Manny Khoshbin is a real estate investment company that offers, among other things, mentorship membership programs and other educational opportunities through its various websites including mannykhoshbin.com, contrarianacademy.com, mannysmentorship.com, mannysuniversity.com, mannysmasterclass.com and realestatestartercourse.com (collectively the “Sites” or singularly the “Site”).
Part I of this Policy sets forth Manny Khoshbin’s policy as to Personal Information collected online through the Sites. Part II sets forth the Policy as to Personal Information collected other than from the Sites.
“Personal Information,” is any information that enables Manny Khoshbin to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. Personal Information includes “sensitive Personal Information” and “pseudonymised Personal Information” but excludes anonymous information or information that has had the identity of an individual permanently removed.
Your use of the Sites and/or provision of your Personal Information or sensitive Personal Information to Manny Khoshbin constitutes your consent to the use, storage, processing and transfer of that information in accordance with this Policy.
Throughout the Sites, there are forms for visitors to request information, products, and services. Manny Khoshbin uses Personal Information from these forms to provide the information and materials you request.
Forms on the Sites that request financial information do so in order to bill you for products or services ordered. Unique identifiers (such as your email) are collected from visitors to verify the user’s identity for access to restricted content or features on the Sites.
This Policy discloses Manny Khoshbin’s privacy practices and contains detailed information about the following:
1. What information does Manny Khoshbin collect?
Manny Khoshbin collects the following Personal Information about visitors to the Sites:
a) Use Information. Manny Khoshbin collects technical information relating to each time a visitor comes to the Sites, including IP address, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform type (e.g. Internet Explorer browser on a Windows platform).
Manny Khoshbin may also collect information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Gathering this technical information helps us to learn what browsers we need to support and helps us determine what sections of the Sites are most popular and how many visitors come to the Sites. You do not have to register with the Sites before we can collect this information.
b) Information Provided to Manny Khoshbin. You may provide Personal Information to us which may include your name, home and/or work email address, postal address, phone number and/or fax number, your employer and job title, demographic information about you including birth year and if you are making a purchase, your debit or credit card information. Such information is only required to take advantage of products and services provided through the Sites.
Manny Khoshbin collects Personal Information in the following ways from different parts of the Sites:
2. Do we share information with third parties? Personal Information collected through the Sites is generally collected and maintained solely by Manny Khoshbin. Manny Khoshbin may share Personal Information in the following ways:
a) Information You Give Manny Khoshbin
Manny Khoshbin does not sell e-mail addresses obtained from Manny Khoshbin member applications or renewals to third-parties.
b) Sensitive Personal Information. Manny Khoshbin does not share with third parties, sensitive Personal Information such as passcodes, social security numbers, debit or credit card numbers except as necessary to complete transactions requested by you or to comply with legal obligations, under strict confidentiality and security protections; nor does Manny Khoshbin publish such sensitive Personal Information.
3. How does Manny Khoshbin use the collected information? Manny Khoshbin uses your Personal Information according to the terms of the Policy in effect at the time of our use. We will only process your Personal Information, including sharing it with third parties, where (i) you have provided your consent which can be withdrawn at any time, (ii) the processing is necessary for the performance of a contract to which you are a party (including your membership with Manny Khoshbin), (iii) is required by law, (iv) processing is required to protect your vital interests or those of another person, or (v) processing is necessary for the purposes of Manny Khoshbin’s legitimate commercial interests, provided your interests and fundamental rights do not override those interests.
We use Personal Information for the following purposes:
a) Information You Provide to Manny Khoshbin
b) Data Information. As mentioned above, Manny Khoshbin uses the aggregate, anonymous data collected to let our sponsors or advertisers know the number of impressions or views and the number of “click throughs” on their advertisement(s).
Manny Khoshbin also uses this aggregate, anonymous data to perform statistical analyses of the collective characteristics and behavior of visitors to the Sites; to measure user interests regarding specific areas of the Sites; and to analyze how and where best to use our resources.
Without such data, we would not know which parts of the Sites are the most popular, and we would not be able to change and update the content and services appropriately.
c) Exceptions. On occasion Manny Khoshbin collects Personal Information through the Sites with the intent to afford a greater degree of privacy for such information than is otherwise set forth in this Policy.
In those relatively rare situations where Manny Khoshbin does so it will clearly disclose to you at the time it collects such information, what degree of privacy will be afforded to the Personal Information collected at such time; and Manny Khoshbin will follow a process to assure that the specifically disclosed degree of privacy is in fact afforded to such information.
For example, Manny Khoshbin may collect information through a survey where Manny Khoshbin’s use of any Personal Information from that survey is more limited than the general Policy would otherwise allow; in such a case, Manny Khoshbin will disclose the stricter Policy governing that survey information at the time such Personal Information is collected from the survey respondent.
4. How can you review and modify your Personal Information? You have the following options for modifying or causing to be deleted Personal Information or demographic information previously provided by you to Manny Khoshbin by sending an email to: [email protected].
5. What is the opt-out policy for these Sites? Manny Khoshbin provides members and customers with the opportunity to opt-out of receiving communications from Manny Khoshbin. If you no longer wish to receive specific communications or services, you have the following options:
6. California Privacy Rights and California Consumer Privacy Act (CCPA) of 2018. Manny Khoshbin may disclose your Personal Information to its subsidiaries or other third parties who may use that information to market directly to you. As a California resident, you have the right to opt-out of having your Personal Information licensed to such third parties. Manny Khoshbin will not share your information after Manny Khoshbin has received your notification that you are opting out. If you wish to opt-out you have the following options:
Effective January 1, 2020, if you reside in California you have the following rights:
Manny Khoshbin will not discriminate against you because you exercised your rights under this section.
For purposes of exercising your rights above, please note the following regarding how Manny Khoshbin collects and use your Personal Information as described in this Notice:
7. What kinds of security procedures are in place to protect against the loss, misuse or alteration of your information? The Sites have security measures equal to or better than those reasonably expected in the industry, such as firewalls, in place to protect against the loss, misuse and alteration of your Personal Information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur Manny Khoshbin takes reasonable precautions to prevent such unfortunate occurrences. Certain particularly sensitive information, such as your credit card number, collected for a commercial transaction is encrypted prior to transmission.
You are ultimately responsible for the security of your Manny Khoshbin login credentials. You may not share your Manny Khoshbin login credentials with colleagues or friends. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personal Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe.
8. Tracking Technologies. Manny Khoshbin may employ the following tracking technologies on its Applications:
COLLECTED OTHER THAN THROUGH THE SITES
The same rules set forth in Part I above for the Sites will be applied to such Personal Information you submit through channels other than the Sites (including without limitation your opt-out rights in Part I, Section 5 above), except as follows:
If you have any questions or complaints regarding this Policy or the Sites, please contact Manny Khoshbin at [email protected].