MBK Privacy Policy

Last Updated: December 31, 2022

Our Commitment to Privacy

MBK Real Estate LLC and its subsidiaries (“MBK,” “we,” or “us”) has developed and implemented this policy to demonstrate its commitment to privacy. This Privacy Policy is designed to assist you in understanding how we collect, use, share, and safeguard personal information and to assist you in making informed decisions about how to engage with us.

About This Privacy Policy

This Privacy Policy describes our practices for collecting, using, maintaining, protecting, and disclosing (“processing”) your personal information when you use our interact with the MBK services (“Services”), such as when you:

Visit a website of ours that links to this Privacy Policy (“Website(s)”), including mbk.com
Send us requests for information or engage in electronic communications with us
Interact with our social media pages
Click on our ads posted on third party sites
Communicate with our service representatives or features (including via chat functions, email, text, or phone)
Visit us at our physical locations (where we may collect personal information related to your visit, including for example, video security footage or your use of our Wi-Fi network)
Use our Services anywhere we collect information from you and refer to this Privacy Policy

This Privacy Policy also applies to personal information we collect from third parties about you. This Privacy Policy does not apply to websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed.

How We Define Personal Information

Personal information (sometimes also called “personal data”) is a broadly-defined term and its legal definition varies across jurisdictions. When used in this Policy, personal information includes information that is reasonably capable of identifying a particular individual (including through a device (like a web browser) either alone or when combined with information from other sources. Personal information does not include information that cannot reasonably be used to infer information about or otherwise be linked to a particular individual or household. We may use personal information to create deidentified or aggregated consumer information that we may use without restriction in accordance with applicable law.

How We Collect, Use, and Disclose Personal Information

The personal information we collect about you depends on the nature and context of your interaction with MBK and our Services. It may also depend on various choices you make about how to use the Services we offer, the functionality and features you choose or enable, your location, the devices you us to interact with our services, and applicable law. The following describes the personal information we collect about you and the way we collect it.

Personal Information You Give to Us

We collect the following categories personal information you provide to us, including the following:

Contact Information. For example, your first and last name, email address, phone number, physical address, job titles, and other contact information you provide.
Online Identifiers. For example, an IP address, user ID, customer number, or similar identifier that can be used to identify and user or account.
Coarse Location Information. A general approximation of your location that is not based on global position system (GPS) information (which we may infer from your IP address).
Audio Recordings. For example, telephone recordings and audio-visual recordings (often associated with customer service calls).
Social Media Content. For example, interactions with our social media pages and content you post on them.
Employment Candidate Information. For example, contact information, work history, education history, salary preferences, résumé and C.V. information.
Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes.

Sensitive Personal Information. Some jurisdictions have defined certain categories of personal information as “special” or “sensitive.” We collect the following categories of sensitive personal information when you provide it to us or allow us to collect it based on your interaction with us.

Payment processing information. For example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.
Social Security number
Driver’s license number
Governmental ID card number
Tax identification number
Military identification number
Passport numbers
Highly personal information. For example, information that reveals your racial or ethnic origin, religious or philosophical beliefs, union membership, political opinions, or sex life or sexual orientation.
Health Information. For example, information pertaining to your physical or mental health, fitness and exercise data.
Health insurance information
Genetic data

Additional Disclosures

We may also disclose any personal information to the following:

With our affiliates, including our parent company, subsidiaries, joint venturers, or other companies that we control or that are under common control with us.
Legally Required Parties. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.
Persons involved in the consideration, negotiation, completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.
Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it.

Retention of Personal Information

We will retain personal information only for so long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider: (i) the amount, nature, and sensitivity of the personal information; (ii) the potential risk of harm from unauthorized use or disclosure of your personal information; (iii) the purposes for which we process your personal information and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements. In some circumstances, you may ask us to delete your personal information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

How We Protect Personal Information

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Periodically, our operations and business practices are reviewed for compliance with policies and procedures governing the security, confidentiality, and quality of our information. Our corporate values, ethical standards, policies, and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons, processes, and transactions.

Children’s Personal Information

Our Services are not intended for persons under 18 years of age. We do not knowingly collect or process the personal information of individuals under the age of 18. If you believe that a child under 18 may have provided us their personal information, please contact us at privacy@mbk.com.

Your Privacy Choices

You can control the collection and use of personal information for some of our processing activities. This includes:

Adjusting Communication Preferences

Email: You may unsubscribe from promotional and other types of communications by following the “unsubscribe” instructions near the bottom of the email. You may also email us at info@MBK.com. Please note, opting out of promotional emails will not stop you from receiving all emails from the company. For example, we may still send you emails pertaining to services alerts, account notifications, updates, and similar purposes.

Text Messages: You may opt out of automated text notifications any time by replying “STOP,” or any alternative keyword we have shared with you. Please note, opting out of automated text messages may prohibit you from receiving important notifications regarding our services.

Blocking Cookies

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

Safari (Desktop) and Safari Mobile (iOS).

Additionally, you may use our cookie consent preference manager to customize your cookie preferences for our Website(s).

Blocking Google Analytics

Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.

Mobile Device Privacy Settings

Mobile devices can use device-level information to serve targeted ads. To learn about your privacy choices for your mobile devices, visit these informational pages from Google (Android) and Apple (iOS).

Exercising Privacy Rights

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include:

The right to know (or confirm) what personal information a business has collected about you.
Deletion. The right to request that a business delete personal information it has collected from you, subject to certain exception.
Correction. The right to request correction of inaccurate personal information maintained by the business.
Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt-out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt-out of the use of personal information for targeted advertising purposes.
Limitation. The right to limit a business’s use or disclosure of certain information, typically sensitive personal information.
Opt-out of Profiling: The right to opt- out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.

MBK will honor the privacy rights afforded to individuals in accordance with applicable law.

You may make a request at any time to exercise your privacy rights listed above by emailing us at privacy@mbk.com. We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision.

International Data Transfers

MBK is based in the United States, and we operate our website and portals from there. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. By submitting personal information to us, including by accessing our website and portals, you understand that we may process, store, and transfer your personal information in and to jurisdictions foreign to you, including the United States. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy laws.

Updates to Our Privacy Policy

We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Contacting MBK

If you have any questions about our Privacy Policy, or would like to remove your stored

information, please contact us at privacy@mbk.com or you can write to us at 4 Park

Plaza, Suite 1700, Irvine CA, 92614.

Supplemental Notice for Residents of California

This section applies to residents of the State of California in addition to all other applicable rights and information contained in this Policy. When referring to “consumers” in this Section, we mean California residents. This supplement is adopted in accordance with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, the “CCPA”). The terms used in this section have the meanings provided for under the CCPA.

California law requires that we describe the personal information we collect, disclose, and sale/share based on certain defined categories. To be clear, this chart overlaps with the description of our processing practices described above. This chart below describes our practices covering the past 12 months.

Categories of Personal Information	Examples	Collected From	Types of Service Providers/Contractors to Whom this Category if Disclosed	Types of Third Parties with Whom this Category of Personal Information Is Shared/Sold
Unique Identifiers	Name, signature, address, telephone email, account name, SSN, DL number, passport number, online identifier, IP address	Consumers Advertising Networks Analytics Providers Business Contacts	Business Operations Services Providers Advertising Networks Internet Service Providers Data Analytics Providers Government Entities Operating Systems and Platforms Social Networks Affiliates	Advertising Networks (Opt-out of Sale/Sharing)
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Consumers Business Contacts	Business Operations Services Providers Government Entities Affiliates	We Do Not Sell
Protected Classifications	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Consumers Business Contacts	Business Operations Services Providers Government Entities Affiliates	We Do Not Sell
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Consumers Business Contacts	MBK Services Partners Business Operations Services Providers	We Do Not Sell
Internet Activity	Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement	Website, Portal, and Social Media Page Visitors	Advertising Networks Internet Service Providers Data Analytics Providers Social Networks	Advertising Networks (Opt-out of Sale/Sharing)
Professional or employment-related information.	Current or past job history or performance evaluations.	(See our Workforce Member Privacy Notice)	N/A	We Do Not Sell
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	We Do Not Collect or Infer.	N/A	We Do Not Sell
Sensitive Personal Information	Social security, driver’s license, state identification card, or passport number, account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email and text messages (unless we are the intended recipient); genetic data; biometric data for identification purposes; health data; and sex life or sexual orientation data.	(See our Workforce Member Privacy Policy)	N/A	We Do Not Sell

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

Your Rights Under the California Consumer Privacy Act (CCPA)

California Residents have certain rights under the CCPA, including the following:

You have the right to know what personal information the business has collected about you. While our California Privacy Policy details the personal information we collect about all California consumers, you have the right to make a request to know and get access to information that is specific to you, should we have any.
Deletion. You have the right to request that we delete personal information we have collected from you, subject to certain exception. For example, we will not delete any personal information required to provide our services to you or that we must maintain to comply with our legal obligations. We will notify you following submission of your request if this is the case.
Correction. You may request that we correct inaccurate information we maintain about you, subject to some exceptions and, if necessary, independent verification.
Opt-Out of the Sale/Sharing of Your Personal Information. If we have sold or shared personal information about you, you have the right to opt out of the sale or sharing of that personal information.
Limitation. In some instances, you have the right to limit our use or disclosure of Sensitive Personal Information. However, MBK does not use or disclose sensitive personal information for any purpose other than for permissible purposes under California law.
Non-Discrimination. You have the right not to be discriminated against if you exercise any of the rights conferred by the CCPA. Please note that a legitimate denial of a request for information, deletion, or to opt out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.

Exercising Your California Privacy Rights

Submitting Access, Deletion, and Correction Requests

To make an access, deletion, correction, or limitation request, please use our online request form available HERE, email us at privacy@mbk.com, or call us at (855) 914-1987.

After we receive your request, to ensure the security of the information we store and consumers’ privacy, we will verify that you are appropriately affiliated with the subject of the request, either as the consumer or as an authorized agent or guardian of the consumer. We may ask you to provide a few pieces of information to confirm your identity in our records.

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. You must provide the authorized agent written permission to exercise your rights under the CCPA on your behalf and we may deny a request from an agent on your behalf if we cannot verify that they have been authorized by you to act on your behalf. Even if you use an authorized agent to exercise your rights under the CCPA on your behalf, pursuant to the CCPA we may still require that you verify your own identity directly to us. This provision does not apply if you have provided a power of attorney under the California Probate Code.

Opting Out of the Sale/Share of Your Personal Information

As described in our privacy policy, we sell and share personal information with our advertising providers for advertising and marketing purposes. You have the right to opt out of the sale or sharing of your personal information by us. The following are some methods you can use to submit opt-out requests:

Opt-Out Preference Signals: This website responds to opt-out preference signals, which are a method by which consumers can opt out of the sale and sharing of their personal information without having to make an individualized request. We honor the following commonly used and recognized opt-out preference signals in a frictionless manner: Global Privacy Control. To implement an opt-out preference signal on your device or browser, download the appropriate browser that uses a recognized opt-out preference signal, like the Global Privacy Control.

This website responds opt-out preference signals in a frictionless manner. That means upon receipt of the opt-out preference signal, we will not require you to provide additional information beyond what is necessary to process the signal.

Online Requests. You may also submit a request to opt out of the sale or sharing of your personal information by email us at privacy@mbk.com.

Additional California Privacy Rights

California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to info@MBK.com with the subject “Shine the Light Request.”

Changes to Our California Privacy Policy

MBK reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post an updated notice on our website with the effective date.

Contact Us Regarding Your Privacy Rights

If you would like additional information regarding our California Privacy Policy or your privacy rights generally, please email us at privacy@mbk.com. Please submit your CCPA rights requests using the methods described above.

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