PURPOSE

At Drawbridge Partners, LLC (“Drawbridge Partners,” “we,” “us,” “our” or the “Firm“), your privacy is important to us. This Privacy Policy describes our privacy practices and provides information on the type of personal data we process, our processing methods, and processing purposes.

This Privacy Policy governs the personal data we collect for Drawbridge Partners business purposes, whether it is from our clients, our website, or other resources, as fully described in this Privacy Policy.

For the purposes of this Privacy Policy:

• “Personal data” or “Personal Information” may mean any information relating to an individual who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The definition of personal data under this Privacy Policy includes any information that is subject to privacy laws and regulations applicable to our business.
• “Process”, “Processes”, “Processing”, or “Processed” means any operation which is performed on personal data, whether or not by automated means, such as collection, recording, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, erasing, destructing, disseminating, or otherwise making available.

EU-U.S. AND SWISS-U.S. DATA PRIVACY FRAMEWORK COMPLIANCE

Drawbridge Partners complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Drawbridge Partners has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Drawbridge Partners has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the EU-U.S. and/or Swiss-U.S. Data Privacy Frameworks, Drawbridge Partners is subject to the regulatory enforcement powers of the Federal Trade Commission.

Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Data Privacy Frameworks, should direct their query to privacy@drawbridgeco.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@drawbridgeco.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Drawbridge Partners’ accountability for personal data that it receives in the United States under the Data Privacy Framework and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Drawbridge Partners remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Drawbridge Partners proves that it is not responsible for the event giving rise to the damage.

DISPUTE RESOLUTION

In compliance with the Data Privacy Framework Principles, Drawbridge Partners commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Framework. European Union, United Kingdom, and Swiss individuals with Data Privacy Framework inquiries or complaints should first contact Drawbridge Partners at:

Drawbridge Partners, LLC
3330 PGA Boulevard, Suite 507
Palm Beach Gardens, FL 33418
(561) 593-1600
privacy@drawbridgeco.com or filling out the contact us form located at Contact Us

Drawbridge Partners has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to an independent dispute resolution mechanism, the BBB Data Privacy Framework Services. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.

If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Additional information is available here for EU/EEA and UK (and Gibraltar) individuals and here for Swiss individuals.

CALIFORNIA PRIVACY RIGHTS (CCPA)

The California Consumer Privacy Act of 2018 (“CCPA”) took effect January 1, 2020 and provides California residents with certain rights regarding their personal information. Those rights are:

• The right to know about personal information being collected
• To request access to the personal information we have about you;
• To request that we delete personal information about you;
• To opt-out of our use, transfer, exchange or disclosure (including to third parties) of personal information about you;
• Not to be discriminated against based upon whether you decide to opt-out.

To view the list of data we may have collected please view the section “Types of Personal Data Collected”. To exercise your rights, please contact us at privacy@drawbridgeco.com or by phone at +1 (561) 593-1600. You may also write to us at:

Drawbridge
3330 PGA Boulevard, Suite 507
Palm Beach Gardens, FL 33418

TYPES OF PERSONAL DATA COLLECTED

Drawbridge Partners may collect the following categories of personal data:

• Full Name
• Company
• Title or Position
• Mailing Address
• Email Address
• Telephone Number
• Business Contact Information
• Username and Password
• Any other personal data you provide Drawbridge Partners access to via our portals, website, email, or any other means of communication

LEGAL BASIS FOR PROCESSING

Drawbridge Partners only collects personal data from you or about you that is reasonably necessary for us to provide the applicable products or services you have engaged us for, to contact you for the purposes of carrying out our contractual obligations, to establish a business relationship with you, to send your marketing communications in accordance with your communication preferences, for a legitimate business interest, or to comply with our legal or regulatory obligations.

Where consent is required, Drawbridge Partners will request your consent to process your personal data. You are free to withdraw your consent at any time by contacting privacy@drawbridgepartco.com.

HOW WE COLLECT YOUR PERSONAL DATA

Drawbridge Partners may collect personal data from the following sources:

• You directly (i.e., email, phone, in-person)
• Our website or social media accounts, if you choose to submit your information through our website or social media accounts
• Our third-party or hosted portals
• Publicly available databases

HOW WE PROTECT YOUR PERSONAL DATA

Drawbridge Partners has reasonable technical, administrative, and physical security controls in place to protect your personal data. If you have reason to believe that our security measures or your interactions with us are no longer secure (i.e., you feel that the security of an account you have with us may have been compromised), please contact us immediately at (561) 593-1600 or privacy@drawbridgeco.com .

RETENTION OF YOUR PERSONAL DATA

Drawbridge Partners retains your personal data as necessary to fulfill our services, for the purposes outlined in this Privacy Policy, in accordance with Drawbridge Partners’ retention policies, and as required or permitted by law.

HOW YOUR PERSONAL DATA IS SHARED

To the extent permitted by law and subject to any contractual limitations on sharing personal data (as set forth in the relevant agreement for products or services), we may share your personal data with our affiliates, subsidiaries, and business partners for the purposes described in this Privacy Policy. We may also share your personal data in the following circumstances:

• Third-Party Service Providers: We may share your personal data with third parties who perform services on our behalf such as, but not limited to, hosting or operating our services or sites, accounting or audit services, tax services, legal services, or IT services. We do not authorize these third parties to use your personal data for purposes other than for which it has been provided, and we do not authorize these third parties to disclose your personal data to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
• Legal Authorities or Basis: We may share your personal data with legal or regulatory authorities, courts, and government agencies, where we believe that doing so would be in accordance with, permitted, or required by any applicable law, regulation, or legal process to defend the interests, rights, or property of Drawbridge Partners.
• Sale of Business: We may transfer your personal data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets. To the extent permitted by applicable law, we may share your personal data with a prospective buyer or transferee of the business as part of the diligence process, provided that we require any such third party to maintain the confidentiality of your personal data and protect it with appropriate technical, administrative, and physical security measures.

Drawbridge Partners may share your personal data with other third parties as directed by you or subject to your consent. Under no circumstances does Drawbridge Partners sell, trade, or rent your personal data.

YOUR COMMUNICATION PREFERENCES

You may choose to receive or not receive marketing communications from Drawbridge Partners by:

• Contacting us at privacy@drawbridgeco.com
• Replying to any marketing email communication you receive from us and requesting to be unsubscribed from future marketing email communications

We will try to comply with your request as soon as reasonably practicable as required by law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by law. In addition, please note that even if you opt-out of receiving marketing communications, we may need to send you service-related communications.

If you have questions regarding your communication preferences or our marketing activities, please contact us at privacy@drawbridgeco.com.

YOUR RIGHTS & REQUESTS

You may have the following set of rights with respect to your personal data:

• Right to access your personal data
• Right to request information regarding your personal data
• Right to request correction of your personal data
• Right to request transfer of your personal data
• Right to request erasure of your personal data
• Right to withdraw your consent to the processing of your personal data
• Right to object to the processing of your personal data
• Right to restrict or limit the processing your personal data
• Right to lodge a complaint with a supervisory authority (such as the supervisory authority in your member state of habitual residence or place of work or where the alleged infringement took place)

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Please note that the above-mentioned rights may not be applicable to you in certain cases and are subject conditions as specified under the applicable law. Drawbridge Partners may require you to verify your identity if you elect to exercise your rights, and we will try our best to comply with your request as soon as reasonably practicable, but no later than the timeframe required by law.

For more information regarding your rights or to exercise your rights, please contact us at privacy@drawbridgeco.com.

COOKIES & SIMILAR TECHNOLOGIES

Our websites may use cookies and similar technologies to operate as required, for security, improve the performance of our website, help address technical issues, and allow you to engage in our social media offerings. Our website may also collect non-personal data either directly or through a third-party service (e.g. Google Analytics).

“Cookies” are automatically collected pieces of data that identifies you as a unique user, facilitates your ongoing access to and use of this website, and helps diagnose server problems. Non-essential cookies may be disabled via the cookie consent form as presented to you. Strictly necessary cookies are required for the functional use of the website. Disabling those via your Browser setting will disrupt services.

The following cookies are located on the client.drawbridgeconnect.com website:

Site	Type	Name	Party
clientdrawbridgeconnect.com	Essential	logintime	First

The following cookies are located on the www.drawbridgeco.com website:

Site	Type	Name	Party
drawbridgeco.com	Essential	CookieLawInfoConsent, __hssc, __hssrc, __hstc, _ga _gat_gtag_UA_125741287_1 _gcl_au, _gid, cookielawinfo-checkbox-advertisement, cookielawinfo-checkbox-analytics, cookielawinfo-checkbox-functional, cookielawinfo-checkbox-necessary, cookielawinfo-checkbox-others, cookielawinfo-checkbox-performance, hubspotutk, viewed_cookie_policy	First
Linkedin.com	Marketing	AnalyticsSyncHistory, UserMatchHistory, bcookie, lang li_gc, lidc	Third
Lltrck.com	Marketing	Trackalzer	Third
doubleclick.net	Analytics	IDE, test_cookie	Third
Hubspot.com	Marketing	_cf_bm	Third

AUTOMATED DECISION-MAKING

Drawbridge Partners does not engage in decision-making based on the automated processing of your personal data, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.

LINKS TO THIRD-PARTY WEBSITES & SERVICES

This Privacy Policy does not apply to the websites of our service providers, subcontractors, or any other third parties, even if their websites are linked to our website. We have no control over third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our website. We encourage you to read the privacy policies located on each third party’s website.

CHILDREN’S PRIVACY

Drawbridge Partners takes children’s privacy seriously. We do not knowingly collect personal data from minors (children under 13 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted personal data via our website, we will notify the user that we may not accept his or her personal data. We will then remove any such personal from our records.

CHANGES TO THIS PRIVACY POLICY

Except as limited by law, Drawbridge Partners reserves the right to makes changes to this Privacy Policy. If we materially change our personal data processing activities, we will revise this Privacy Policy to reflect such changes. We encourage you to periodically review this Privacy Policy in order to stay informed of how we are using and protecting your personal data.

CONTACT US

If you have any questions, comments, or complaints about our Privacy Policy or privacy practices, please contact us at:

Drawbridge Partners, LLC
3330 PGA Boulevard, Suite 507
Palm Beach Gardens, FL 33418
privacy@drawbridgeco.com