BLUE SKY SERVICES ASSET MANAGEMENT, LLC
PRIVACY POLICY
Revised: May 1, 2016
Blue Sky Services Asset Management, LLC (“Blue Sky” or “we”) values your privacy. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Blue Sky website and mobile applications (collectively, the "Site") or Blue Sky services ("Services").
1. Information We Collect
Personal Information
We collect information that personally identifies you, such as your name, address, phone number, e-mail, information you submit for inquiries, such as loan inquiries, information you submit through loan applications, and other personally identifiable information that you choose to provide us with You may be asked to provide us with Personal Information when you register with the Site or use any of our Services, and at other times.
We may also collect Personal Information from the following sources:
· Social media websites and services;
· Loan applications;
· Personal financial statements;
· Tax returns;
· Credit reports;
· Partnership agreements;
· Searches on google.com;
· Client events, including webcasts; and
· Other sources.
The decision to provide Personal Information to us is optional; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services.
Usage Data and Site Activity
We automatically collect information regarding the actions you take on the Site ("Usage Data"). For example, each time you use the Site we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the Site. We use this information to help us understand how people use the Site and Services, and to enhance the services we offer.
Cookies and Other Tracking Technologies
We use cookies (a small text file placed on your computer to identify your computer or device and web browser). We use cookies to improve the experience of the Site and Services, such as pre-populating your username for easier login. We do not use cookies to collect Personal Information. From time to time, Blue Sky and its Service Providers (defined below) track your online activity on the Site. Blue Sky and those third party providers will at times associate that tracking information with information that can identify you, an account belonging to you, or your device or with information that can be used to contact you.
Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies or other tracking technologies in connection with the services they perform on our behalf.
2. How We Use Information and When We May Share and Disclose Information Generally
Except as otherwise stated in this Privacy Policy, we use Personal Information for internal purposes only, such as to provide you with the Site and Services, to provide you with Services that you request, to process and evaluate a job application that you submit, to improve the Site and Services, to notify you of new products or services offered by Blue Sky and its affiliates, and to otherwise communicate with you about Blue Sky and its affiliates. We may share your Personal Information with third parties as necessary to provide services requested by you, such as in response to a loan inquiry or application or to send you a research report in response to an inquiry from you.
We may share your Personal Information with the following entities to provide services that you request:
· Commercial banks;
· Investment banks;
· CMBS aggregators/issuers;
· Private and public funds;
· Fannie Mae, Freddie Mac, and HUD;
· Mortgage bankers;
· Insurance companies;
· Private lenders;
· Other third party vendors; and
· Blue Sky sales agents.
We will not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Privacy Policy. We may disclose to third parties for ours and others’ marketing purposes, certain Usage Data regarding the Site and Services. However, in such cases, your Usage Data is aggregated with the usage data of others and does not identify you individually.
3. Service Providers
From time to time, we may establish a business relationship with other businesses whom we believe to be trustworthy and who have confirmed that their privacy practices are consistent with ours ("Service Providers"). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by Blue Sky.
4. Access to Personal Information and Retention of Your Personal Information
Blue Sky provides access to your Personal Information to Blue Sky employees and contractors, such as originators, processors, and closers, in order to provide you with the services that you request. Once we complete providing services that you request, we may retain certain of your Personal Information and we may contact you from time to time as detailed in this Privacy Policy. After a certain period of time, we may destroy certain information and files we have about you.
5. Other Transfers
We do not sell or rent personal information about our users for marketing purposes. We do, however, share your personal information with our trusted partners who perform vital functions with respect to our services.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with Blue Sky. If Blue Sky is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, the new entity plans to handle your information in a way that differs materially from this Privacy Policy.
6. Compliance with Laws and Law Enforcement
Blue Sky cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of Blue Sky or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
7. Security
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
8. Links To Other Websites
Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party's website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.
9. Children's Privacy
The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.
10. Processing in the United States and Elsewhere
Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store information in the United States, The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.
11. Privacy Policy Changes
Blue Sky expressly reserves the right to amend this Privacy Policy at any time in order to address future developments. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. You can determine when the Privacy Policy was revised by referring to the “Last Updated” legend on the top of this policy. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you consent to the revised Privacy Policy.