Effective Date:  July 21, 2020

This privacy policy (“Privacy Policy”) describes how BBR Partners, LLC and its affiliates (collectively, “BBR”) protects the privacy of personal information of users of our website (the “Site”).

By using the Site, you consent to the collection and use of your personal information by BBR in accordance with this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use the Site.

If we decide to change our Privacy Policy, we will advise you of the changes through postings on our Site.  Your continued use after we provide notice will mean that you accept the changes.

What does this Privacy Policy cover?

This Privacy Policy covers how BBR treats personal information that it collects and receives through the Site.  Personal information is information that can identify you specifically (e.g., your name, address, e-mail address or phone number), including information related to you that is collected through our Site and identified with those identifiers.  For California residents, personal information is broadly defined to include, among other things, nearly all information that reasonably can be directly or indirectly linked to an individual or household.  In all cases, personal information does not include deidentified information, aggregate information that cannot be linked to a particular individual, or pseudonymized information.

Personal Information – What we Collect and Why, and Sharing

For the 12-month period prior to the date of this Privacy Policy, the table below shows the categories of information we have collected, the purpose for the collection and, if the information was shared, with which categories of categories of third parties.


We will continue to collect the same categories of information and for the same purposes as listed in the chart above.  We also in the future may use the information we collect from you in the following ways:

  • To respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
  • To investigate, prevent, or take action regarding alleged or actual illegal activities, violations of agreements with BBR, or as otherwise required by law.
  • To comply with applicable laws and regulatory requirements, including laws pertaining to taxes on sales.
  • To administer a promotion, survey or other Site or services feature.
  • We may also share information about you for any other purposes disclosed to you at the time we collect your information or with your consent.

Sharing with Third Parties in the Future.  We will continue to share information with third parties, as listed in the chart above.  We may also release your personal information when we believe release is appropriate to comply with the law, enforce our policies, or protect ours or others’ rights, property, or safety.  In addition, we may choose to buy or sell assets.  In these types of transactions, customer information is typically one of the business assets that are transferred.  If BBR, or substantially all of its assets were acquired, or in the unlikely event that the company goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party.  You acknowledge that such transfers may occur, and that any acquirer of BBR or its assets may continue to use your personal information as set forth in this policy.

Source of Personal Information.  We collect personal information that you provide to us.  We also collect personal information from third parties, including from advisors, vendors and publicly available sources.  We also may automatically collect certain information about the devices you use to access our Site, as well as information on how you interact with the Site, through cookies, web server logs, and other similar tracking technologies.

We use Google Analytics to monitor activity on our Site. To learn how Google Analytics collects and processes data, please visit, “How Google uses data when you use our partners’ sites or apps” available at: https://www.google.com/policies/privacy/partners/.

No Sales of Personal Information

We have not sold personal information to third parties during the 12 months prior to the Effective Date of this Privacy Policy, and do not plan to do so without further notice (with the exception of a sale in connection with the sale or transfer of the business or our assets, as noted in the section above about sharing).


If you are under 18, you should always get permission from your parents before providing any personal information (such as your name or email address). We do not knowingly allow anyone under the age of 13 provide personal information to us.

Do we use “cookies” or other tracking technology?

We may use cookies. Cookies are small files that a Site or its service provider transfers to your computer’s hard drive through your browser (if you allow) that enables the Site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we may use cookies to help us remember items you have searched for in the past. Cookies can also help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding visitors to our Site. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (such as Chrome, Safari, Mozilla Firefox, Internet Explorer or Edge) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to features that make your Site experience more efficient and some of our services may not function properly, and registered users may not be able to login properly.

We (and our third party service providers) may also use technologies such as beacons, scripts, tags and clear gifs. These technologies may be used to analyze trends, administer our Site, track users across the Site, and gather demographic information about our user base on the whole. We may receive reports based on the use of these technologies on an individual and aggregate basis.

“Do not track” signals / Collection of data across sites and over time

Some Internet browsers include the ability to transmit “Do Not Track” signals.  We do not process or respond to “Do Not Track” signals.  We do not intentionally allow other parties to collect personally identifiable information about your online activities over time and across different websites when you use the Site or our services.

Does this Privacy Policy cover third party links?

This Privacy Policy does not apply to third party links.  In an attempt to provide you with increased value, we may include third party links on our Site.  These linked websites have separate and independent privacy policies.  We therefore have no responsibility or liability for the content and activities of these linked sites.  Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these linked websites (including if a specific link does not work).

Does this Privacy Policy apply to offline or other information?

Except as provided below for California residents, this Privacy Policy applies only to information collected through our Site and not to information collected offline.

For California residents, this Privacy Policy applies to all personal information that we collect that can be linked directly or indirectly with you to the extent required under the California Consumer Privacy Protection Act (“CCPA”) and other California privacy laws.  It should be noted that most of the provisions of the CCPA do not apply to certain types of information, including information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.  We provide notices to customers and consumers as required by those laws separately.  We note also that all of the rights afforded to consumers under the CCPA do not apply to personal information collected in certain contexts (such individuals acting as job applicants, employees or contractors, or in business to business communications).

How do you ask questions and provide feedback?

If you have questions about this Privacy Policy or any feedback, please contact our privacy team at privacy@bbrpartners.com.

How do you review, correct or update personal information?

You can review, correct or update your personal information by contacting us by electronic-mail at privacy@bbrpartners.com or sending a written request to:

BBR Partners, LLC
Attention: Chief Compliance Officer
55 E 52nd St 18th Floor
New York, NY 10055

However, we will maintain copies of your information to the extent retained as part of our standard backup/archive process.  In addition, these procedures will not remove any of your information that you have provided to other users or third parties, or that has been collected from you by third parties linked from the Site.

Your California Privacy Rights

If you are a California resident, you have certain rights with respect to your personal information. Those rights and how you may exercise them are described below.  It should be noted that most of the provisions of the CCPA do not apply to certain types of information, including information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

Non-Discrimination.  Under the CCPA, you have the right to be free from discrimination for exercising your rights to know or delete.  We will not deny you products or services, charge you different rates, or give you different discounts because you used any of these rights.

Right to Know.  Under the CCPA, you may request that we provide you a list of the categories of personal information we have collected about you over the last 12 months, the categories of sources from which it was collected, the business or commercial purpose for collecting or selling the information, and the categories of third parties to whom we disclosed or sold that information.  You may also request that we provide you a copy of the specific pieces of personal information we have collected about you in the past 12 months.  You may make a request to know up to two times in a 12-month period, subject to limitations described in the law.  For a list of general categories of information that we have collected and shared in the past 12 months, see the table above.  This right does not apply to information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

Right to Delete.  Under the CCPA, you may request that we delete any personal information that we have collected from you, with the exception of information that the law allows us to keep.  When we respond to your request to delete, we will explain what (if any) information we have kept and why.  This right does not apply to information that is subject to protection under the Gramm-Leach-Bliley Act and its implementing regulations, other applicable federal laws or regulations or the California Financial Information Privacy Act.

How to Make a Request to Know or Delete.  Under the CCPA, you or your authorized agent may make a request to know or delete by (i) emailing: request_to_know_or_delete@bbrpartners.com or (ii) submitting a written request in person or via mail to: BBR Partners, LLC, Attention: Chief Operating Officer, 55 E 52nd St 18th Floor, New York, NY 10055.  When you make a request, we will take steps to verify your identity before responding.  This is to protect your information.  At our discretion, such steps may include asking you to provide us your email and physical address.  If you maintain an account with us, these must match the address connected to your account.  We may then send you a physical letter to this address with a one-time code.  You must email us this code from the email address you provided to us.  Once you do, we will respond to your request.

Authorized Agent.  Under the CCPA, you may designate an authorized agent to make requests on your behalf.  We will require verification that you did, in fact, authorize the agent.  Unless the law requires otherwise, your authorized agent must provide contact details for you.  We will contact you to confirm that you authorized the agent.  Once you confirm, we will promptly respond to the rights request.

Right to Request Information About Disclosure for Direct Marketing Purposes. You may request information about our disclosure of personal information to affiliated companies for their direct marketing purposes. To make such a request, please email us at privacy@bbrpartners.com.  Please allow up to 30 days for us to process your request.  You may submit such a request once per year.