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”).

OVERVIEW

These Sites are owned and operated by Manny Khoshbin, LLC (“Manny Khoshbin”), a California Limited Liability Company with offices at 18071 Fitch Suite 100, Irvine, CA 92614. This Privacy Policy (the “Policy”) applies to information collected on the Sites and any Site accessed via a user’s computer, mobile, e-reader, tablet or other device (“Device”) used to access the Device, and Applications (as defined in the Terms) and Sites affiliated with Manny Khoshbin products and services, that link to this Policy (collectively, the “Devices”). This Policy is incorporated into and subject to the terms of use and conditions (“Terms”) for these Sites. Each time that you access or use the Devices, you signify that you have read, understand and agree to be bound by the Terms and this Policy. If you do not agree to the Terms and this Policy, you must discontinue using our Devices. From time to time, Manny Khoshbin may update its Policy. Manny Khoshbin will post the new Policy with a new effective date to notify you of these changes. If you are concerned about how your information is used, you should check back to this Policy frequently for updates. By accessing the Devices after the Effective Date, you are deemed to consent to Manny Khoshbin’s then-current Policy.

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.

PART I – MANNY KHOSHBIN SITE PRIVACY 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:

• What information does Manny Khoshbin collect?
• What are “cookies” and how does Manny Khoshbin use them?
• Does Manny Khoshbin share information with third parties?
• How does Manny Khoshbin use the collected information?
• How can you review and modify your Personal Information?
• What is the opt-out policy for the Sites?
• California privacy rights
• What types of security procedures are in place to protect against the loss, misuse or alteration of your information?

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:

• Membership Applications: You are sharing Personal Information with Manny Khoshbin when you join or renew your membership through the Sites. Manny Khoshbin members will have Manny Khoshbin membership log-in credentials which enable members to take advantage of restricted content and features on the Sites.
• Other Registration: When registering for specific services Manny Khoshbin may ask for the same type of Personal Information. For example, if you subscribe to an e-mail newsletter, we will ask you to provide your e-mail address.
• Online Purchases: When you make a purchase of Manny Khoshbin course[s] through the Sites, Manny Khoshbin may also ask for the same type of Personal Information. The number and variety of useful products and services on the Sites may require the collection of Personal Information.
• Email Newsletters: When you sign-up to receive Manny Khoshbin email information newsletters, Manny Khoshbin may require that you supply your name, email address and other information.

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

• (i) When you provide Personal Information about you on the Sites to register for a service, buy a product, or take advantage of a promotion Manny Khoshbin will share such Personal Information as necessary to the complete the transaction requested by you. Manny Khoshbin also reserves the right to sell or otherwise provide to selected third parties, mailing or information lists derived from such registrations. These third parties may contact you directly regarding their products and services. 
• If you wish to opt out of the sale or distribution of such lists to third parties at any time, you may do so by following the directions in Item 5 below.

• Information provided when joining or renewing membership in Manny Khoshbin. If you join or renew your membership through the Sites, you provide Personal Information about you on the membership application. Manny Khoshbin will share such Personal Information as necessary to complete the transaction requested by you. Manny Khoshbin also reserves the right to sell or otherwise provide mailing/information lists concerning members to selected third-parties.
• If you wish to opt out of the sale or distribution of such lists to third parties at any time during your Manny Khoshbin membership, you may do so by following the directions in Item 5 below.

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

• to carry out Manny Khoshbin’s obligations arising from your membership, and any other agreement entered into between you and Manny Khoshbin
• to update and renew your membership as required
• to provide you with the information, products and services you request from Manny Khoshbin
• to arrange and deliver conferences, events and programming relevant to your subjects of interest
• to respond to your questions and provide related membership or customer services
• to improve the Sites
• to send you Manny Khoshbin publications, information about member benefits and special offers, and other information that Manny Khoshbin believes is relevant and useful to its members, where you have not opted out of receiving such information; we may automatically process your information to determine which products and services may be of most use to you. You may object to such processing by sending an email to [email protected].
• to send you third party information that Manny Khoshbin believes is relevant and useful to you, where you have given your consent
• to notify you about changes to your membership or related services or to ask you to provide feedback
• to enable you to partake in a prize draw, competition or complete a survey
• to administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
• to comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities including in matters involving a danger to personal or public safety, or to protect the rights, property or safety of Manny Khoshbin members, customers or others, Manny Khoshbin may voluntarily provide information to appropriate governmental authorities.

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:

• Send an e-mail to: [email protected]
• Send mail to the following postal address: 18071 Fitch Suite 100, Irvine CA 92614.

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:

• Send an e-mail to: [email protected]
• Send mail to the following postal address: 18071 Fitch Suite 100, Irvine CA 92614.

Effective January 1, 2020, if you reside in California you have the following rights:

• You have the right to opt-out of Manny Khoshbin’s sale of your Personal Information.
• You have the right to request the deletion of your Personal Information.
• You have the right to request us to disclose to you the following, no more than twice in a 12-month period:
• Categories of Personal Information collected about you during the preceding 12 months.
• Categories of sources from which Manny Khoshbin collected the Personal Information during the preceding 12 months.
• Business or commercial purpose(s) for collecting or selling your Personal Information during the preceding 12 months.
• Categories of third parties with whom we share the Personal Information during the preceding 12 months.
• Specific pieces of Personal Information we collected about you during the preceding 12 months.
• Categories of Personal Information we have sold and categories of third parties to whom the information was sold to during the preceding 12 months.
• Categories of Personal Information we disclosed about you for a business purpose during the preceding 12 months.

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:

• collects the following categories of personal information: identifiers; payment information; commercial information; internet of other electronic network activity information; geolocation data; audio, electronic or visual information.
• discloses the following categories of personal information for a business purpose: identifiers; payment information; commercial information; device information; and demographic information.
• sells the following categories of personal information: Identifiers; payment information; event information; demographic information; device information; location information; commercial information; internet or other network activity information.

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:

• Cookies: “cookies” give users a special ID, which are small text files that are stored in the memory of a user’s Devices used to access the Applications. Manny Khoshbin employs cookies to recognize you and your access privileges for certain locations on the Devices as well as to track site usage. Subscribers who do not accept cookies from the Devices cannot access many areas of the Devices. We use both “session ID cookies” and “persistent cookies.” Session ID cookies are used to store information while a user is logged into the Devices and expires when the user closes his/her browser. Persistent cookies are used to make tasks like logging into the Devices easier for returning users by remembering a user’s login information. Persistent cookies stay on a user’s hard drive from one session to the next.
• Web Beacons: Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Devices, to monitor how users navigate the Devices, to count how many emails that were sent were actually opened or to count how many particular articles or links were actually viewed.
• Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Devices, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Devices, and is deactivated or deleted thereafter.
• HTML5: We may use HTML5 in the Devices, including without limitation in Manny Khoshbin mobile websites and certain mobile applications for the iPhone or iPad (and any other Apple iOS device). HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies are not stored in a browser “cookies” file and, like Flash cookies, can be used to track users across websites. We are currently unaware of a way for a user to disable local storage while simultaneously leaving cookies enabled.
• E-tags/cache browsers/web logs: Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and Device identification in order to improve security, analyze trends and administer the Devices. We may track your movement within the Devices, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our Devices, the operating system of your computer, the unique IP address of the computer or Device identification from the Device that you used to access our Devices and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Devices, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather information. We may also use individual information we collect through web logs to send you targeted offers and other communications.

PART II – MANNY KHOSHBIN PRIVACY POLICY FOR INFORMATION
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:

• The “cookies” and other tracking devices used by the Sites and described in Part I above do not apply to Personal Information gathered through channels other than the Sites.
• Hardcopy Personal Information provided to Manny Khoshbin which is not converted to electronic media or hosted by Manny Khoshbin will be subject to different security procedures than electronically stored Personal Information. Manny Khoshbin has security measures equal to or better than those reasonably expected in the industry, in place to protect against the loss, misuse and alteration of your hardcopy Personal Information under Manny Khoshbin’s control.
• When Manny Khoshbin collects Personal Information through channels other than the Sites it may in some instances apply a different privacy policy to such information; but where it does so it shall conspicuously disclose to you at the time of collection what policy will apply 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.

QUESTIONS
If you have any questions or complaints regarding this Policy or the Sites, please contact Manny Khoshbin at [email protected].