Privacy Policy

Last Updated and Effective Date: February 18, 2026

This Privacy Policy describes how Bochi Investments, LLC (“we,” or “us”) collects, uses, discloses, and processes your Personal Information (“you” and “your”), as well as rights that you may have regarding that information. We reserve the right to change this Privacy Policy at any time. If we change our Privacy Policy, we will post an updated version on this website. Please check back periodically to see if our Privacy Policy has been updated. Updates to the Privacy Policy will be referenced by the "Last Updated and Effective Date" date shown above. By visiting this website, you acknowledge and consent to the privacy practices described in this Privacy Policy, including any revisions to this Privacy Policy that we post.

1. Definitions.

Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, household or device. “Personal Information” does not include: (a) information that is lawfully made available from federal, state, or local government records; (b) information that we have a reasonable basis to believe is lawfully made available to the general public by you from widely distributed media; or (c) information that is deidentified or aggregated consumer information.

Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial, ethnic, or national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (e) the contents of mail, email, and text messages unless we are the intended recipient of the communication; (f) genetic data; (g) information about a child; (h) biometric information for the purpose of uniquely identifying an individual; (i) mental health, physical health and pregnancy; (j) sex life or sexual orientation, including status as a trans or nonbinary individual; (k) status as a crime victim; and (l) neural data. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.

Please note that various jurisdictions may use different terms. For example, some jurisdictions use the terms “personal data” or “sensitive personal data”. Moreover, some jurisdictions do not consider some of the Personal Information listed in the Sensitive Personal Information definition above as Sensitive Personal Information.

2. Information We Collect and the Categories of Sources of Collection.

Set forth below are the categories of Personal Information we collect and have collected in the preceding 12 months and the categories of sources from which the Personal Information was collected. Please note that we may not collect all of the information referenced below regarding you.

Category of Personal Information What We Collect Categories of Sources from which Personal Information Collected
PERSONAL INFORMATION
Personal Identifiers
Real name
Alias
Postal address
Telephone number
Email address
Signature
Characteristics or description
Directly from you
Automatically, such as when you visit our website (e.g., cookies and tracking technologies)*
Our service providers
Inferences
Note: This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Directly from you
Automatically, such as when you visit our website (e.g., cookies and tracking technologies)*
Our service providers

* See the section entitled Online Technologies below.

We do not use or disclose Sensitive Personal Information.

We also collect aggregated, de-identified or anonymous data that does not identify individual consumers. We collect this information for various purposes such as statistical or demographic data for legitimate business purposes not prohibited herein or by law. We commit to maintain and use such data without attempting to re-identify the data.

3. Business or Commercial Purpose for the Collection of Personal Information.

Set forth below are the business or commercial purpose for our collection of Personal Information. Please note that we may not use your Personal Information for all purposes set forth in this Privacy Policy.

  • If you provide services to us or have a business dealing with us (or are employed or engaged by an organization which provides services to us or has a business dealing with us)
  • To create, maintain, and verify accounts and identities
  • To respond to inquiries, send notices, messages, and related communications
  • To conduct marketing and advertising
  • To operate our website
  • To operate and manage IT and communications systems and facilities, including functionality and debugging of our website
  • To maintain security on our websites and internet-connected assets and to detect fraud
  • To audit ad impressions
  • To analyze usage and trends
  • To audit interactions, transactions, and compliance
  • To detect and prevent security incidents
  • To protect against malicious, deceptive, fraudulent, or illegal activity
  • To maintain the integrity of our systems and data
  • To identify and fix errors that impair functionality.
  • To undertake internal research and development
  • To prevent and manage fraud and abuse
  • To manage risk
  • To meet and comply with legal, regulatory, tax, and reporting obligations
  • To enforce contracts and terms
  • To exercise or defend legal claims
  • See also the next section regarding Online Technologies
4. Online Technologies.

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. We and our service providers and partners use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, to gather demographic information about our user base as a whole and to provide marketing.

We use several types of cookies and other tracking technologies on our website, as described below.

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it and on third-party websites more relevant to your interests.
  • Third-party cookies. These cookies are placed on your device by a website from a domain other than our website. These parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies include analytical cookies, performance cookies and targeting cookies.
    • We use third party advertising companies to place ads. We do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our site. The data received by our third party advertising and social media partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests.
    • We use Google Analytics to ensure website functionality and improve our website and services. This software may record information such as your IP address, location, age and gender, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter and other actions you take while visiting us, the pages you view immediately before and after you access the services, how often you use our Services, aggregated usage and performance data, app errors and debugging information. Data collected by Google is subject to its privacy policy. To learn how Google uses data related to website analytics, please click here. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here.

In addition, we use web beacons and pixels, which are images that can be placed in web pages and some forms of email. These technologies can be used to deliver cookies and to collect information about your use of the site. Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel. We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our site. Other entities may have access to some of this information.

Emails that we and our service providers send may include similar technologies that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email. More information on how to unsubscribe from our marketing emails is found below.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

By using our website and services you affirmatively agree to the use of online technologies disclosed in this Privacy Policy.

5. Personal Information We Disclose, Share for Targeted Advertising or Sell and the Purpose for It.
Disclosure of Personal Information to Service Providers

We disclose your Personal Information to service providers, vendors, and contractors that perform services on our behalf. We disclose and have disclosed in the preceding 12 months the foregoing categories of Personal Information to our service providers and contractors for the following business purposes:

  • Auditing of Ad Impression: We disclose Personal Information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
  • Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.
  • Short-Term / Transient Use: We disclose Personal Information for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s Personal Information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
  • Services on Our Behalf: We disclose Personal Information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
  • Advertising and Marketing Services: We disclose Personal Information to provide advertising or marketing services on our own behalf.
  • Research & Development: We disclose Personal Information for internal research related to technological development and demonstration.
  • Quality Control & Improvement of Products and Services: We disclose Personal Information to verify, maintain, and improve our products and services.
As Necessary Disclosures

We may also use and/or disclose Personal Information, as necessary: (a) to comply with any law, regulation and/or legal process and/or exercise or defend legal claims; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose your Personal Information to our subsidiaries and affiliates or in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You acknowledge that such transfers may occur and that any acquirer of or successor to us may continue to use your Personal Information as set forth in this Privacy Policy.

Selling and Sharing (for Targeted Advertisement) of Personal Information

We do not sell your Personal Information as that term is commonly understood to be disclosure of your Personal Information in exchange for money. Rather, as used herein, definition of sale includes situations where another company can use your Personal Information for its own purposes. Please see the Online Technologies section above.

As noted in the Online Technologies section, we use third party cookies.

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Our Retention Policy – How Long We Keep Your Personal Information.

We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Data Security.

We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process and disclose. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

7. Email Communications.

You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in our commercial emails we send, or by sending us a request to info@bochiinvestments.com. If you opt-out of receiving marketing email communications, we may still send you email messages related to specific transactions with us. Unsubscribing yourself from our marketing communications will not affect our service to you.

8. Children.

We do not direct our websites or applications to children under thirteen (13) years of age. We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever. We do not allow persons known to be under 13 years of age to receive direct marketing communications from us. No information should be submitted to our website or applications by persons under 13 years of age. When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein.

9. Your State Privacy Rights.

Depending on your state of residency, you may have certain rights related to your personal data, including:

  • Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
  • Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
  • Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.
  • Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us by emailing us at info@bochiinvestments.com. To appeal a decision regarding a consumer rights request contact us by emailing us at info@bochiinvestments.com.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your Personal Information are not sales under Nevada law, so no opt-out right applies.

10. How to Contact Us.

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by emailing us at info@bochiinvestments.com or by mail at 525 3rd Street, Lake Oswego, OR 97034.