Privacy Policy

DJR Companies values the privacy of the visitors to its website djrcompanies.com (“Website”) and the users of the services provided thereon (individually, “User” or “you”, and collectively, “Users”), and makes it a priority to protect any personally identifiable information it obtains from its Users. This Privacy Policy explains DJR Companies’ collection, use, and protection of your personal information on and in connection with the djrcompanies.com website (“Website”) and all content, services and/or products provided through the Website (collectively, the “Services”). If you have any questions that this policy does not address, please contact us (https://www.djrcompanies.com/contact).

By accessing the Services, registering as a user, using our Service or by otherwise submitting your personal information to us, you give your consent to the collection and use of personal information as explained in this policy. The term “personal information” refers to non-public information that personally relates to or identifies you (such as your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, and other similar information). Non-personally identifiable information collected on the Website may include, without limitation, website pages viewed, sites visited before visiting the Site, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, presentations viewed, time spent viewing pages of our website or using certain features of our website, demographic data such as server locations, clickstream data, location services, server location, cookies existing on your computer, search criteria used and results, date and time of access or visits to our website, frequency of visits to our website, connection speed, and other information which does not specifically identify you.

Our Commitment

We are required by law and regulatory bodies to ask for certain information in order to provide our Services to you. DJR Companies makes commercially reasonable best efforts to maintain the confidentiality, integrity and security of our clients’ personal information. Keeping client information secure, and using it only as our Users want us to, are matters of principle for all of us at DJR Companies. With this in mind, here is our commitment to our Users:

Except as you may otherwise expressly approve, we will limit the collection and use of client and user information to what we believe would be useful to service your accounts, administer our business, or to: Tell you about our Services; We will restrict employee access to client and user information to those who need to know in order to provide Services to you; We will educate our employees according to our internal policies to reinforce the importance of confidentiality and client and user privacy; We will maintain commercial reasonable and customary security standards and procedures to protect information about you; We will respond quickly to your request to correct inaccurate information.

Updates and Changes to Privacy Policy

In the event of a change in this policy, a revised Privacy Policy will promptly be posted to our Website, and the “Updated” date will be changed. If the revised Privacy Policy contains a material change to how we collect or use personal information, notice of the change will be emailed to you or posted on the Website’s home page. Please revisit this page to familiarize yourself with changes to the Privacy Policy. You agree to accept posting of a revised Privacy Policy as described herein as actual notice to you of such revised Privacy Policy. Your continued use of the Services after such posting constitute to the collection and use of your information as described in the then-current Privacy Policy.

How and Why We Gather Information

When you register for an account for the Services or at any later time, we collect certain personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your “Profile.” From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences. If you choose to provide such information, during registration or otherwise, you are giving DJR Companies the permission to use and store it consistent with this Privacy Policy. We may also obtain your personal information from your transactions with us or other Users through the Services, or from third parties such as credit reporting agencies. If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with the Services, we will treat the combined information as personal information in accordance with this Privacy Policy.

When you visit the Website, whether or not you register for an account, we may send one or more cookies. “Cookies” are small text files containing a string of alphanumeric characters that may be placed on your web browser. Cookies make it easier for you to navigate our Website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between webpages on the Website and/or as you access the Services. This use of cookies for authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set or to prevent cookies from being set. A “web beacon” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server. Please note that if you decline to use cookies, you may experience reduced functionality or slower site response times. Declining to use our authentication-related cookies may prevent you from using the Website altogether.

We or our service providers may also collect web surfing data related to your use of the Services (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences). This may be accomplished by using cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Web surfing data and similar information may be used: for administrative purposes; to assess the usage, value and performance of our online products and services; and to improve your experience with the Services.

How Information Helps Both You and Us

DJR Companies’ mission is to provide you with exceptional investment opportunities to match your individual investment goals. Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business. For example, we use information about you to: Provide you with the Services available through the Website; Establish and set up your account, issue an account number, and maintain your transaction history; Respond more accurately and efficiently to your requests; Identify opportunities to give you more convenience and control by developing new services that may benefit you; Verify your identity and contact information to help protect you and DJR Companies from fraud; Comply with certain legal and regulatory requirements.

We generally use the information that you provide or that we collect to establish and enhance our relationship with you, and to operate, maintain, enhance, and provide the Services and the Website. We may use such information to periodically provide you with information, newsletters or offers about features and services available through the Services that may be of interest to you. We may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will have the option to opt out of receiving such information.

We use aggregated information provided by or collected from our Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Services and the Website work and look, and to create new features and functionality. We may use aggregated information about our Users’ investments to generate statistics and maps that we deem helpful in the provision of the Services or any part thereof. We do not and will not sell analytics about our users without written consent from the user.

As you browse DJR Companies and other websites, online ad networks we work with may place anonymous cookies on your computer, and use similar technologies, in order to understand your interests based on your (anonymous) online activities, and thus to tailor more relevant ads to you. If you do not wish to receive such tailored advertising, email your request to dlambert@djrcompanies.com to opt out of most companies that engage in such advertising. (This will not prevent you from seeing ads; the ads simply will not be delivered through these targeting methods.)

How and Why DJR COMPANIES Discloses Your Information to Third Parties

We limit the sharing of personal information outside DJR Companies. We do not sell, license, lease, or otherwise disclose your personal information to third parties, except as noted below:

We may disclose your personal information when such disclosure illegally required or appropriate pursuant any court orders, subpoenas or any regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies, and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.

To help us improve our Services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business. Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing, and companies that perform reporting, tax documentation, custody, title or escrow services on our behalf. Use of any personal information we share with these third parties is limited to the performance of the task we request. The third parties with which we share personal information are required to protect it in a manner similar to the way we protect your personal information.

If you indicate an interest in making an investment through Services, we will notify the Issuer of your interest and will provide your personal information to the Issuer.

To engage in any other lawful activities we believe are consistent with this Privacy Policy and the Services.

You may elect to share your User Content (as that term is defined in the Terms of Service http://www.djrcompanies.com/terms-of-service) with other Users. Any personal information that you choose to include in, or that is associated with, your User Content will be accessible by other Users. Once you make your personal information available to others in any of these ways, it may be collected and used by the recipients without restriction.

We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or that you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.

In the event that DJR Companies is acquired by or merged with a third-party entity, it reserves the right to transfer or assign the information that it has collected from its Users as part of such merger, acquisition, sale, or other change of control. In such cases, DJR Companies will provide you notice before your personal information is transferred to and becomes subject to the privacy policy of a different entity.

We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

We further reserve the right to disclose any of your personal information as we believe appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Services, or to protect the rights, property or personal safety of DJR Companies, its Users, Issuers, or others.

DJR Companies may also use and disclose personally identifiable information and non-personally identifiable information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our website or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of DJR Companies’ business or assets. Any successor in interest to our business would acquire the information we maintain, including personally identifiable information, and may alter the terms of this Privacy Notice. DJR Companies does not and will not sell any of your information, including non-personally identifiable or personally identifiable information, to any third party for purposes of advertising, soliciting, or telemarketing. We may, however, have to disclose your information, including non-personally identifiable information or personally identifiable information, to other companies or entities in the event that DJR Companies may be sold or is sold to another company or entity. In that case, your information, including personally identifiable information and non-personally identifiable information, may be sold or transferred to such acquiring company or entity.

Our Privacy Policy Does Not Apply to Third-Party Activities or Sites

The Website may provide links to third-party websites for your convenience and information. If you access those links, you will leave the DJR Companies Website. Any information submitted by you to a third party, including Issuers, will be controlled by that third party’s privacy policy, which may differ from DJR Companies’. This Privacy Policy does not cover the collection of information by cookies or other methods by such third party services or other third parties, such as our business partners. We do not control how these third party services or third parties collect information or by what means such third party services or third parties may use their own cookies to collect information about you. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services. We encourage you to review the privacy policy of any company before submitting your personal information.

Keeping Information Safe

We limit access to your personal information to those employees who have a legitimate business need to access such information to provide you with the Services. In keeping with industry standards and practices, we maintain commercial reasonable physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.

Users are required to identify and authenticate themselves prior to accessing restricted portions of the Services. Generally, identification and authentication take place through the use of your user name and a password and/or while logging in with one of our technical support staff. You are responsible for keeping your password confidential.

We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, notify us (http://www.djrcompanies.com/contact) immediately.

The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Opt-out Policy

We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at: dlambert@djrcompanies.com.

Please note that opt-out requests may take up to twenty-four (24) hours to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other login information by visiting your account’s settings page subject to our website policy. If you wish to delete your account or need help modifying account information, please contact us at dlambert@djrcompanies.com. We will require up to twenty-four hours (24) to process such requests.

Through your account settings you will be able to set certain preferences and permissions regarding the visibility of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to others. You may stop or restrict the placement of DJR Companies’ cookies, Google’s cookies and third party cookies on your computer by adjusting your web browser preferences or a “Do Not Track” setting in your web browser. If you do so, you may still use our website, but this may interfere with some of its functionality.

You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at: http://support.google.com/analytics/bin/answer.py?hl=en&answer=270
0409.

If you would like us to remove your Personally Identifiable Information from our database, please send a request to: dlambert@djrcompanies.com.

We are not responsible for removing your Personally Identifiable Information from the lists of any Third Party Services or other third party who has previously been provided your information in accordance with this notice.

Reviewing, Changing or Correcting Information

You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us (http://www.djrcompanies.com/contact).

You may, of course, decline to share any or all of your personal information with us or ask us to delete your personal information from our systems at any time, in which case we may not be able to provide to you some of the features and functionality found on or through the Website and the Services.

An Ongoing Commitment to Your Privacy

We are committed to protecting the privacy of our former clients as well as our current clients. If you choose to become an inactive client, you will continue to be protected by the policies and principles described in this Privacy Policy for as long as your personal information is retained by us. Should you close your account with us, we will only retain your personal information for as long as necessary to comply with any applicable legal or regulatory requirements.

Our Commitment to Children’s Privacy

DJR Companies does not knowingly collect personal information on or through the Services from persons under 13 years-of-age without their legal guardian’s consent. If DJR Companies learns that personal information has been collected from persons under 13 years-of-age through the Services without their legal guardian’s consent, then DJR Companies will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the Services or DJR Companies has received any personally identifiable information of that child without your consent, you may alert DJR Companies by contacting us (http://www.djrcompanies.com/contact).

International Visitors

The Services may be accessed and/or used by Users located outside the United States in accordance with our Terms of Use and other policies and procedures posted on the Website. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States and by providing your personal information on or through the Services you consent to that transfer.

Children’s Privacy Policy

The DJR Companies website is not intended for use by children, especially those under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the website, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children under the age of thirteen (13) or anyone under eighteen years of age. If you believe that a minor has disclosed Personally Identifiable Information to DJR Companies, please report this to us immediately by emailing us at: dlambert@djrcompanies.com.

Applicable Law and Jurisdiction

This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of California applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the California State Courts located in San Diego, California, or the federal district court for San Diego, California. You consent to the in person jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

Contact Information

Please contact DJR Companies with any questions or comments about this Privacy Policy, your personal information, or your choices with regards to our collection and use of your personal information, by completing our contact form (https://www.djrcompanies.com.com/contact) or email directly to dlambert@djrcompanies.com.