Effective January 1, 2025
This Privacy Policy covers the information we collect about you when you use our online services or otherwise interact with us electronically, for example, via email or webchat (collectively, our “Online Services”). “MBK,” “we” and “us” refers to MBK Real Estate, LLC, and any of our corporate affiliates. Our Privacy Policy is here to help you understand how MBK manages your personal data using our Online Services. In this policy, we detail what information we collect, how we use it, and the choices and rights you have regarding its use. Our aim is to give you the necessary insights to make informed decisions about your interactions with our services. If you do not agree with the data collection practices described in this Privacy Policy, do not access or use our Online Services.
This Privacy Policy describes the various contexts and circumstances in which we collect personal data, including through our Online Services. These Online Services include:
MBK maintains separate privacy notices for other types of data processing. For example, this Privacy Policy does not apply to personal data collected in the context of our physical properties and facilities, our business-to-business relationships, or with respect to our workforce. Depending on the context in which you interact with us, we may present you with additional notices or policies about our privacy practices. For questions regarding the scope of this Notice, please contact us as set forth in the Contact Information section.
We obtain the information we collect about you through various means and sources, including:
4 Information Collected and How We Use It
We collect and use personal data for several purposes, including to provide our Online Services and continually improve them. The personal data we collect, and how that information is used, depends on how you interact with us, the choices you make when engaging with us, and the Services you use. Please note, we share personal information for targeted advertising purposes, and we allow users to exercise their privacy rights with respect to this sharing.
This section provides an overview of the types of personal data we may collect about you and the general purposes for which they are used in particular contexts. Please note that the actual information collected and its use may vary depending on your interactions with us and the Online Services you use.
4.1 Personal Data We Collect Directly From You Online
This section describes the personal data we collect about you when you provide it directly to us through our Online Services or in an electronic communication.
4.1.1 What We Collect or Process
4.2 Personal Data Collected Using Online Data Collecting Tools
We collect, use, and disclose personal data gathered in connection with your online interactions with us, including your use of our websites and their features. We also collect personal data in connection with electronic communication services like email and electronic messaging, and our social media pages (though not the platforms on which they are maintained). When you use our Online Services, we collect some information automatically and combine it with other information we collect about you. In many cases we utilize third parties to assist with this collect. In such cases, your personal data is made available to other entities for processing on our behalf or at our direction or to serve you with targeted advertisements.
Some of this information is collected and logged as a result of your access to our servers, but various technologies such as cookies, web beacons, scripts, tags, and other software code that store and transmit personal and other information (collectively “data collecting technologies”). Some of these data collecting technologies are used by third parties to collect or receive information from our Online Services and elsewhere on the Internet and use that information to provide measurement services and target ads.
4.2.1 What We Collect or Process Using Data Colleting Technologies
4.2.3 Third Parties Who Provide Online Services
We may use third-party services for various purposes, including but not limited to analytics, advertising, and customer support. Below are some specific third parties that we may use. To learn more about the types of entities who deploy cookies and online tracking technologies on our websites, please review “Disclosure of Personal Data.”
4.3 Data Collected from Other Parties
We obtain information from businesses provide us with our business and Online Services, such as our data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, and publicly available sources. We also create information based on our analysis of the information we have collected from you. We use this information for our business operations purposes, including offering and improving our Services, providing customer support, measuring the effectiveness of our Services, accounting and transaction purposes, and to enforce our terms and policies. Please see “Disclosure of Your Personal Data” to learn more about how we process personal information via our business services providers.
4.4 Other Purposes for Processing Personal Data
While less frequent, there are other scenarios where we may use or disclose your personal data:
5 Disclosure of Your Personal Data
We may disclose the above information to the following types of parties:
We retain your personal data only as long as needed to fulfill the purposes we collected it for, including satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider (i) the amount, nature, and sensitivity of the personal data; (ii) the potential risk of harm from unauthorized use or disclosure of your personal data; (iii) the purposes for which we process your personal data and whether we can achieve those purposes through other means; and (iv) the applicable legal requirements related to our processing activities. Additionally, we may anonymize your personal data (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. If you have any questions about the specific retention periods for different types of your personal data, please feel free to contact us using the Contact Information provided below.
You can control the collection and use of personal data for some of our processing activities. Below are the avenues through which you can manage the types of communications you receive from us:
8.1 Description of Your Privacy Rights
Depending on your location and applicable laws and regulations, you may also have data privacy rights regarding MBK’s processing of your personal data. Based on the legal requirements applicable to your jurisdiction, and subject to any legal restrictions or exceptions, you may have the choices and rights described below.
Residents of California may also have additional rights pertaining to their personal data, as described in “California Privacy Rights.”
8.2 Exercising Your Privacy Rights
To exercise any of the rights outlined above, please visit our web form.
To ensure the security and confidentiality of your personal data, we have established verification measures that must be completed prior to fulfilling any request to exercise your data rights. These measures may involve confirming your identity through a series of questions or requiring documentation that substantiates your identity or authority to make the request. Should we be unable to verify your identity or authority adequately, we reserve the right to decline the request and will provide an explanation for our decision. Upon receiving a verified request to exercise your data rights, we will acknowledge receipt of the request. We will aim to respond substantively to your request within time permitted under the applicable law. If we require more time to process your request, we will inform you of the reason and extend the period by the notified number of days.
Please note that not all requests will be granted. Certain legal exceptions may apply, such as if we are unable to verify your identity, or if there are legal or contractual reasons that prevent us from fulfilling a deletion request. Regardless of the outcome, you will receive a written response that either details the actions we took or explains why no action was possible. If you are dissatisfied with our initial response, you may seek further review. To initiate an appeal, please contact us within 30 days of receiving our initial response using the method provided in the response. You should include a copy of your original request, our response, and a detailed explanation of why you are seeking reconsideration. You may also attach any additional supporting information and documents that you believe are relevant. We will review your appeal and provide a final determination within 60 days.
We implement recognized physical, technical, and organizational safeguards tailored to protect the confidentiality, integrity, and availability of the specific categories of personal data we collect and process. These safeguards are designed to prevent unauthorized or unlawful access, destruction, loss, alteration, or disclosure of your personal data. However, despite our best efforts, no controls can provide absolute protection against all security threats, and we cannot guarantee that unauthorized access or loss will never occur. We have procedures in place to deal with any suspected data security breach. We will notify you and/or any applicable regulator of a suspected data security breach where we are legally required to do so in accordance with any legally prescribed timeframes.
MBK’s primary operations are based in the United States, and as such, the majority of data processing occurs within the United States. To facilitate our international operations for the purposes of providing our Services, we transfer of your personal data across different locations, including countries other than the one where the information was originally collected. We implement appropriate measures to ensure that your personal data remains protected and secure during these transfers, including by adopting approved certifications, codes of conduct, or contractual clauses specific to the data transfer.
Our Services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect personal data from children. If you are a parent or guardian and believe that your child has provided us with personal data, please use our Contact Information. If we become aware that we have collected the personal data of a child, we will take steps to promptly delete such information.
12 Updates to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, services, or legal obligations. Any modifications will be effective upon the date specified in the updated Privacy Policy. If we make material changes to this Privacy Policy that significantly affect your rights or the way we use your personal data, we will notify you through the most appropriate channels. Generally, this will be done by updating the date at the top of this page. However, other notification methods may include sending an email to the address you have provided, posting a notice on our Services, or other methods as required by law. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
We will indicate the date of the last revision at the top of this Privacy Policy. We encourage you to periodically review this Policy to stay informed about how we are protecting your personal data.
This section is tailored to meet the specific requirements imposed by California law. While this section outlines state-specific rights for California residents, the preceding sections of this Privacy Policy also apply to them.
13.1 Additional Notice to California Residents
California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the privacy policy.
Description of Information Practices Regarding CCPA-Defined Categories of Personal Information | ||||
Category | Examples | Collected | Disclosed for a Business Purpose | Shared for Cross-Context Behavioral Advertising |
Identifiers | A real name, alias, postal address, unique personal identifier (e.g., employee ID), online identifier, Internet Protocol address, email address, driver’s license number, passport number or other similar identifiers. | ✔ | ✔ | ✔ |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Personal information can exist in various formats, including, but not limited to, physical formats, digital formats, and abstract digital formats, as each term is defined in Cal. Civ. Code § 1798.140(v)(4). | ✔ | ✔ | |
Protected classification characteristics under California or federal law | Age (40 years or older), citizenship, marital status | ✔ | ✔ | |
Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | ✔ | ✔ | |
Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data | |||
Internet or other similar network activity | Browsing history, information on a consumer’s interaction with a website, application, or advertisement. | ✔ | ✔ | ✔ |
Geolocation data | Physical location or movement. | ✔ | ✔ | ✔ |
Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | |||
Professional or employment-related information | Current or past job history or performance evaluations. | ✔ | ✔ | |
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | |||
Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | ✔ | ✔ | ✔ |
Sensitive Information | Government identifiers (social security, driver’s license, state identification card, or passport number); complete account access credentials (usernames, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; mail, email, or text message contents, genetic data; and neural data. | ✔ | ✔ |
For a comprehensive understanding of the types of personal information we collect, the sources from which we collect it, and the purposes for which we use it, please refer to the “Information Collected and How We Use It” section of this Privacy Policy.
13.2 California-specific Privacy Rights
California law grants rights specific rights to California consumers regarding their personal information. Note that these may be duplicative of the rights described above in “Your Privacy Rights” They are as follows:
To exercise your California privacy rights, please visit this web form or use the contact methods described below. We may request specific information from you to help us confirm your identity and your rights. 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 verify your identity, 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.
You have the option to designate an authorized agent to submit requests on your behalf for exercising your data rights. An authorized agent can be either a person or a business entity that you have formally authorized to act on your behalf.
To use an authorized agent:
Please note that we reserve the right to deny requests from agents who do not provide proof of authorization or if we cannot verify the agent’s identity.
If you have any questions or concerns about this Privacy Policy or our data practices, you can reach out to us through the following means:
Toll-Free Telephone: (855) 914-1987 (U.S. only).
Email: privacy@MBK.com.
Submit Your Privacy Rights Request: Consumer Request Form