customer support and respond to inquiries

Legal basis: Contract performance and pre-contractual measures (GDPR Art. 6(1)(b))

4.2 Legitimate Business Interests

We use your information to:

• Improve our services and website functionality
• Conduct market research and analysis
• Communicate about relevant services and updates
• Detect and prevent fraud
• Protect our legal rights and interests

Legal basis: Legitimate interests (GDPR Art. 6(1)(f))

4.3 Legal Compliance

We use your information to:

• Comply with Know Your Customer (KYC) requirements
• Meet Anti-Money Laundering (AML) obligations
• Respond to lawful requests from authorities
• Maintain required business records
• Comply with tax and financial regulations

Legal basis: Legal obligation (GDPR Art. 6(1)(c))

4.4 Consent

We may use your information for:

• Marketing communications (where you have opted in)
• Analytics and tracking cookies (where not strictly necessary)
• Sharing with third parties for marketing purposes

Legal basis: Consent (GDPR Art. 6(1)(a))

5. Who Has Access to Your Data

We may share your personal information with:

5.1 Internal Access

• Authorized employees who need access to perform their duties
• Management and compliance personnel
• IT and security teams maintaining our systems

5.2 Service Providers

• Email and communication service providers
• Website hosting and analytics providers
• Payment processors
• Identity verification services
• Legal, accounting, and audit professionals

5.3 Legal Requirements

• Regulatory authorities and government agencies
• Law enforcement when required by law
• Courts and legal proceedings

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity.

6. Third-Party Services

We use the following categories of third-party services:

6.1 Analytics

• Google Analytics (website usage analytics)
• Similar tools to understand website performance

6.2 Communication

• Email service providers for sending communications
• Contact form services (Formsubmit)

6.3 Security

• SSL certificate providers
• Website security monitoring services

6.4 Hosting

• Web hosting providers
• Cloud infrastructure services

These third parties are contractually obligated to protect your data and only use it for the purposes we specify.

7. Data Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

7.1 Technical Measures

• Encryption: SSL/TLS encryption for data in transit
• Access Controls: Role-based access and authentication
• Firewalls: Network security systems
• Regular Updates: Security patches and updates
• Monitoring: Continuous security monitoring

7.2 Organizational Measures

• Staff Training: Regular data protection training
• Access Policies: Strict access need-to-know policies
• Incident Response: Documented breach response procedures
• Regular Audits: Periodic security assessments

While we take reasonable steps to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

8. Data Retention Policy

We retain your personal information only for as long as necessary:

8.1 Retention Periods

• Client Records: 7 years after the end of the business relationship (regulatory requirement)
• Marketing Data: Until you opt out or request deletion
• Website Analytics: 26 months (configurable)
• Contact Form Submissions: 3 years
• Communication Records: Duration of relationship plus 7 years

8.2 Criteria for Retention

We consider:

• Legal and regulatory requirements
• Contractual obligations
• Statute of limitations for legal claims
• Business and operational needs

8.3 Deletion

When retention periods expire, we securely delete or anonymize your data.

9. Your Rights (GDPR & CCPA)

Depending on your location, you have certain rights regarding your personal data:

9.1 Right to Access

You have the right to request a copy of the personal data we hold about you.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data.

9.3 Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data, subject to certain exceptions (e.g., legal retention requirements).

9.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data under certain circumstances.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, machine-readable format.

9.6 Right to Object

You have the right to object to processing based on legitimate interests or direct marketing.

9.7 Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing that produce legal effects.

9.8 CCPA-Specific Rights

California residents have additional rights:

• Right to know what personal information is collected, sold, or disclosed
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising these rights

Note: We do not sell personal information as defined under CCPA.

10. How to Request Data Deletion

To exercise your rights, including requesting deletion of your personal data:

10.1 How to Submit a Request

• Email: Send a request to finance@brickhousecapital.net with "Data Request" in the subject line
• Phone: Call us at +1 636-393-7072
• Mail: Send a written request to the address below

10.2 Required Information

Please include:

• Your full name and contact information
• Specific right(s) you wish to exercise
• Description of the data or processing you're concerned about
• Proof of identity (may be required)

10.3 Response Time

• GDPR: We will respond within one month of receiving your request
• CCPA: We will respond within 45 days of receiving your request

10.4 Verification

We may need to verify your identity before processing your request to protect your privacy.

11. Contact Information

For privacy-related inquiries or to exercise your rights, please contact us:

11.1 Data Protection Officer

For GDPR-related matters, you may contact our Data Protection Officer at the address above or via email at finance@brickhousecapital.net.

11.2 Right to Lodge a Complaint

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with a supervisory authority:

• EU Residents: With your local Data Protection Authority
• California Residents: With the California Attorney General's Office

12. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including the United States. These countries may have different data protection laws.

When we transfer data internationally, we implement appropriate safeguards such as:

• Standard Contractual Clauses approved by relevant authorities
• Binding Corporate Rules (where applicable)
• Other legally valid transfer mechanisms

13. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take steps to delete that information promptly.

14. Policy Updates

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending an email notification for material changes (where we have your email address)

We encourage you to review this policy periodically.

15. Additional Information

15.1 Do Not Track

Our website may not respond to Do Not Track signals. Please manage your privacy preferences through our cookie consent tool.

15.2 Links to Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to review their privacy policies.

15.3 Questions

If you have any questions about this Privacy Policy or our data practices, please contact us at finance@brickhousecapital.net.