Privacy Policy
At Green Brick Group, LLC (“Green Brick Group”, “GBG” or “We”), the protection of your personal data is of particular importance to us. We protect your personal data in accordance with applicable data protection laws as well as this Privacy Policy (“Policy”). We have prepared this Privacy Policy to inform you of the manner in which we collect, use, disclose, and otherwise process the information we may collect about you from (a) your use of our Website and/or our products and services, (b) your interactions with us online and at in-person events, or (c) any other circumstances (“Services”).
How Do We Collect Personal Information
● From you. We may collect personal information and other information that you voluntarily provide when taking certain actions, such as when you use our Services, register with Green Brick Group online, interact with our affiliated Advisors, sign up for newsletters, or otherwise communicate with us.
● From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and Similar Technologies” section below.
● From third parties and publicly available sources. This includes personal information we collect from other public sources including, but not limited to, websites that enable social sharing, social media sites, and from our Service Providers, Third Parties, vendors and suppliers, our affiliates, or other individuals and businesses.
● From you in person. This includes information you may give one of our team members if you meet with them in person.
Types of Personal Information We May Collect From You
Depending on how you interact with us and our Services, we may collect the following information:
● Contact Information such as name, email address, zip code, phone number and home address.
● Biographical and Identifying Information such as date of birth, location, and Social Security Number.
● Internet Usage and Activity Information such as information collected when you interact with our Services, including browser or device model and settings, operating system, and unique identifiers, clickstream data, search history, cookies and localStorage, browsing history, web-based location, IP address, non-precise geolocation, and any other internet usage information our Services may automatically record when you visit.
● Device information such as browser or device model and settings, operating system, and unique identifiers, and the version of the app you’re using.
● Inferences such as inferences drawn from any of the personal information we collect to better understand your preferences.
● Account Information such as information you provide when you create an account, like username and password.
If you submit any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this policy.
How We May Use Your Personal Information
We may use information you provide us through our online services to:
● Provide, market, and develop our products and services. GBG collects information to provide our services, maintain our websites and mobile applications, and better understand the interests of our clients and investors who use our services and products.
● Process transactions and administer your account. We may use your information to process your transactions and requests, and offer our products and services that may be of interest to you.
● To process your employment application. We may use your information to process employment applications, including verifying statements made on your application (e.g., credit and employment history), performing background and credit checks.
● Communicate with you. We may use your information to respond to your inquiries and send you communications regarding our products and services.
● Develop new products and services and quality assurance. We may use personal information to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
● Security and fraud prevention. We may use personal information to monitor, detect, and prevent fraud and improper or illegal activity. It may also be used to investigate any suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper. We may also use it to enforce our Terms of Use and any other agreements between you and GBG.
● Verify your identity and verify our records. We may use personal information to verify your identity for the purposes of responding to a request regarding your personal information that you make. This information may also be used to verify our own records for accuracy.
● Debugging and Performance of Systems. We may use your personal information to secure our online services including our network and websites and to debug our online services. We may also use it to diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services.
● Comply with law. We may use personal information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigation.
● Internal business purposes. We may use personal information for our internal business purposes, such as data analysis, audits, and enhancing our Services. We may also use inferences drawn from personal information to create a profile reflecting your preferences so we can tailor our Services to you.
How We Disclose Personal Information
We may disclose personal information in the following ways:
● GBG Affiliates. GBG may disclose personal information with GBG Affiliates for the purposes described in this Privacy Policy. Consumers who visit GBG Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.
● Service Providers. We may provide personal information to vendors, contractors, business and service partners, or other third parties who provide services to us including data storage firms, payment companies, technology suppliers, technology services, customer service, risk solution providers, analysis firms, fraud prevention companies, advertisers, marketers, and others.
● Collaborators and Advisors. We may disclose personal information with collaborators with whom we jointly develop or promote our services.
● Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
● At your direction. We may disclose your personal information at your direction or with your consent.
● Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.
● In connection with a merger, acquisition, or business transfer. If GBG sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a reorganization, merger, or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), GBG may transfer or disclose your information to the party or parties involved in the transaction as part of that transaction.
Children’s Privacy
You must be eighteen (18) years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.
Links to Third Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.
If you provide any personal information through a third-party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.
Advertising and Opt-Out Disclosures
When you use our Services, our third-party advertising partners, social media providers and analytics providers may collect personal information about your online activity on our Services and on third party websites.
These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
Information Security
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.
Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, local Storage, and other similar technologies (“Tracking Technlogies”). Some of these Tracking Technologies store data in the browser or on your device. Other Tracking Technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These Tracking Technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history. Additionally, we may use these Tracking Technologies to collect analytics and measure the use of our Services.
We and our partners may also use these Tracking Technologies to gather personal information about how you view and use our Services and content, and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these Tracking Technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.
Your web browser can be set to allow you to control these Tracking Technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. Although most browsers are initially set to accept cookies, you can change your browser settings to notify you when you receive a cookie or to reject cookies generally. To learn more about how to control privacy settings and cookie management, click the link for your browser below.
To find out more about cookies, visit www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising. For more information about Google Analytics, please review the site “How Google uses data when you use our partners’ sites or apps,” located at www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout.
Tracking Technologies fall into one of these four categories:
● Essential
● Advertising
● Analytics & Customization
● Performance & Functionality.
You are able to see the specific Tracking Technologies we use and exercise choices about the types of cookies and other technologies you want to accept by selecting the “Manage Cookie Preferences” section of our website.
Additionally, we collect non-personal data through our Internet log files, which record data such as browser types, domain names, and other anonymous statistical data involving the use of the Green Brick Group services. This information may be used to analyze trends, to administer the Green Brick Group services, to monitor the use of the Green Brick Group services, and to gather general demographic information. We may link this information to personal data for these and other purposes such as personalizing your experience on the Green Brick Group services and evaluating the Green Brick Group services in general.
Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites. We do, however, respond to global privacy preferences when required by law.
Your Marketing Preferences
We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email. You may unsubscribe from text messages you previously consented to by following the prompt provided on our messages. We will work to comply with your request promptly.
There are certain service notifications and other non-promotional emails that you may not opt-out of, such as notifications of changes to our Services or policies.
Suspicious Email
It is our policy not to email you or send you electronic communications to request non-public personal information or account information (such as a username or password). If you receive an unsolicited email or other electronic communication that appears to be from the Green Brick Group but you suspect may be from another source and might be fraudulent, please contact us at info@greenbrickgroup.com.
Social Media
You may also find additional information on our products and services through our social media sites such as Facebook, LinkedIn, or X. Please keep in mind that any information you share is visible to all participants on these social media sites and you should never post any sensitive personal information (such as account number or tax identification). Please carefully review the Terms of Use and Privacy Policy on these social media sites as they may be different from our policies.
Storage and Protection of Personal Information
GPG has a dedicated group that designs, implements and provides oversight of information security. We also monitor our systems infrastructure in order to detect weaknesses and potential intrusions.
In order to help secure personal information collected from you as an GBG online services user the information is protected by SSL encryption when it is exchanged between your web browser and GBG online services. However, the internet is not a fully secure environment, and we cannot ensure or warrant the security of any information transmitted to or generated by GBG in connection with GBG online services. There is no guarantee information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, and physical, or other operational, safeguards. You play a critical role in protecting your information by maintaining up-to-date computer security protections. Steps you take to ensure the security of your computer, computer passwords, or other personal identifier authentication mechanisms are key components of the protection of your personal information. You agree that you are responsible for any additional verification procedures and security you deem necessary.
By using GBG services, you agree the procedures provided for in this Privacy Policy and the procedures implemented on GBG services to protect personal information and to verify the identity of users including, but not limited to, those procedures described in the foregoing paragraph, constitute commercially reasonable website security and customer verification procedures.
Notice to Persons Accessing the Green Brick Group Site Outside the United States
If you access the GBG online services outside the United States, any information you provide to us through the GBG online services will be transferred out of that jurisdiction and into the United States. If you do not want your personally identifiable information to leave that jurisdiction, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.
Updating and Correcting Your Personal Information
Keeping your information accurate and up to date is very important. If your personal or account information is incomplete, inaccurate or not current, please feel free to update your profile accordingly online or call Green Brick Group directly.
Non-North Carolina Residents
If you are not a resident of North Carolina, your state of domicile may have a consumer privacy act which may protect your personal data; however, those state laws do not apply to Green Brick Group, LLC for various reasons.
What We Collect
We collect the following information and may disclose this information to our affiliates, business partners, service providers who process information on our behalf to assist our operations, law enforcement and/or to bona-fide rights owners. We do not knowingly “share” or “sell” Personal Information of minors under eighteen (18) years of age.
● Identifiers
○ Including first and last name, email address, phone number, address, IP address, online and device identifiers, and military and/or veteran status.
● Personal Information
○ Including names, addresses, phone numbers, employment information which may identify you (company, job position, title) geo location, subject areas of interest and/or demographic information.
● Internet or Network Activity Information
○ Including browsing history, search history, and information regarding a consumer’s interaction with an internet website, device software platform/OS and firmware, mobile carrier, and preferred languages.
● Commercial Information
○ Including financial information, such as products or services purchased or considered.
● Audio, Electronic, Visual and Other Similar Information
○ Including your profile picture and/or recordings of customer service calls.
● Professional or Employment Related Information
○ Such as work history and prior employer.
● Inferences
○ Drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
● Other Information You May Share
○ Collected from forms or materials submitted to GBG.
Please note we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction, including bankruptcy, or other similar transaction involving all or any portion of our business.
We do not usually seek to collect your sensitive personal information (i.e., data relating to your social security, driver’s license, state identification card, or passport numbers; non-GBG account username or number or financial account, debit card, or credit card number in combination with credentials allowing access to such accounts; racial or ethnic origin; national origin; immigration or citizenship status; religious or philosophical beliefs; trade union membership; genetic or biometric data; precise geolocation; political opinions; status as victim of a crime; medical or health conditions/status (including data related to pregnancy, abortion, or reproductive or sexual health); researching, obtaining, or seeking gender affirming health care or reproductive or sexual health services; status as transgender or non-binary; or sex life or sexual orientation. Sensitive personal information also includes the contents of your personal mail, email, or text messages unless we are the intended recipient). We will obtain your explicit consent to collect and use such information where required by law.
Data Retention
We will retain your Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Privacy Notice, unless a longer retention period is required or permitted by law.
Sources of Personal Information
In general, we only collect Personal Information that is reasonably necessary for and proportional to the purposes for which we process it. We collect this Personal Information directly from the user (including California residents) themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website or apps); referrals; joint marketing, co-branding, co-promotional, or advertising partners; Advisors; and sources of demographic and other information, including through devices you used to interact with us through our Services. The sources of personal information collected are noted in the sections above.
Rights and Choices Available
Certain state residents have certain rights with respect to their Personal Information, as described below.
We may be required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.
● Request to Know and Access Your Personal Information: You may request to access the following information we have collected and maintain about you:
○ The specific pieces of Personal Information we collected about you;
○ The categories of Personal Information we collected about you and the categories of sources;
○ The business/commercial purpose for collecting/disclosing/ selling Personal Information about you; and
○ The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties to whom we sold, shared, or otherwise disclosed that Personal Information.
● Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
● Request to Delete Your Personal Information: You may request we delete your personal information. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, as permitted by applicable law, we may retain your information in our business records. Please note, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
● Request to Opt-Out of “Sale” and Certain Sharing Practices: You have a right to opt-out of the sale or share of your personal information, as depending on the applicable law in your state or circumstance.
● Request Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate personal information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
● Non-Discrimination: You have the right to be free from unlawful discrimination for exercising any of the applicable rights above depending on your jurisdiction and applicable laws.
● Limit the Use of Sensitive Personal Information. You have a right to limit the use of your sensitive personal information. Please note, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
Authorized Agent
Certain consumers may have the right to submit a request through an authorized agent. If you are an authorized agent acting on behalf of a consumer to exercise a privacy right discussed in this section, you must be able to demonstrate you have the requisite authorization to act on behalf of the consumer. We may also contact the consumer directly to verify his or her own identity and that the consumer granted you authorization to act on their behalf as an authorized agent. An authorized agent may also be permitted to act on behalf of a consumer in order to exercise certain opt-out rights. If you are an authorized agent trying to exercise rights on behalf of a consumer, please contact us at the contact information above with supporting verification information, which should include proof that you have the consumer’s authorization to act. Under certain circumstances, we may also require you to prove and verify your identity if you are acting as an authorized agent on behalf of a consumer.
To Exercise Your Rights
In order to exercise your Right to Opt-Out of the Sale, Sharing of your Personal Information or your Right to Limit the Use of Your Sensitive Personal Information, please contact us.
We may need to obtain information about you or your specific request in order to verify your identity and respond.
Shine the Light Disclosure
We do not share personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by contacting our offices. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.
Contacting Us About Privacy Questions
If you have questions or concerns regarding this Privacy Policy, you should contact us by email at info@greenbrickgroup.com.
Changes to the Privacy Policy
We reserve the right to modify or supplement this Online Privacy Policy at any time. Therefore, we recommend you review this Online Privacy Policy, updated and posted on this Site, regularly for changes. If we make changes to the Privacy Policy, we will revise the “Last Updated” date at the top of this Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the site. Your use of Green Brick Group services following these changes means you accept the revised Privacy Policy.