Privacy Policy

Effective Date: January 1, 2020
Last Updated: February 12, 2020

Introduction

The Wolff Company, LLC, its parents and affiliates (collectively, “The Wolff Company,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website, www.awolff.com (the “Site”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically. Your continued use of the Site after any such amendment signifies your acceptance thereof.

Collecting and Using Information

Personally Identifiable Information We Collect Online

Through your use of the Site, we may collect Personally Identifiable Information from you. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

Contact Us. If you complete the Contact Us webform on our Site, you will provide us with your first and last name and email address and any additional Personally Identifiable Information that you choose to provide in the “message” field.

Investor Portals. If you have an online investor account, you may provide Personally Identifiable Information including your email address. We use third-party processors to power our investor portals.

If you apply for a job, you will provide us with your first and last name, email address, telephone number, postal address, postal address, employment and education-related information, and any additional Personally Identifiable Information that you choose to provide. We use third-party processors to power our career listings and application submissions.

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site, such as the following:

Usage Information. We collect information automatically through your use of the Site and Services, such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.
Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.
Location Information. We collect location information from Site visitors on a city-regional basis.

Third-Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, when you complete the “Contact Us” form available on the Site, you may provide information about another individual. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to contact you, improve our Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

Provide support;
Maintain and improve our Site;
Defend our legal rights and the rights of others;
Efficiently maintain our business; and
Comply with applicable law.

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

With service providers who perform data services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.).
To the extent that we are required to do so by law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
To any other person or entity as part of any business or asset sale; and
To any other person or entity where you consent to the disclosure.

Cookies and Other Tracking Technologies

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

Estimate audience size and usage patterns; and
Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future.

We set Cookies ourselves, which are required for the Site to function properly. Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You can understand which third parties 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.

Third-Party Processors

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personally Identifiable Information with to ensure that your Personally Identifiable Information is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use service providers to power our investor account portals and to process career application transactions.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Security

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

Third-Party Links

The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired on this Site. We accept no responsibility or liability for these other websites.

Children’s Privacy

The Site is not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 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 privacy@awolff.com.

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.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is publicly available, deidentified or aggregate information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

Specific pieces of Personal Information that we have collected about you;
Categories of Personal Information we have collected about you;
Categories of sources from which the Personal Information was collected;
Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
The business or commercial purpose for collecting or, if applicable, selling 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.

How to Submit a Request to Know

You may submit a request to know through our interactive webform available here, by emailing us at privacy@awolff.com, or by contacting us toll-free at 1-800-505-1381.

Our Process for Verifying a Request to Know

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information

The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

Categories of Personal Information Collected	Categories of Sources from which Personal Information was Collected	Business or Commercial Purpose for the Collection	Categories of Third Parties with whom We Share Personal Information
Name	§ Site visitor § Investor	§ Providing customer service § Performing services § Verifying investor information	§ Service provider
Email address	§ Site visitor § Investor	§ Providing customer service § Performing services § Verifying investor information	§ Service provider
Telephone number	§ Investor	§ Providing customer service § Performing services	§ Service provider
Postal address	§ Investor	§ Performing services § Verifying investor information	§ Service provider
Bank account number	§ Investor	§ Performing services § Verifying investor information	§ Service provider
Social security number	§ Investor	§ Performing services § Verifying investor information	§ Service provider
Internet protocol address	§ Site visitor	§ Providing analytic services	§ Data analytics providers
Cookies, beacons, pixel tags, or other similar technology	§ Site visitor	§ Providing analytic services	§ Data analytics providers
Information re consumer’s interaction with website	§ Site visitor	§ Providing analytic services	§ Data analytics providers

Disclosure or Sale of Personal Information

We have not sold to third parties any Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

Name
Email address
Telephone number
Postal address
Bank account number
Social security number
Internet Protocol Address
Cookies, beacons, pixel tags, or other similar technology
Information re consumer’s interaction with website, application or advertisement

We do not sell the Personal Information of minors under 16 years of age without affirmative authorization.

Right to Request Deletion of Personal Information

Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete

You may submit a request to know through our interactive webform available here, by emailing us at privacy@awolff.com, or by contacting us toll-free at 1-800-505-1381.

If you submit a request to delete online, you will be asked to confirm separately that you want your Personal Information deleted.

Our Process for Verifying a Request

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Notice of Right to Opt-Out of Sale of Personal Information

Your Right

If you are a California resident, you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

We do not and will not sell Personal Information as it is defined in the CCPA.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know or delete on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission and (2) you verify your identity directly with us. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

Shine the Light Law

We do not disclose personal information obtained through our Site to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

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 alternative format, please contact us as described below.

How to Contact Us

For questions or concerns about our privacy policies or practices please contact us at:

The Wolff Company II, LLC
6710 E. Camelback Rd., Suite 100
Scottsdale, AZ 85251

Email: privacy@awolff.com