Privacy Policy

Adam Dunn CRE · adamdunncre.com

Last updated: July 1, 2026

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service, and tells you about your privacy rights and how the law protects you. We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

1.Interpretation and Definitions

Interpretation

Words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for you to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as "the Company," "we," "us," or "our") refers to Adam Dunn CRE, operated from Massachusetts, United States.
  • Cookies are small files placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses.
  • Device means any device that can access the Service, such as a computer, a cell phone, or a digital tablet.
  • Personal Data (or Personal Information) is any information that relates to an identified or identifiable individual.
  • Service refers to the website at adamdunncre.com.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
  • Website refers to Adam Dunn CRE, accessible from adamdunncre.com.
  • You means the individual accessing or using the Service.

2.Collecting and Using Your Personal Data

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. This may include:

  • Email address
  • First name and last name
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service and may include information such as your device's Internet Protocol (IP) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service through a mobile device, we may collect additional information automatically, including the type of mobile device, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data.

Tracking technologies and cookies

We use Cookies and similar tracking technologies to track activity on our Service and store certain information. We use both Session Cookies and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies (Session): essential to provide you with services available through the website and to authenticate users.
  • Cookie Policy / Notice Acceptance Cookies (Persistent): identify if users have accepted the use of cookies.
  • Functionality Cookies (Persistent): allow us to remember choices you make when you use the website, such as login details or language preference.

Where required by law, we use non-essential cookies only with your consent. You can withdraw or change your consent at any time through your browser or device settings.

3.Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor usage.
  • To manage your account and registration as a user of the Service.
  • For the performance of a contract: the development, compliance, and undertaking of any contract with us through the Service.
  • To contact you by email, telephone, SMS, or other electronic communication regarding updates or informative communications related to the Service.
  • To provide you with news, special offers, and general information about goods, services, and events we offer that are similar to those you have already inquired about, unless you have opted out.
  • To manage your requests to us.
  • For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets.
  • For data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, and to evaluate and improve our Service.

We may share your Personal Data in the following situations:

  • With Service Providers, to monitor and analyze the use of our Service, or to contact you.
  • For business transfers, in connection with any merger, sale of Company assets, financing, or acquisition of all or a portion of our business.
  • With Affiliates, in which case we will require those affiliates to honor this Privacy Policy.
  • With business partners, to offer you certain products, services, or promotions.
  • With your consent, for any other purpose disclosed to you.

4.Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. The following maximum retention periods apply:

  • Account information: duration of your account relationship plus up to 24 months after account closure.
  • Customer support data: up to 24 months from the date of ticket closure.
  • Usage Data (cookies, IP addresses, analytics): up to 24 months from the date of collection.
  • Server logs: up to 24 months for security monitoring and troubleshooting.

We may retain Personal Data beyond these periods where required by legal obligation, to establish or defend legal claims, at your explicit request, or due to technical backup limitations. When retention periods expire, we securely delete, anonymize, or remove Personal Data from our systems.

5.Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices in Massachusetts and in any other places where the parties involved in the processing are located. Your data may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or country unless adequate controls are in place, including the security of your data and other personal information.

6.Delete Your Personal Data

You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you. You may update, amend, or delete your information at any time by signing into your account and visiting account settings, or by contacting us directly. Please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

7.Disclosure of Your Personal Data

Business transactions

If the Company is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, such as a court or a government agency.

Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability

8.Security of Your Personal Data

The security of your Personal Data is important to us. While we strive to use commercially reasonable means to protect your Personal Data, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee its absolute security.

9.California Online Privacy Protection Act

CalOPPA notice. This section applies to residents of California and any other visitor to this website, as CalOPPA requires that any commercial website or online service that collects personally identifiable information from California consumers must conspicuously post a privacy policy.

In accordance with CalOPPA, we agree to the following:

  • Users can visit our site anonymously.
  • This Privacy Policy is accessible from our home page or at minimum the first significant page after entering our website, and includes the word "Privacy" so it can be found easily.
  • We will notify users of any Privacy Policy changes by updating the "Last updated" date at the top of this page. Material changes will also be communicated via email where we have your address.
  • Users are able to change their personal information by contacting us directly at our contact page.

Do Not Track

We honor Do Not Track (DNT) signals. When a Do Not Track signal is detected, we will not track you, plant cookies, or use advertising. California Business & Professions Code Section 22575(b) requires us to disclose how we respond to DNT signals. We do not track users across third-party websites and do not permit third parties to collect personally identifiable information about users' online activities over time and across different websites when those users use our Service.

10.California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

CCPA/CPRA notice. This section applies to California residents. The California Consumer Privacy Act of 2018 (CCPA), as amended and expanded by the California Privacy Rights Act of 2020 (CPRA, effective January 1, 2023), provides California residents with specific rights regarding their personal information. This section describes those rights and how to exercise them.

Personal information we collect

In the past 12 months, we have collected the following categories of personal information:

  • Identifiers: such as name, email address, and IP address.
  • Internet or other electronic network activity information: such as browsing history on our Service, interactions with our newsletter, and device identifiers.
  • Geolocation data: approximate location inferred from IP address.
  • Inferences: drawn from the above categories to create a profile about preferences and interests.

We collect this information from the following sources: directly from you when you provide it (for example, when subscribing to our newsletter or completing a contact form), automatically through your use of our Service, and from third-party analytics providers.

Purposes for collecting personal information

We collect your personal information for the following business or commercial purposes:

  • To provide, maintain, and improve our Service and newsletter.
  • To communicate with you, including sending The Dunn Report newsletter and updates about our brokerage services.
  • For analytics and research to understand how our Service is used.
  • To comply with legal obligations.
  • To detect, prevent, and address security incidents and fraud.

Sale or sharing of personal information

We do not sell your personal information to third parties for monetary consideration. However, under the CCPA/CPRA, sharing personal information with third-party advertising or analytics providers for cross-context behavioral advertising may constitute "sharing" under California law. To the extent we engage in such sharing, you have the right to opt out as described below.

Your rights as a California resident

Subject to certain exceptions, California residents have the following rights:

Right to know. You have the right to request that we disclose to you the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, our business or commercial purposes for collecting or sharing it, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected about you.

Right to delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions such as where we need the information to complete a transaction, detect security incidents, comply with a legal obligation, or exercise a legal right.

Right to correct. Under the CPRA, you have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

Right to opt out of sale or sharing. You have the right to opt out of the sale or sharing of your personal information. If you wish to exercise this right, please contact us using the information in Section 14. We will process your request within 15 business days.

Right to limit use of sensitive personal information. Under the CPRA, you have the right to direct us to limit our use of sensitive personal information to that which is necessary to perform the services or provide the goods you requested. We do not currently collect sensitive personal information as defined by the CPRA, but we will update this policy if that changes.

Right to non-discrimination. We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge you different prices, provide a different level or quality of goods or services, or suggest that you may receive a different price or quality of goods or services as a result of exercising your rights.

Exercising your California privacy rights

To exercise any of your California rights, you or your authorized agent may submit a verifiable consumer request by:

  • Visiting our contact page
  • Sending an email to the address listed on our contact page with the subject line "California Privacy Request"

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days total), we will inform you of the reason and the extension period in writing within the initial 45-day period. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why and provide a cost estimate before completing your request.

Data retention under CCPA/CPRA

We retain personal information for the minimum time necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention periods for each category of personal information are described in Section 4 above.

Authorized agent

You may designate an authorized agent to make a request under the CCPA/CPRA on your behalf. We will require the authorized agent to provide proof of your written permission and may require you to verify your identity directly with us. We may deny a request from an authorized agent who does not submit proof of authorization.

Annual CCPA/CPRA metrics

To the extent required by law, we will maintain records of consumer requests made under the CCPA/CPRA and our responses, and will include the required metrics in this Privacy Policy or a separate disclosure on an annual basis.

11.Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.

12.Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13.Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top. For material changes, we will provide additional notice via email where we have your address. You are advised to review this Privacy Policy periodically for any changes. Changes are effective when posted on this page.

14.Contact Us

If you have any questions about this Privacy Policy, your California privacy rights, or to submit a verifiable consumer request, you can contact us:

By visiting: adamdunncre.com/contact

For California privacy requests specifically, please include "California Privacy Request" in your subject line so we can route your inquiry appropriately.

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