Privacy Policy

1. Introduction

TB Manhattan LLC ("we," "our," "us," or "Company") is committed to protecting your privacy and maintaining the confidentiality of sensitive real estate and financial information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage our services for residential real estate, property investment, and patrimonial holding management.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our services. Your use of our services signifies your acceptance of this Privacy Policy.

2. Information We Collect

Personal and Financial Information

• Contact Information: Name, email address, phone number, mailing address, and nationality
• Financial Information: Bank accounts, investment capacity, credit references, and financing information
• Property Information: Details about properties you own, desire to purchase, or manage
• Transaction Data: Purchase agreements, sales history, lease information, and transaction terms
• Investment Profile: Investment objectives, risk tolerance, portfolio composition, and holding strategy

Information Collected Automatically

• Website Usage Data: Pages visited, time spent, click patterns, and navigation preferences
• Device Information: Browser type, operating system, IP address, and device identifiers
• Cookies and Similar Technologies: We use cookies to enhance user experience and analyze website performance

3. How We Use Your Information

We use the information we collect for the following purposes:

• To facilitate residential property identification and acquisition
• To provide property investment advisory and portfolio management services
• To manage patrimonial holdings and property portfolios
• To coordinate property transactions and closing procedures
• To maintain client records and provide ongoing client service
• To fulfill legal and regulatory compliance obligations
• To conduct financial due diligence and investment analysis
• To communicate with clients regarding properties and services
• To improve our services and website functionality
• To respond to inquiries and provide customer support
• To market our services (only with appropriate consent)
• To analyze website performance and user behavior patterns

4. Legal Basis for Processing (CCPA Compliance)

Under California Consumer Privacy Act (CCPA) requirements, we process your information based on:

5. Information Sharing and Disclosure

We Share Information Only In These Circumstances:

• With Your Consent: To real estate professionals, lenders, tax advisors, and other service providers with written authorization
• With Service Providers: Trusted vendors including escrow companies, title companies, property managers, and financial institutions under confidentiality agreements
• Legal Compliance: When required by law, court order, regulatory authority, or IRS
• Protection of Rights: To prevent fraud, protect safety, or enforce our legal agreements
• Business Transitions: In connection with merger, acquisition, or sale of company assets (with appropriate notification)

We DO NOT sell your personal information to third parties.

6. Real Estate Transaction Transparency

TB Manhattan maintains strict confidentiality regarding property transactions and client holdings:

• Property information is disclosed only to authorized parties with legitimate business need
• Client identities in property transactions are protected and disclosed only as required by law
• Financial information related to transactions is kept confidential and secure
• Portfolio holdings are managed with strict privacy protection
• Investment strategies and personal financial situations are protected from unauthorized disclosure

7. Data Security

We implement comprehensive security measures to protect your sensitive real estate and financial information:

• Encryption: Sensitive data is encrypted in transit (SSL/TLS) and at rest using industry-standard encryption protocols
• Access Controls: Information access is limited to authorized personnel with legitimate business need
• Secure Storage: Financial and property data stored in secure, bank-grade systems
• Regular Audits: Periodic security assessments and vulnerability testing
• Employee Training: Staff training on data protection, privacy obligations, and confidentiality requirements
• Data Retention: Information retained only as long as necessary for service delivery or legal requirements
• Destruction Protocols: Secure destruction of information when no longer needed

Note: While we implement robust security measures, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security of information transmitted over public networks.

8. Your Privacy Rights (CCPA and California Consumer Privacy Act)

As a California resident or individual whose data is processed by us, you have the following rights:

How to Exercise Your Rights

To exercise any of these rights, contact us using the information provided in Section 10. Include "Privacy Request" in your subject line and specify which right you are exercising. Provide sufficient information to allow us to verify your identity. We will respond within 45 days and may request additional information to confirm your identity or the scope of your request.

9. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to:

• Remember user preferences and login information
• Analyze website traffic and usage patterns
• Enhance user experience and functionality
• Detect and prevent fraudulent activity
• Track analytics and improve service delivery

Types of Cookies:

• Essential Cookies: Required for website functionality and security
• Analytics Cookies: Help us understand how visitors use our site
• Preference Cookies: Remember user choices and preferences

You can control cookie settings through your browser preferences. Disabling cookies may affect website functionality and your ability to access certain features.

10. Contact Information for Privacy Requests

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on this page and updating the "Last Updated" date. Your continued use of our services following such modifications constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

12. Third-Party Links and Services

Our website may contain links to third-party websites and services. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices of other sites. We encourage you to review the privacy policies of any third-party websites before providing personal information or engaging their services.

13. California Privacy Rights Summary

Under CCPA, California residents have specific rights regarding personal information:

14. Real Estate Specific Privacy Considerations

TB Manhattan recognizes the sensitive nature of real estate transactions and holdings:

• Property Ownership Privacy: Client property ownership information is protected and shared only with necessary parties
• Transaction Confidentiality: Details of property purchases, sales, and transactions are kept confidential
• Investment Strategies: Client investment objectives and strategies are protected from unauthorized disclosure
• Financial Information: Lending arrangements, down payments, and financing details are treated as highly sensitive
• Valuation Protection: Property valuations and appraisals are shared only with authorized parties

15. Compliance Certifications

TB Manhattan LLC commits to compliance with:

• California Consumer Privacy Act (CCPA): Protection of California consumer privacy rights
• California Real Estate Law: Compliance with state real estate transaction requirements
• Federal Housing Finance Agency (FHFA) Standards: Compliance with mortgage and lending regulations
• Anti-Money Laundering (AML) Requirements: Verification and compliance with federal AML regulations
• IRS Regulations: Compliance with federal tax reporting requirements for real estate transactions

16. Data Breach Notification

In the event of a data breach or unauthorized access to your personal information, TB Manhattan will:

• Notify affected individuals without unreasonable delay
• Provide clear description of the breach and information involved
• Recommend steps to protect yourself from potential harm
• Comply with all California data breach notification laws
• Conduct thorough investigation and remediation

17. Questions or Concerns

If you have questions about this Privacy Policy or our privacy practices, please contact us at the address provided above. We are committed to working with you to resolve any privacy concerns and maintaining your trust.