Last Updated and Effective Date: May 23rd, 2024 

This Privacy Policy describes how Chain Bridge Estates (“we,” or “us”) collects, uses, discloses, and processes your Personal Information (“you” and “your”), as well as rights that you may have regarding that information.  We reserve the right to change this Privacy Policy at any time.

If we change our Privacy Policy, we will post an updated version on this website.  You are responsible for reviewing the current Privacy Policy when you visit the website. Please check back periodically to see if our Privacy Policy has been updated.  Updates to the Privacy Policy will be referenced by the “Last Updated and Effective Date” date shown above.

This Privacy Policy is incorporated into, and part of, the Terms of Use, which govern your use of our website.  By visiting our website, you acknowledge and agree that you have read this Privacy Policy and agree to the collection, use and other processing of your Personal Information in accordance with the practices described in this Privacy Policy as well as our Terms or Use.  If you do not agree to all of the terms, conditions and practices set forth herein, you should cease use of the website immediately.

1. Definitions.
   “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. “Personal Information” does not include: (a) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (b) information that is deidentified or aggregate information.Please note that various jurisdictions may use different terms.  For example, some jurisdictions use the terms “personal data” or “sensitive personal data”.  Moreover, some jurisdictions do not consider some of the Personal Information listed in the Sensitive Personal Information definition above as Sensitive Personal Information.
2. Information We Collect, the Categories of Source of Collection and the Purpose for Collection.
   Set forth below are the categories of Personal Information we collect and that have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business or commercial purpose for such collection.  Please note that we may not collect all of the information referenced below regarding you and we may not use your Personal Information for all purposes set forth in this Privacy Policy.

   Category of Personal Information	What We Collect	Categories of Sources from which Personal Information Collected	Business or Commercial Purposes for Collection
   PERSONAL INFORMATION
   Personal Identifiers	Real name Postal address Telephone number Email address Unique personal identifier Online identifier Internet protocol address	Directly from you, including information from you on applications, forms and in other communications with us Automatically, such as when you visit our website (e.g., cookies and tracking technologies)* Our service providers and consumer reporting agencies Our affiliates	To provide you with our services and products To register with our website To help us understand how you use the website To recognize your needs and continue to make improvements that are important to you and our customers. To respond to specific inquiries or requests To send notices, offers and solicitations To offer promotions or special opportunities To manage a promotion or opportunity in accordance with its rules
   Commercial Information	Records of property or products purchased, obtained, or considered	Directly from you, including information from you on applications, forms and in other communications with us	To provide you with our services and products To register with our website
   Internet Information	Electronic network activity information Browsing history Search history Information regarding interaction with a website, application, or advertisement	Automatically, such as when you visit our website (e.g., cookies and tracking technologies)*	To provide you with our services To register with our website To help us understand how you use the website To recognize your needs and continue to make improvements that are important to you and our customers. To respond to specific inquiries or requests To send notices, offers and solicitations To offer promotions or special opportunities To manage a promotion or opportunity in accordance with its rules

   * See the section entitled Cookies below.

3. Cookies and Tracking Technologies.
   A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer.  Cookies contain information that is transferred to your computer’s hard drive. We use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or of the service we provide as some of our features or services may not function properly without cookies.We use the following cookies:
   • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
   • Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
   • Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
   • Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it and on third-party websites more relevant to your interests.
   • Third party cookies.  These cookies are placed on your device by a website from a domain other than our website.  Please note that various third parties may also use these types of cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

   In addition, we use web beacons and pixels, which are images that can be placed in web pages and some forms of email.  These technologies can be used to deliver cookies and to collect information about your use of the site.  Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel.  We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our site.  Other entities may have access to some of this information.

   Emails that we and our service providers send may include similar technologies that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email.  More information on how to unsubscribe from our marketing emails is found below.

   If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this.  Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

   By using your website and services you affirmatively agree to the use of cookies disclosed in this Privacy Policy.

4. Personal Information We Disclose, Share for Targeted Advertising or Sell and the Purpose for It.
   Disclosure of Personal Information to Service ProvidersWe disclose and have disclosed in the preceding 12 months Personal Information to our service providers and contractors for the following business purposes.  
   • Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
   • Functionality & Debugging:  We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.  Specifically, in the course of carrying out our operations and seeking to improve the content of the website, we may transfer your Personal Information to our offices, affiliates, and service providers.
   • Services on Our Behalf: We disclose Personal Information in order to receive services performed on our behalf.  For example, we may disclose your Personal Information for transaction requirements and to our general contractor.  Moreover, we may disclose your Personal Information, where necessary, to financial entities, insurers and vendors.  Finally, from time to time, we may join with other parties, including our affiliates, to provide specific services or products, respond to specific inquiries or requests, and to send notices, offers, solicitations and promotions.  These other parties are not permitted to use the Personal Information except for the purpose of providing these services or products.
   • Advertising and Marketing Services: We disclose Personal Information to provide advertising or marketing services on our own behalf and on behalf of our affiliates.The following chart sets forth the categories of Personal Information we have disclosed to our service providers for a business purpose over the past 12 months.

   Categories of Personal Information that We Disclose	Business Purposes for the Disclosure of Personal Information
   PERSONAL INFORMATION
   Identifiers	Security and Fraud Detection Functionality & Debugging Services on Our Behalf Advertising and Marketing Services
   Commercial Information	Security and Fraud Detection Functionality & Debugging Services on Our Behalf Advertising and Marketing Services
   Internet Information	Security and Fraud Detection Functionality & Debugging Services on Our Behalf Advertising and Marketing Services

   As Necessary:  We may also disclose Personal Information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.  We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

   Selling and Sharing (for Targeted Advertisement) of Personal Information

   We do not sell your Personal Information as that term is commonly understood to be disclosure of your Personal Information in exchange for money.  As noted above, we may disclose your Personal Information in certain circumstances.  Under some state laws, such as California law, the definition of sale includes situations where another company can use your Personal Information for its own purposes, which you can see in the chart below.  Please also see the Cookies section above.

   Also, we may also share with others certain Personal Information we have collected from you for cross-context behavioral advertising (targeted advertising) with some other entities, including our affiliates.

   The chart below shows the categories of Personal Information we sell (as defined herein) or share for cross-context behavioral advertising (targeted advertising) or that we have sold or shared in the past 12 months, the categories of third parties to whom we have sold or shared Personal Information and the purpose for the sale or sharing of the Personal Information.

   Categories of Personal Information	Categories of Third Parties	Business or Commercial Purposes
   PERSONAL INFORMATION
   Identifiers	Our affiliate entities Social media companies Third party advertising partners Third parties for marketing purposes Data analytics providers Our general contractor	Advertising purposes Cross-context behavioral advertising Marketing purposes Analytics purposes
   Commercial Information	Our affiliate entities Social media companies Third party advertising partners Third parties for marketing purposes Data analytics providers Our general contractor	Advertising purposes Cross-context behavioral advertising Marketing purposes Analytics purposes
   Internet Information	Our affiliate entities Social media companies Third party advertising partners Third parties for marketing purposes Data analytics providers	Advertising purposes Cross-context behavioral advertising Marketing purposes Analytics purposes

   We may use third party advertising companies to place ads.  We may do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our site.  The data received by our third party advertising and social media partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests.

   We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties.  By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.  Data collected by Google is subject to its privacy policy.  To learn how Google uses data related to website analytics, please click here https://policies.google.com/technologies/partner-sites.  You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here: https://tools.google.com/dlpage/gaoptout.

   Under California law, the disclosure of data received by our third party partners may be considered a sale of Personal Information.

   We will share aggregated demographic information with our affiliates and other third parties. This type of information is not linked to any Personal Information that can identify any individual person.

   We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

5. Our Retention Policy – How Long We Keep Your Personal Information.
   We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. Data Security.
   We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process and disclose. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information.  We evaluate these measures on a regular basis to help ensure the security of the processing.  Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. 
7. Email Communications.
   If you do not wish to receive mailings or e-mails, or telephone contact concerning us or our products or services, you may opt-out of receiving such marketing or promotional communications by emailing a written request to privacy@ChainBridgeEstates.com.  However, if you choose to opt-out of marketing or promotional communications, we reserve the right to contact you regarding technical support and any other matters that might affect our service to you, and/or your use of the website, as applicable.
8. Children.
   We do not direct our website to children under thirteen (13) years of age.  We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever.  No information should be submitted to our website or applications by persons under 13 years of age.  When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein. Parents should supervise the online activities of their children, and consider the use of tools available from online services and software providers that help provide kid-friendly Internet environments
9. Consumer Rights.
   Your Rights if You Are a Resident of California  California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and related regulations.  Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.
   • Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting, selling, or sharing Personal Information; (4) the categories of parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you.  You also have the right to know the list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. You may submit a request by calling us at 833-880-2262 or emailing us at privacy@ChainBridgeEstates.com.
   • Right to Know Personal Information Disclosed, Sold or Shared and to Whom.  You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; (2) the categories of Personal Information that we sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared; and (3) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.  You may submit a request by emailing us at privacy@ChainBridgeEstates.com.
   • Right to Request Deletion of Your Personal Information.  You have the right to request that we delete your Personal Information, subject to a number of exceptions.  Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records.  If we cannot delete all of your Personal Information, we will let you know the reason.  You may submit a request by emailing us at privacy@ChainBridgeEstates.com.
   • Right to Correct Inaccurate Information.  If you believe that any of the Personal Information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information.  Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct.  You may submit a request by emailing us at privacy@ChainBridgeEstates.com.
   • Right to Opt-Out of the Sale and Sharing of Your Personal Information.  You may opt-out of the sale or sharing of your Personal Information, to the extent appliable, by clicking here: https://tools.google.com/dlpage/gaoptout.  Contact us by emailing us at privacy@ChainBridgeEstates.com.
   • Right to Limit the Use of Your Sensitive Personal Information.  We do not collect sensitive personal information.  As such, this right does not apply to you.    
   • Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

   For California residents, regarding your rights to opt-out of the sale and sharing of Personal Information and to limit the use of your Personal Information, in addition to the links above, you can also exercise your right to opt-out by using a browser that supports an opt-out preference signal (also known as a Global Privacy Control (GPC)).  If you choose to use this signal, you will need to turn it on for each browser you use.

   Your Rights If You Are a Resident of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Florida or Montana.

   If you are a resident of Colorado, Connecticut, Utah, Virginia, Texas, Oregon, Florida, or Montana, (except as noted below), you may have, or may soon have, certain additional rights set forth below.

   Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

   • The Right to Know:  You have the right to know whether we are processing your Personal Information, and, if you are a resident of Oregon, the categories of your Personal Information we have processed and the specific third parties to which we have disclosed it.
   • The Right of Access: You have the right to access your Personal Information, and to obtain a copy of it in a readily usable format, if feasible.
   • The Right to Correct Inaccuracies: You may request that inaccuracies in your Personal Information be corrected.  Utah law does not provide for this right.
   • The Right to Delete:  You have the right to request that your Personal Information be deleted, except in cases where retention is required by law or contractual obligation.
   • The Right to Data Portability: You have the right to obtain a copy of your data in a portable and, if feasible, readily usable format.
   • The Right to Opt-Out: You may elect to prevent your Personal Information from being:
   1. Used in targeted advertising;
   2. Sold;
   3. *Used for profiling purposes that may produce legal or similarly significant effects.

   * Utah law does not provide for this right.

   • The Right to Non-Discrimination for Exercising Your Rights:  If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
   • Rights Regarding Sensitive Personal Information:  We do not collect sensitive personal information.  As such, this right does not apply to you.    

   You may submit a request via email to privacy@ChainBridgeEstates.com

   Residents of Other States

   For residents of all other states, if your Personal Information changes, or if you no longer desire our services, you may correct, update or delete/deactivate your Personal Information.  This can be done by e-mailing privacy@ChainBridgeEstates.com.

   Verification of Consumer Requests

   When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity.  Our verification procedure may differ depending on whether you have an account with us or not and the request you are making.  The following generally describes the verification processes we use:

   • Password Protected Accounts.  If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data.  If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know, correct or delete.
   • Verification for Non-Accountholders.  If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
     • For valid requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
     • For valid requests to know specific pieces of Personal Information, right of access and right to data portability, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.
     • For valid requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion.  We will act in good faith when determining the appropriate standard to apply.

   If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

   We may also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.  We will maintain all signed declarations as part of our records.

   If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request.

   There may be situations where we cannot grant your request.  For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your personal information serves a legitimate purpose such as for security purposes.  Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.

   We will respond to valid requests to know, requests to delete and / or delete no later than 45 calendar days.  If we cannot verify your request within 45 days, we may deny your request.  If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

   Valid under “Right of Access” and “Right to Data Portability” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days. At that point if you believe our decision was in error, you may have the right to submit an appeal using the method(s) above.  If the result is the same, you can also seek assistance and/or redress from your state attorney general.

10. Nevada Privacy Notice.
    Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity.  Our uses of your Personal Information are not sales under Nevada law, so no opt-out right applies. 
11. Other Sites.
    Our website may contain links to other websites.  Unless otherwise expressly, all such websites are not owned, operated or controlled by us and shall be governed by their own terms and conditions and privacy policy and not this Privacy Policy. We cannot control and are not responsible for the privacy practices or content of such other websites. We encourage you to read the privacy statements of each and every website that collects Personal Information.
12. How to Contact Us.
    If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by emailing us at privacy@ChainBridgeEstates.com or by mail at Chain Bridge Estates, Attn:  Data Privacy, 1350 Beverly Road, Suite 115-177, Mclean, VA  22101.