Privacy Policy for Brummell Investment Group LLC

Effective Date: August 31, 2025

Brummell Investment Group ("Company," "we," "us," or "our"), a real estate wholesale company

that purchases houses from homeowners, is committed to protecting your privacy. This Privacy

Policy explains how we collect, use, disclose, store, and protect your personal information when

you interact with us, including through our SMS messaging program (the "Program"), website

(www.brummellinvestmentgroup.com), forms, phone calls, or in-person consultations. By

engaging with our services or opting into our Program, you agree to the practices described in

this Privacy Policy.

For questions about this Privacy Policy, contact us at:

• Email: [email protected]

[email protected]

• Phone: (945)297-2073

• Address: 30 N Gould Street Suite R Sheridan, Wy 82801

• Website: www.brummellinvestmentgroup.com/contact

We may update this Privacy Policy at any time, with changes posted at

www.brummellinvestmentgroup.com/privacy. Your continued engagement with our services or

Program after changes constitutes acceptance of the updated policy.

1. Information We Collect

We collect information to provide our home-buying services and operate our SMS Program. The

types of information we collect include:

a. Information You Provide

• Contact Information: Name, phone number, email address, and mailing address, provided

when you:

Opt into our SMS Program (e.g., by texting "SELL" or checking a box on our website).

Submit a form to discuss selling your house.

Contact us via phone, email, or in-person consultations.

• Property Information: Details about properties you wish to sell (e.g., address, condition,

ownership status).

• Transaction Details: Information related to property evaluations or purchase offers (e.g.,

financial details, closing preferences).

• Consent Records: Opt-in data for SMS messages (e.g., timestamp, IP address, keyword

used, or signed forms).

b. Information Collected Automatically

• Website Usage Data: If you visit www.brummellinvestmentgroup.com, we may collect:

IP address, browser type, device type, operating system, and pages visited.

Cookies or similar technologies to track preferences and improve user experience (see

Section 7).

SMS Interaction Data: Records of your interactions with our Program, such as messages

sent, replies (e.g., "YES," "STOP"), and opt-in/opt-out timestamps.

c. Information from Third Parties

Public Records: Property data from public sources (e.g., county records) to evaluate houses

you wish to sell.

• Service Providers: Data from SMS platforms (e.g., Twilio) or transaction partners (e.g., title

companies) to facilitate messaging or purchases, under strict confidentiality agreements.

2. How We Use Your Information

We use your information to operate our home-buying business and SMS Program, including:

• SMS Messaging Program:

Sending messages about offers to buy your house or transaction updates (e.g., appointment

reminders).

Managing opt-in and opt-out requests to comply with TCPA and CTIA guidelines.

• Home-Buying Services:

Evaluating properties you wish to sell and preparing cash offers.

Processing transactions, such as property purchases or contract assignments.

• Business Operations:

Responding to inquiries or customer service requests.

Improving our website, services, and Program through analytics.

• Legal Compliance:

Maintaining records of SMS consent to comply with TCPA and carrier requirements.

Complying with applicable laws, such as Missouri real estate regulations or CCPA.

We do not use your information for purposes unrelated to our home-buying services or Program

without your consent.

3. How We Share Your Information

We do not sell or rent your personal information to third parties for marketing purposes. We may

share your information in the following limited circumstances:

• Service Providers: With vendors who support our operations (e.g., SMS platforms like

Twilio, title companies, or CRM systems) under strict confidentiality agreements. These

providers are prohibited from using your data for other purposes.

Example: Your phone number is shared with an SMS provider to send messages.

• Transaction Partners: With entities involved in property purchases (e.g., title companies,

escrow agents) to facilitate deals, only with your consent or as necessary to complete a

transaction.

• Legal Obligations: When required by law, subpoena, or regulatory authority (e.g., to comply

with tax reporting or Missouri real estate regulations).

• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information

may be transferred but will remain subject to this Privacy Policy.

No mobile information (e.g., phone numbers, SMS opt-in data) will be shared with third parties

or affiliates for marketing or promotional purposes. All SMS opt-in data and consent records are

kept confidential, except as required for message delivery or legal compliance.

4. Your Choices and Rights

You have control over your information and participation in our Program:

• SMS Program:

Opt out by texting "STOP" to our 10DLC number or following instructions in our Terms of

Service (www.brummellinvestmentgroup.com/terms).

Rejoin by following the opt-in process (e.g., texting "SELL").

• Access and Deletion:

Request access to or deletion of your personal information by contacting us at

[email protected]

[email protected]. We will respond within the timeframe required by law

(e.g., 45 days for CCPA requests in California).

Note: We may retain certain data (e.g., transaction records, consent logs) as required by

law or for legitimate business purposes (e.g., tax reporting).

• CCPA Rights (California Residents):

If you are a California resident, you have the right to:

Know what personal information we collect, use, or disclose.

Request deletion of your information (subject to exceptions).

Opt out of the sale of your information (we do not sell your data).

Non-discrimination for exercising your rights.

To exercise these rights, contact us at

[email protected]

[email protected] or (945)297-2073

• Cookies: Adjust your browser settings to disable cookies (see Section 7).

5. Data Security

We use industry-standard security measures to protect your information, including:

• Encryption of sensitive data (e.g., phone numbers, opt-in records) in transit and at rest.

• Secure storage of consent records to comply with TCPA and carrier audits.

• Access controls to limit who can view your information within our organization.

However, no system is completely secure. We cannot guarantee the absolute security of your

data, especially against unauthorized access beyond our control (e.g., carrier network issues).

6. Data Retention

We retain your information only as long as necessary for the purposes described in this Privacy

Policy or as required by law:

• SMS Data: Phone numbers and consent records are retained to comply with TCPA and

carrier requirements (e.g., 2-5 years, depending on jurisdiction).

• Property and Transaction Data: Retained for the duration of our business relationship or as

required for tax, legal, or auditing purposes (e.g., 7 years for financial records).

• Website Data: Usage data (e.g., IP addresses) may be retained for up to 1 year for

analytics.

You may request deletion of your data (see Section 4), subject to legal retention obligations.

7. Cookies and Tracking Technologies

If you visit www.brummellinvestmentgroup.com, we may use cookies or similar technologies to:

• Track website usage (e.g., pages visited, time spent).

• Improve user experience (e.g., remembering form inputs).

• Analyze site performance via tools like Google Analytics.

You can disable cookies in your browser settings, but this may affect website functionality. For

details, review our Cookie Policy (if applicable) at www.brummellinvestmentgroup.com/cookies.

8. Third-Party Links

Our website or messages may contain links to third-party sites (e.g., title companies, real estate

resources). We are not responsible for their privacy practices. Review their policies before

providing information.

9. Real Estate Disclaimers

• Property Data: Property information (e.g., address, condition) is collected to evaluate

potential purchases. We may verify data using public records.

• No Guarantees: Providing information does not guarantee a property purchase. All offers

are subject to evaluation and mutual agreement.

• Not a Broker: Brummell Investment Group is a real estate wholesaler, not a licensed real

estate broker, unless otherwise stated. We do not act as your agent unless explicitly agreed.

10. International Users

Our services are intended for U.S. residents. If you are outside the U.S., your information may

be processed in the U.S., where privacy laws differ. By engaging with us, you consent to this

transfer. For GDPR compliance (if applicable), contact us to discuss additional protections.

11. Children’s Privacy

Our services and Program are not intended for individuals under 18. We do not knowingly

collect information from minors. If you believe we have collected data from a minor, contact us at

[email protected] to request deletion.

12. Compliance with TCPA and CTIA

We comply with TCPA and CTIA guidelines for our SMS Program:

• We obtain prior express written consent before sending marketing messages.

• Consent records are securely stored and not shared, except as needed for message

delivery.

• Messages include required disclosures (e.g., opt-out instructions, program details).

• We honor opt-out requests promptly by removing you from the Program.

13. Contact Us

For questions, requests, or complaints about this Privacy Policy or our practices, contact us at:

• Email: [email protected]

[email protected]

• Phone: (945)297-2073

• 30 N Gould Street Suite R Sheridan, Wy 82801

We will respond promptly, typically within 30 days, or sooner if required by law (e.g., 45 days for CCPA).

Brummell Investment Group LLC 30 N Gould Street Suite R Sheridan, Wy 82801 (945)297-2073

[email protected]

[email protected] | www.brummellinvestmentgroup.com