1. Introduction
BDF FUND, LLC respects the privacy of every person who visits our website, contacts our office, or becomes a partner in our private capital program. This Privacy Policy explains what information we gather, why we gather it, how we hold it, and what choices you have. The firm is a private fund administrator that pools patient capital for small Utah operators and property owners. The developer named in our site materials is BDF Fund, and the operating company is BDF FUND, LLC. Our registered location is 571 N 1420 E, Logan - 84321-4371, United States (US).
We wrote this policy in plain language so that a reader does not need a legal dictionary to understand it. If any part of this policy is unclear, please contact us using the details in the final section and we will explain the practice that applies to your situation. Our goal is a record that stands level, just as the rest of our work does.
2. Scope of This Policy
This policy covers the personal information that BDF FUND, LLC collects through our website at bdffund.autos, through written and verbal communications with our subscription desk, and through the administration of partner interests in the fund. It applies to prospective partners, current partners, former partners, website visitors, operators who explore a working relationship with us, and any other person who shares information with our office.
This policy does not apply to websites operated by other companies, to services offered by third parties, or to information that you share directly with an operator that is independent of BDF FUND, LLC. When we link to another site or work with a third party, that party applies its own privacy practices, and we encourage you to review them.
3. Information We Collect
We collect information that you provide directly, information that arises from your use of our website, and information that we receive from lawful sources in the course of administering a fund. The categories below describe the kinds of data we may hold.
Identity and contact data
This includes your name, postal address, email address, telephone number, and the names of any entity through which you invest or operate. For partners, it also includes government issued identifiers and documentation that applicable law requires us to verify.
Financial and subscription data
This includes your subscription amount, the date of your commitment, bank account details used for contributions and distributions, tax identification information, and the allocation and redemption history attached to your interest.
Correspondence data
This includes written inquiries, phone notes, emails, signed consents, and the record of any question you raise with our desk and the answer we provide.
Technical data
This includes the internet protocol address from which you visit our site, the type of browser and device you use, the pages you view, and the times of those visits. We use this data in aggregate to keep the site working and to understand which pages serve visitors well.
4. How We Collect Information
We collect information directly from you when you complete a contact form, call our office, send an email, sign a subscription packet, or correspond with our desk by any channel. We collect information automatically when your browser requests a page from our website, because our server records standard request data as part of normal operation.
We may also receive information from lawful third parties. For example, a bank may confirm the arrival of a wire, a verification service may confirm an entity record, or a referring operator may introduce a prospective partner with that person consent. When we receive information from another source, we treat it under this same policy.
5. Why We Use Information
BDF FUND, LLC uses personal information for defined purposes. We use it to respond to inquiries, to open and maintain subscription files, to verify identity as the law requires, to process contributions and distributions, to run quarterly allocations, to prepare investor statements, to maintain side-pocket records, to assemble audit trails, to process redemptions and transfers, and to meet our own accounting and legal obligations.
We also use information to protect the fund and its partners against fraud, to enforce our agreements, to resolve disputes, and to improve the clarity of our website and our written materials. We do not sell personal information, and we do not use personal information for advertising networks.
6. Legal Bases for Processing
Where the law requires a legal basis for processing, we rely on one or more of the following. We process information to perform a contract with you, such as administering your interest in the fund. We process information to comply with legal obligations, such as identity verification and tax reporting. We process information for our legitimate interests, such as protecting the fund, improving our services, and communicating with partners, provided those interests are not outweighed by your rights. Where we rely on consent, you may withdraw that consent at any time.
We keep the purposes for which we hold information narrow and specific. When a new purpose arises, we either seek consent or confirm that another lawful basis supports the use before we begin.
7. Subscription and Onboarding Records
When you begin a subscription with BDF FUND, LLC, we create a file that contains your signed documents, your entity records, your signer authority, your source of funds information, and the instructions that govern your contributions and distributions. This file exists so that every dollar can be traced from the first commitment to the final distribution.
Onboarding records are sensitive because they include identity and banking information. We limit access to the staff and service providers who need the file to do their work, and we log access where our systems permit. We keep these records for as long as your interest remains active and for the period afterward that applicable law and good accounting practice require.
8. Allocation and Reporting Data
Each quarter we calculate the allocation of income and expense across the pool. That work produces figures tied to your interest, and those figures appear on the statements we issue to you. The underlying worksheets, the cash reconciliations, and the register entries form part of your personal record with the fund.
We use this data to produce accurate statements, to answer your questions about a figure, and to support the audit index. We do not disclose your allocation figures to other partners. A partner sees the partner share of the whole only in the form that the operating agreement requires, never as a disclosure of another person private balance.
9. Side-Pocket and Valuation Records
When a holding moves slowly, we set it into a side pocket and track it apart from the liquid line. Side-pocket records include the original cost, the carrying value, the valuation notes, and the reason the holding remains set apart. These records may contain information about a specific property or operator, and we treat that information as confidential.
We disclose side-pocket balances to the partners who hold an interest in the relevant pocket and to the service providers who help us value or audit the holding. We do not publish side-pocket details, and we do not share them with parties who have no interest in the asset.
11. Service Providers and Processors
Like most fund administrators, we rely on third parties for specific tasks. A bank may hold fund accounts and process wires. An accounting firm may assist with reconciliations. An auditor may review the books. A technology provider may host this website and store our documents. A communication vendor may deliver email.
We select providers with care and we contract with them to limit their use of personal information to the service they provide to us. We do not authorize a provider to use partner information for its own marketing. If a provider breaches its obligations, we take steps to protect the fund and the affected persons.
13. Data Retention
We keep personal information only as long as we need it for the purpose we collected it, and as long as the law and sound accounting practice require. Subscription files, allocation records, side-pocket notes, and audit materials are kept for the life of the fund and for the period afterward that regulators and accountants consider necessary.
When information is no longer needed, we delete it or render it unreadable. When deletion is not possible because information sits in a backup or an archive, we isolate it and limit access until deletion becomes possible. We do not keep personal information indefinitely without a purpose.
14. How We Protect Information
We use administrative, technical, and physical safeguards to protect personal information. These include limiting access to staff who need it, using secure methods to transmit sensitive data, keeping software current, and storing paper files in a controlled space. We train our staff on confidentiality and we review our practices as the fund grows.
No system is perfectly secure. If we learn of a breach that affects personal information, we investigate promptly, take steps to limit harm, and notify affected persons and authorities as the law requires. We ask that you protect your own information as well, including by using a secure email account and by contacting us immediately if you suspect that someone has used your identity in connection with the fund.
15. Your Privacy Rights
Subject to applicable law, you may have the right to know what personal information we hold about you, to request a copy, to ask us to correct information that is wrong, to ask us to delete information that we no longer need, and to ask us to limit certain uses. You may also have the right to object to processing and to withdraw consent where consent is the basis for the use.
To exercise a right, contact us using the details in the final section. We will verify your identity before we act, because we must not release one person information to another. We will respond within the time the law allows. If we cannot honor a request, we will explain the reason and the remedy available to you.
16. California Privacy Notice
If you are a California resident, you may have additional rights under California law. These rights include the right to know the categories and specific pieces of personal information we have collected, the right to know the sources of that information, the right to know the business purposes for which we use it, and the right to know the categories of third parties with whom we share it. You also have the right to request deletion, to request correction, and to be free from discrimination for exercising your rights.
BDF FUND, LLC does not sell personal information, and the firm does not share personal information for cross context behavioral advertising. To make a request, contact us using the details in the final section and state that you are a California resident making a privacy request. We will verify your identity and respond as the law requires. An authorized agent may make a request on your behalf when the agent provides written permission and we can verify your identity.
17. Privacy for Children
Our website and our services are intended for adults. BDF FUND, LLC does not knowingly collect personal information from children under the age of thirteen. If we learn that we have collected information from a child under thirteen without the required consent, we will delete it promptly. If you believe that a child has provided information to us, please contact us using the details in the final section and we will act without delay.
Because our work concerns capital and property, our services are not directed to minors in any respect, and we do not market to minors. This section stands as our commitment to keep the fund record free of information that does not belong there.
18. International Visitors
BDF FUND, LLC operates in the United States, and our records are held primarily in the United States. If you visit our website from another country, you understand that the information you provide will be transferred to and processed in the United States, where privacy laws may differ from those in your home country. Where the law requires additional safeguards for a cross border transfer, we put those safeguards in place before the transfer occurs.
We serve partners and operators who work within the United States, and we describe the transfer in this section so that a visitor from abroad can make an informed choice about using our site and contacting our office.
19. Changes to This Policy
We may update this Privacy Policy from time to time. When we make a material change, we post the updated policy on this page and revise the last updated date at the top. We may also notify partners by email or by a notice on the website when the change is significant. We encourage you to review this page periodically so that you understand the practices that apply.
Your continued use of our website or your continued partnership with the fund after a change takes effect means that you accept the updated policy. If you do not agree with a change, you may contact us to discuss your options, including the options available under your operating agreement.
20. How to Contact Us
If you have a question about this Privacy Policy, or if you wish to exercise a privacy right, please contact BDF FUND, LLC using the details below. We answer written inquiries within one business day and we log every request so that nothing is lost.
When you write to us about privacy, please include enough detail for us to locate your record, such as the name on your subscription file and the email address you used. We will confirm receipt, verify your identity, and proceed as the law allows.
Our commitment: BDF FUND, LLC treats personal information the way it treats every line on the wall. It is set carefully, checked against the record, and held to the same standard through every season.