PRIVACY POLICY
Definitions
“CNL Financial Group” is the company to which this privacy policy pertains. We refer to ourselves as “CNL”, “We” or “Us” throughout this policy.
“You” is the client/customer or user of this website. We refer to you as “you”, “your” or “client”.
“Affiliate” is a company that is in the CNL family of companies.
“Third Party” or “Third Parties” is a company (ies) that is not a company in the CNL family of companies.
“Personal Information” about you, for purposes of this policy, is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
“Sensitive Personal Information” about you, for purposes of this policy, is as defined in applicable privacy law and includes, without limitation, non-public Personal Information that reveals your social security, driver’s license, state identification card, or passport number.
Entity Covered
This is the privacy policy for: CNL Financial Group and Affiliates.
Personal Information We Collect
In the preceding 12 months, we have collected the following categories of Personal Information:
- Identifiers (e.g., a real name, postal address, email address, account name, other similar identifiers);
- Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual (e.g., bank account number, financial information);
- Characteristics of protected classifications under California or federal law (e.g., gender, age);
- Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing histories);
- Professional or employment-related information (e.g., securities licensing);
- Inferences drawn from any of the information identified above (e.g., preferences, characteristics, or behavior); and
- Sensitive personal information (e.g., tax identification number).
How Your Personal Information is Collected from you:
- The information that you voluntarily supply to us when you make an investment.
- The information that you voluntarily supply to your stock broker, registered investment adviser, financial professional, custodian, or the channel through which you make an investment with our Affiliates, and that is in turn provided to us.
- The information that you supply to us voluntarily via the website, email, telephone, meetings, or mail.
- Inferences drawn from any of the Personal Information (other than Sensitive Personal Information) identified above to create a profile about you reflecting your preferences, characteristics, and behavior.
We may also collect Personal Information from the following categories:
- Publicly accessible sources (e.g., property records, licensing, and registration records).
- Third parties (e.g., customer due diligence providers, data analytics providers, government entities, and data brokers).
- Information about your use of our website. By example, such information includes the pages you access, the time you spend on the page and the like, to the extent you do not turn off cookies, tracking and the like via your web browser settings. For more information, see our Terms of Use.
Note that when you use our website, we use “cookies,” which are small data files your web browser stores on your hard drive that allow our website to recognize your computer so that you can use the site efficiently. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. But if you choose to block cookies, you may lose some functionality of our website — that is, it may not work entirely correctly. For more information on what cookies are, review this information: https://en.wikipedia.org/wiki/HTTP_cookie.
What We Do With Your Personal Information
We may use your Personal Information:
- To administer our business and provide service to you.
- To contact you, such as to respond to questions you may raise.
- To advertise to you.
- To make changes to and improve our website.
- To respond to law enforcement, court, or regulatory inquiries.
- For our legitimate internal business purposes, such as analytics designed to improve and enhance the services we may offer you.
- To share with third parties with which we contract as defined by the purpose of the contract. See also “How We Share Your Information” below.
In addition to these limitations on the use of your Personal Information, in any event, we further restrict the use of your Sensitive Personal Information to what is reasonably necessary for our legitimate internal business purposes.
The length of time we intend to retain your Personal Information is determined by the time period reasonably necessary for the disclosed purpose above; our routine back-up retention policies; any applicable legal, regulatory or other similar document retention requirements; and certain other legitimate purposes as further described below in “Right to be Forgotten or Deleted.”
To protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure, CNL employs reasonable security measures, such as technological safeguards and secured files and buildings. We also contractually require any Third Parties that we may share your Personal Information with to comply with all privacy and security laws. CNL will only share such information with contracted third parties subject to appropriate confidentiality agreements that obligate Third Parties to maintain and protect the confidentiality of such information.
How We Share Your Personal Information
We may share your Personal Information as follows:
- CNL will not sell your Personal Information as part of its business (e.g. as a “product”); however, at times CNL will contract with Third Parties to provide services to CNL. As part of that agreement, the Third Party may gain rights to own or use your information.
- As indicated above, CNL does not currently sell your information as a product; however, if in the future CNL determines that it will sell your information as a product, it will first seek your express permission before so doing if required by law.
- Mobile Information. As indicated above, mobile information will not be shared with third parties for their own marketing/promotional purposes. Additionally, text messaging originator opt-in data and consent will not be shared with any third parties, provided that the foregoing does not apply to sharing (1) with service providers who need access to such information to provide services on our behalf (and who will not use such information for their own purposes); (2) if we believe disclosure is required by any applicable law, rule, or regulation; or (3) if we receive your consent.
- If you do not want us to share your Personal Information for use by Third Parties for their own marketing purposes, either so indicate at the time of collection, or please follow the procedure described below to opt out of such sharing.
- CNL transfers information to and sometimes among its Affiliates for the purposes of carrying out the business operations of each of the Affiliates. This information may include your Personal Information.
- None of the Affiliates focuses its business on “data sales” or “data mining” your information.
- None of the Affiliates focuses its business on marketing your data as a product.
- Rather, each of the Affiliates is, generally speaking, in the business of investing in real estate, operating businesses, and securities (i.e. “stock”) or supporting such businesses.
- CNL may share your Personal Information with government agencies and/or officials when required to do so by law, rule or regulation.
- CNL may share your Personal Information with our lawyers, accountants, consultants, and other service providers when necessary for them to provide advice and services to CNL; however, our service providers are contractually bound to use such information only for the intended purpose.
If in the unlikely event CNL is sold or acquired, it will likely include your Personal Information as a part of that sale, and we will not ask for your permission prior to such company sale unless a court rules that we must. Similarly, if in the unlikely event CNL or an Affiliate declares bankruptcy, your Personal Information may be transferred via that bankruptcy proceeding as an “asset” of the bankruptcy estate.
Categories of Personal Information We Disclosed for a Business Purpose
In the preceding 12 months, we have disclosed the following categories of your Personal Information for a business purpose:
- Identifiers (e.g., a real name, postal address, email address, account name, other similar identifiers);
- Personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual (e.g., bank account number, financial information);
- Characteristics of protected classifications under California or federal law (e.g., gender, age);
- Commercial information (e.g., records of products or services purchased, obtained, or considered, or other purchasing histories);
- Professional or employment-related information (e.g., securities licensing);
- Inferences drawn from any of the information identified above (e.g., preferences, characteristics, or behavior); and
- Sensitive personal information (e.g., tax identification number).
Your Rights and “Opting Out”
Right to Know. You have the right to know the following with respect to Personal Information about you that we have processed within the past 12 months or collected after January 1, 2022:
- what specific information we have collected about you
- what categories of Personal Information we have collected about you
- the categories of the sources of Personal Information we have collected about you
- the categories of Personal Information that we have shared with Third Parties for a business purpose about you
- the business or commercial purpose for collecting and sharing Personal Information
Please note that you also have the:
- Right to Correct Inaccurate Information (sometimes referred to as “rectification”). You have the right to correct errors in the Personal Information we have about you.
- Right to Opt Out. You have the right to opt out of our sharing your Personal Information with third parties for their own marketing purposes.
- Right to be Forgotten or Deleted. You have the right to have your Personal Information that we collected from you deleted.
- Please note that your right to be forgotten/deleted is limited in some instances, including: (i) where we maintain applicable record-keeping rights, (ii) consistent with our regulatory/legal compliance requirements, (iii) if we need to keep your Personal Information to complete the transaction(s) for which it was collected, (iv) as reasonably necessary and proportionate to help ensure security and integrity, (v) to identify and repair errors; (vi) if another federal, state or other law preempts your right regarding deletion, (vii) if we have any right to retain the information by law or regulation that exists or later may be established over time.
- Please note that we will not usually be able to delete your information from back-up systems, but instead such information will be deleted or destroyed in accordance with routine back-up retention policies.
- Likewise, we may continue to keep information that has been anonymized (i.e. your identifying information has been removed) or aggregated (your information has been added to a data pool but without your identifying information). We will not attempt to reidentify your deidentified Personal Information, except as provided by law.
Should you wish to correct errors or be forgotten/deleted, please contact us using the below-referenced phone number, email address or form. If you wish to opt out of our sharing of your Personal Information with Third Parties for their own marketing purposes, please follow the steps set out in this form.
Right to Protection Against Retaliation
You have the right to not be retaliated against by us because you exercised any of Your Rights under applicable privacy law. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Please contact us at 1-866-650-0650, cnlprivacypolicy@cnl.com, or by filling out this privacy request form.
Our Right to Verification
In interacting with you and in order to ensure that no Personal Information is inappropriately disclosed or deleted, please understand that we are required by law to require that you prove to us that you are who you represent yourself to be before taking any actions that you may request with respect to Personal Information.
In verifying who you are, we routinely require the following information which is not an exhaustive list: your name, address, telephone number, certain identification characteristics of your account, Social Security number, information from your driver’s license or other government issued identification, and other information that we may reasonably require to authenticate your identity. Likewise, we may require you to provide to us other additional elements of data for authentication purposes.
Non-U.S. Residents
We do not solicit or wish to obtain the Personal Information of non-United States residents. By using our website or doing business with CNL, you represent that you are present and reside in the United States when you do so. Moreover, you agree that the law of the United States, and in particular, Orange County, Florida, shall apply to and govern your business with us.
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Amended: April 15, 2024