Privacy Policy

Privacy Policy

Breakthrough Properties (“Breakthrough”, “we”, “us”, or “our”) is committed to protecting the privacy of personally identifiable data (“personal data”) of identifiable individuals who visit btprop.com (the “Site”) and inquire about or use services associated with our business available through our Site (the “Service/s”), or express interest in our business. The privacy of your personal data is important to us at Breakthrough. This Privacy Policy discloses the privacy practices for Breakthrough and for its Site, and localized versions of that site, including the type of personal data collected and tracked, how the data is used, and with whom the data is shared. 

In order to provide you with Services you may request, it is necessary for us to possess some personal data of yours. Similarly, without some of that data, we cannot inform you about the Services we have available or that you may request (though if you are currently receiving marketing communications from us, you may opt-out of receiving further communications at any time). This Privacy Policy explains our personal data policies and practices. It includes, but is not limited to, explanations of the types of personal data we may collect about you, the purposes for collecting such data, the circumstances under which we may disclose such data to third parties, the measures we take to secure the confidentiality of such data, your rights regarding your personal data, and the way to contact us to exercise those rights.

Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments.

Types of Data We Collect

We collect personal data about you in connection with providing our services to you. This information may include your name, date of birth, address and other contact details, national identification or social security number, identity documents such as passports and other “know your client” documents and may also include other information such as:

Category of Information Collected

Examples 

Personal Identifiers

A real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. 

Personal data 

A name, signature, Social Security number, address, telephone number, passport number, driver’s license, or state identification card number. Some personal data included in this category may overlap with other categories. 

Characteristics of Protected Classes 

Age, national origin, citizenship, marital status.

Employment Information

Professional or employment related information. 

Internet or Other Similar Network Activity

Website activity, traffic data, location data, logs and other communication data, IP address, operating system, browser type, mobile ad identifiers, cookies.

 

Sensitive Personal Data

Subject to the relevant jurisdictional regulatory requirements, we may process sensitive personal data. We will only use and disclose sensitive personal data for a purpose for which it was originally collected. Unless we request it, we ask that you not send us, or disclose, any sensitive personal data. 

Within the last twelve (12) months, we have collected and processed the following categories of sensitive personal data:

  • The contents of an individual’s mail, email, and text messages unless the business is the intended recipient of the communication.
  • An individual’s precise geolocation;
  • The contents of an individual’s mail, email, and text messages unless the business is the intended recipient of the communication.

How We Gather Personal Data

We obtain personal data directly from you, when you apply for, access and use our and our business associates’ financial products and services – whether in person, by telephone or electronically. We may verify this personal data or collect additional personal data from third parties, including consumer reporting agencies or other public sources.

We may also obtain some of your information indirectly, from a variety of sources, such as your joint account holder(s), and / or our service providers, such as vendors providing anti-money laundering and sanctions checking databases.

Purposes for Collecting Your Personal Data

You may provide your personal data to Breakthrough in order to fulfill a Service. You are then entering a business relationship with Breakthrough and are agreeing to the use of that data by Breakthrough and its applicable worldwide affiliated companies, as stated in this Privacy policy. We request personal data for a variety of purposes throughout your interaction with Breakthrough, some of which are listed below:

  • To collect data for our recruiting process;
  • To operate our sites;
  • Contacting you or your designated representative by phone, email, fax, or mail;
  • Providing you or your representative with marketing communications;
  • Creating and managing your account with us;
  • Sharing data about our Services including investment research;
  • Facilitating financial transactions related to your account;
  • Fulfilling our legal and regulatory obligations;
  • The performance of obligations under any applicable agreements;
  • The administrative processes (and related communication) carried out between Breakthrough in preparing its services;
  • Ongoing communication with you and/or your designated contacts;
  • The ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between the parties;
  • To ensure the security of our services;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
  • Any legal or regulatory requirement; or
  • Any other purpose that has been notified, or has been agreed, in writing; and
  • where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings. We do not “sell” or “share” your personal or sensitive personal data as each of these terms is defined under the California Consumer Privacy Act (CCPA). 

Data Storage and Retention​

We will retain your personal data only for as long as is necessary for the purposes set out in this Policy.

We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and other legitimate business needs. 

We will delete your personal data when it is no longer reasonably required for the uses described herein, or when you withdraw your consent or request erasure, to the extent that we are not legally required or otherwise permitted to continue to hold such data.

Lawful Basis

There is a need to process personal data for the purposes set out in this privacy policy as a matter of contractual necessity under or in connection with the applicable agreement, and in the legitimate interests of Breakthrough to operate their respective businesses. From time to time, Breakthrough may need to process the personal data on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, Breakthrough is relying on performance of a contract necessity and legitimate interests.

A failure to provide the personal data requested to fulfill the purposes described in this Privacy policy may result in Breakthrough being unable to provide the services in connection with the terms of the subscription agreement.

Protection of Personal Data

We take precautions to protect data and information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal data. However, no system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your personal data from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal data.

Please recognize that protecting your personal data is also your responsibility. We ask you to be responsible for safeguarding the password, security questions and answers and other authentication information you use to access our Sites.

Restricted Use Regarding Minors

This Site is not intended or designed to be used by children under the age of 13. We do not collect personal data from any person we know to be under the age of 13 and instruct children under 13 not to send us any data.

Our Site and Use of Cookies

We use various technologies to collect other types of information, including personal data, automatically. For example, in order to measure the usefulness and efficiency of our Sites, we automatically track certain information from all visitors to our Sites. The types of information we might track may include the Internet address that you just came from, which Internet address you go to, what browser you are using, your IP address, your internet service provider, date and timestamp information, or clickstream information.

Additionally, like most interactive web sites, we use “cookies” on certain pages of our Sites. “Cookies” are small data files that are stored on your hard drive that store certain information, including certain personal data, accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us recognize you, customize your experience on the Sites and analyze your use of the Sites to make them more useful to you. By visiting our Sites, you agree to our use of cookies. 

Automated Decision Making 

We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal data. 

Sharing Your Personal Data

In general, we will not disclose your personal data except with your consent and as described in this Policy. We may disclose your data for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data. 

  • Service Providers. We may share your personal data with our service providers for various purposes including to manage, improve, or optimize our Sites and/or Services provided to you. These service providers may include accounting, legal, tax preparation, IT, due diligence, communications, marketing, and payment processing providers. These service providers may engage additional companies to be able to support us. Such companies do not have any independent right to use or disclose your personal data except as we request.
  • we may disclose personal information to property management, security, and parking service providers at the Property.
  • Tenants: We may disclose personal information to property management, security, and parking service providers at the Property.
  • Visitors to Our Properties: we may disclose personal information to property management, security, and parking service providers at the Property.
  • Investors: we may disclose personal information to platform providers, escrow agents, account managers, law firms, accounting firms, transfer agents, banks or similarly situated service providers.
  • To Maintain Legal and Regulatory Compliance. We reserve the right to share any information collected through our Sites or Services with legal authorities if it is, in our sole opinion, necessary to investigate, prevent or otherwise take action regarding suspected fraud, situations involving threats or potential harm, or if otherwise required by law (such as by a subpoena, court order or other legal means).
  • To Protect You, Us or Others. We may share your personal data if we believe, in good faith, that such disclosure would protect your interests or rights or the interests or rights of others, including Breakthrough and its personnel; to protect the integrity of our Sites; and to protect against and investigate fraud.
  • Within Our Corporate Organization. Breakthrough is a part of a corporate organization that has many legal entities, business processes, management structures and technical systems.

Breakthrough may, subject to applicable law, share your personal data within this organization in order to conduct its business and provide services to you.  

  • Mergers and Acquisitions. We can share, sell, assign, or license your personal data in connection with certain business transactions, such as a sale, acquisition, merger, or change in control, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy. Any entity that acquires all or substantially all of the Company’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you.
  • Other Parties, Depending Upon the Nature of Your Relationship with Us.

Transfers of Personal Data

We process personal data in the United States and will, from time to time, send some of your personal data to recipients based in other countries that are located outside the UK and EEA. Your personal data may be transferred, stored and/or otherwise processed in a country other than the one in which your personal data is collected. As these countries are not within the UK and EEA, this may mean that such countries are not deemed to provide an adequate level of protection for your personal data. When transferring your personal data to the US or other countries, we have implemented procedures designed to ensure that appropriate safeguards based on risk are in place to protect the personal data regardless of where it is being transferred. 

To the extent your personal data is transferred to countries outside of the UK and EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact: dataprivacy@Breakthrough.com.

Your Data Subject Rights

You are provided with a number of different rights under the data protection laws in relation to your personal data. These allow you:

  • To access your data;
  • To request we correct your data;
  • To request that we erase your data;
  • To object to the processing of your data;
  • To request a restriction in the processing of your data;
  • To request a transfer of your data;
  • Complain to the Data Commissioner’s Office; and
  • To withdraw your consent.

Exercising Your Data Subject Rights

If you wish to exercise any of these rights, please contact dataprivacy@Breakthrough.com. Please note that you will not have to pay a fee to access your personal data or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further data from you to confirm your identity before we release any personal data. This does not affect your right to make a complaint. For more information see the “Contact Us” section below. 

Additional Information for Residents of California

To the extent that you are a resident of California, this section supplements the above Privacy Notice with respect to specific obligations and rights granted under the California Consumer Privacy Act of 2018 (the “CCPA”) as amended and expanded by the California Privacy Rights Act of 2020 (CPRA) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA/CPRA.  

Disclosures for a Business Purpose Under the CCPA

Within the last twelve (12) months, we have disclosed each of the following categories of personal data collected with third-party service providers as set forth in the “Sharing Your Personal Data” section in this Privacy Notice.  

Category of Information Collected

Categories of External Recipients

Disclosed for a Business
Purpose as defined in the CCPA

Personal Identifiers
  • Service Providers 
  • Legal Authorities

Yes

Personal data 
  • Service Providers 
  • Legal Authorities

Yes

Characteristics of Protected Classes 
  • Service Providers 
  • Legal Authorities

Yes

Investment Related Information 
  • Service Providers 
  • Legal Authorities

Yes

Employment Information
  • Service Providers 
  • Legal Authorities

Yes

Internet or Other Similar Network Activity
  • Service Providers 
  • Legal Authorities

Yes

In addition to the categories of external recipients identified above, during the 12-month period prior to the last updated date of this Privacy Notice, we may have disclosed personal data about you to governmental agencies, regulators, and other third parties for the purposes set forth in the “Disclosure of Personal data” section in this Privacy Notice.   

Your CCPA Data Subject Rights

You have certain rights under the CCPA in respect of the personal data we hold and which you may exercise. These rights are:

Deletion Rights: You have the right to request that we delete any of your personal data that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and nonU.S. laws, rules and regulations.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal data specific to you over the last twelve (12) months. Such information includes:

  • The categories of personal data we collected about you;
  • The categories of sources from which the personal data is collected;
  • Our business or commercial purpose for collecting such personal data;
  • Categories of third parties with whom we share the personal data;
  • The specific pieces of personal data we have collected about you; and
  • Whether we disclosed your personal data to a third party, and if so, the categories of personal data that each recipient obtained.

Additional Rights: Under CCPA you also have the right to:

  • Request the correction of any inaccurate personal data maintained by us about you.
  • Request that we limit the use and disclosure of your sensitive personal data.
  • Choose to opt-out of the sale of personal data or the sharing of personal data for cross-context behavioral advertising. Currently, however, we do not sell or share personal data as defined under the CCPA.

Your rights will in each case be subject to the restrictions set out in the CCPA. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your personal data, can be obtained by contacting us.

Non-Discrimination for Exercising Your Rights

We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

Verifying Your Identity 

If you choose to contact us with a request, you will need to provide us with identifying information that matches the personal data we currently have about you.

Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact dataprivacy@Breakthrough.com. 

Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please contact compliance@btprop.com 

Contact Us

In order to make a query, raise a concern, avail yourself of your data protection rights or for any other reason related to this privacy notice, please contact us using the below contact details:

Telephone: 888-433-2280

E-mail: Compliance@btprop.com 

Address:
c/o Breakthrough Properties
10100 Santa Monica Boulevard, Floor 15
Los Angeles, CA 90067
Attn: Legal and Compliance

Changes to this Privacy Notice

From time to time we may update this privacy notice. If revisions are made to the privacy notice, we will update the statement with a new revision date. 

This privacy notice was last revised and posted on November 26, 2024