Privacy Policy

We know that your privacy is important to you, and we work hard to earn and keep your trust. APBOE, LLC (collectively with its subsidiaries, “Company,” “the Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

The types of information we collect from you or that you may provide when you visit our website available at: https://www.apboe.com/ as well as any websites and blogs directly owned by the Company (collectively, our “Website”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Company or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Website Terms of Use; Other Agreements

This Policy should be read in conjunction with any applicable Website Terms of Use and Website Cookie Policy, into which this Policy is incorporated by reference.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”).

You may provide us Personal Information as a buyer, seller or user of the Website (referred to throughout this Policy as “you,” “your” and “user”). In particular, the Website has collected the following categories of Personal Information from users of the Website within the last twelve (12) months:

Category	Examples	Collected	Disclosed
Identifiers.	A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.	YES	YES – Affiliates and/or Service Providers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, telephone number, credit card number, debit card number, or any other financial information required by Company for the purchase of a subscription.	YES	YES – Affiliates and/or Service Providers.
Protected classification characteristics.	Age range.	YES	YES – Affiliates and/or Service Providers.
Commercial information.	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. You may become a “verified” user on our Website by providing the following information: Custodian/business dealer revenue report; profit and loss statement; and model investment portfolio.	YES	YES – Affiliates and/or Service Providers.
Sensitive Personal Information	financial account, debit card, credit card number, or other payment information.	YES	YES – Service Providers (i.e., PCI-DSS Payment Processors)
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	N/A
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES	YES – Affiliates and/or Service Providers.
Geolocation data.	Physical location or movements.	NO	N/A
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	N/A
Professional or employment-related information.	Current or past professional history.	YES	YES – Affiliates and/or Service Providers.
Non-public education information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	N/A
Inferences drawn from other Personal Information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	N/A

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, when you:
- register yourself with the Website;
- provide information about your company or business as a buyer or seller;
- subscribe to one of our e-newsletters; or
- communicate with us, such as request information.
Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
Directly and indirectly from activity on our Website. For example, from website usage details that are collected automatically. For more information on automatic information collection, please review our Cookie Policy.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password. Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous.

Credit Card Information. Please note that for any credit card information provided on the Website, we utilize a trusted third-party PCI-DSS compliant payment processor to process all of your transactions and it collects and maintains the necessary Personal Information needed to necessitate such transactions.

Aggregated and De-Identified Data. We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-Identified data could be derived from your Personal Information but is not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

Information of Other Individuals. As a user of the Website, you may have the opportunity to provide information of another company or other individuals, such as providing seller or buyer information in the pre-approval questionnaire. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and the Company shall not be responsible or held liable for your failure to obtain the necessary consents.

Recording Use of the Website. We may partner with trusted third-party vendors to analyze performance and traffic of our Website. This may include things like buttons you click, mouse movements and other behavior on the Website, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please see our Cookie Policy to learn more about cookies, pixels tags, and analytic technologies.

4. How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

Automated matchmaking between buyer and seller by identifying buyers’ PurchasingPower™ score and filtering buyers to the Seller’s needs and preferences.
providing the information, products and services you request;
security, credit or fraud prevention purposes;
providing you with effective customer service and support;
providing you with a personalized experience when you use the Website;
contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
contacting you with information and notices related to your use of the Website;
inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
better understanding your needs and interests;
improving the content, functionality and usability of the Website;
improving our products and services;
improving our marketing and promotional efforts; and
any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.

5. How We Disclose Your Information

We may disclose your Personal Information by disclosing it to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

We do not sell or lease your Personal Information to any third party. If we ever decide to sell Personal Information, we will update you via this Policy and provide you with an opportunity to opt out of sales of your Personal Information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

Our Affiliates. We may disclose the information collected through the Website with our affiliates, subsidiaries, and other related entities in order to provide our products, services and effective customer support.
Other users that are potential buyers or sellers.
Third-Party Service Providers. We disclose Personal Information collected through the Website with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing.
In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company. Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances:

Legal Reasons.
- We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
- To respond to duly authorized information requests from law enforcement or other governmental authorities;
- To enforce our agreements, policies, or the Terms of Use;
- To investigate and prevent security threats, fraud, or other malicious activity; or
- To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.”

Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

6. Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

When you create an account on the Website, you acknowledge and agree that we may send you marketing emails regarding our products or services. After you receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

7. Text Messaging

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

9. Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18). We do not target the Website to minors, and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

11. Important Notice & Disclaimers

Your Personal Information will always be processed by the Company in accordance with this Policy unless otherwise agreed to in writing. Nonetheless, it is important to advise you that certain privacy laws do not apply to the Website or our Services.

Gramm Leach Bliley Act (“GLBA”). Although we facilitate the matching of buyers and sellers in anticipation of potential financial transaction, we are not a financial institution and therefore not subject to the requirements of GLBA in the operating of this Website.

Fair Credit Report Act (the “FCRA”). The Company is not a “consumer reporting agency” or “reseller” as those terms are defined under the FCRA. The Company does not process, assemble, or merge any Personal Information to create or modify any consumer report. Accordingly, the FCRA does not apply to the Company’s processing of Personal Information as described in this Policy. While the Company may use information you provide through the Website to make determinations about your PurchasingPower™ score, the Company plays no role in a seller’s final determination of selecting a buyer for its business. All such determinations are the sole responsibility of the seller.

12. Your California Rights

California.

Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
Do Not Track Signals. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights.

Some state laws in the United States provide consumers with additional rights with respect to their Personal Information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your Personal Information, you may exercise each of your rights as identified below, subject to our verification of your identity.

Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Correction. You can correct what personal data our Website database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy
Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
Non-Discrimination. If a consumer exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, CTDPA, UCPA, and VCDPA, we shall not discriminate against that resident by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
Exercising your rights. If you are a consumer that has rights under applicable state law, including but not limited to the CCPA, CPA, CTDPA, UCPA, and VCDPA, who chooses to exercise the rights listed above, you can:
1. Submit a request via email at info@APBOE.com; or
2. Call us at (800)-263-4908 to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Nevada.

WE DO NOT SELL YOUR PERSONAL INFORMATION. Nevada residents can request their Personal Information not to be sold in the future. To make a request to opt-out of potential future selling of data, please contact us at info@APBOE.com.

13. For Website Users Outside of the United States

Our Website is designed for use by individuals in the United States only. We do not warrant or represent this Policy or the Website’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

14. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. As a user, you have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

15. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

16. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at:

APBOE, LLC
294 Grove Lane East
Suite 120
Wayzata, MN 55391

Email: info@APBOE.com

APBOE, LLC Website Privacy Policy

APBOE, LLC
Website Privacy Policy