Effective Date: August 8, 2026 | Last Updated: August 8, 2026
Oliver Twists LLC, DBA Cody Lassen & Associates (“Company,” “we,” “us,” or “our”), operates the website located at www.codylassen.com (the “Site”). We respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site, submit inquiries, or interact with our messaging and communication services.
Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Site.
1. Information We Collect
We may collect information about you in a variety of ways when you interact with our Site, submit contact forms, or opt in to receive communications:
- Personal Information: When you voluntarily submit information through our contact forms, newsletter sign-ups, or text messaging opt-in forms, we may collect personally identifiable information, such as your full name, email address, postal address, telephone number, and professional affiliations.
- Investment and Business Information: If you are an investor, potential investor, co-producer, or creative partner, we may collect professional background details, investment history, entity details, and accredited investor verification information as necessary for our business operations and regulatory compliance (including Regulation D private placements under the Securities Act of 1933).
- Automatically Collected Information: When you access the Site, our servers automatically collect certain technical information, including your IP address, browser type, operating system, access times, pages viewed, and the referring website URL.
- Cookies and Tracking Technologies: We use cookies, web beacons, and similar tracking technologies to enhance your experience on our Site and analyze site traffic. See Section 5 for more detail.
2. How We Use Your Information
We use the information we collect for various business and operational purposes, including to:
- Operate, maintain, and improve our Site, services, and communications.
- Respond to inquiries, provide customer support, and communicate regarding theatrical productions, film projects, and investment opportunities.
- Send administrative information, such as updates to our terms, conditions, and policies.
- Send marketing communications, newsletters, updates, and text messages, provided you have given explicit consent to receive them.
- Comply with legal obligations, including securities regulations applicable to Regulation D private placements, enforce our legal terms, protect our rights, and prevent fraudulent or illegal activities.
3. SMS / Text Messaging Disclosures
If you opt in to receive text messages from Cody Lassen & Associates (including updates, news, administrative messages, or promotional communications), the following terms and disclosures apply:
- Opt-In Consent: You may opt in to receive text messages by checking an opt-in box on our website form or by texting a designated keyword. Consent is entirely voluntary and is not a condition of purchasing any goods or services. Opt-in checkboxes are unchecked by default.
- Message Frequency: Message frequency varies depending on your interactions with us and your selected preferences.
- Cost: Message and data rates may apply. Please contact your wireless carrier for details.
- Opt-Out Instructions: Reply STOP to any text message to unsubscribe. You will receive a single confirmation message and no further texts will be sent unless you opt in again.
- Help and Support: Reply HELP to any message or contact us using the details in Section 15.
- Carrier Liability: Wireless carriers are not liable for any delayed or undelivered messages.
4. Sharing of Your Information
We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:
- Service Providers: We may share information with trusted third-party vendors, consultants, and service providers (such as our CRM and SMS infrastructure providers like Twilio) who assist us in operating our Site, strictly on a confidential basis and solely for the purpose of performing services on our behalf.
- Legal Compliance and Protection: We may disclose your information if required to do so by law or in good faith belief that such action is necessary to comply with legal obligations (including securities regulations), protect and defend our rights or property, prevent fraud, or protect the personal safety of users or the public.
- Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
5. Cookies and Tracking Technologies
We and our third-party service providers use the following types of cookies and similar technologies on our Site:
- Essential Cookies: Necessary for the Site to function properly. These cannot be disabled without impairing Site functionality.
- Analytics Cookies: Used to collect aggregate information about how visitors use our Site (e.g., Google Analytics).
- Marketing / Advertising Cookies: Used to deliver relevant advertisements and track campaign performance (e.g., Facebook Pixel, LinkedIn Insight Tag). These cookies may track your activity across other websites.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. Residents of certain states (including California, Colorado, and Connecticut) may have additional rights regarding cookies used for targeted advertising — see Sections 8 and 9 below.
6. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal and regulatory obligations (including recordkeeping requirements under securities regulations applicable to Regulation D private placements), to resolve disputes, and to enforce our agreements. When personal information is no longer needed, we will securely delete or anonymize it. Investment-related records may be retained for a minimum of seven (7) years as required by applicable law.
7. Third-Party Links and Services
Our Site may contain links to third-party websites, platforms, or services — including social media platforms such as LinkedIn, Facebook, and Instagram — that are not operated or controlled by us. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices or content of any third-party website and encourage you to review the privacy policies of any site you visit.
8. California Privacy Rights (CCPA / CPRA)
If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include:
- Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes, and the categories of third parties with whom we share it.
- Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions.
- Right to Correct: You have the right to request that we correct inaccurate personal information we hold about you.
- Right to Opt Out of Sale or Sharing: We do not sell your personal information. However, our use of certain advertising cookies and pixels (e.g., Facebook Pixel) may constitute “sharing” under the CPRA. You may opt out by adjusting your cookie preferences or contacting us.
- Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information (such as financial data), you have the right to limit its use to what is necessary to perform the services you requested.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
To exercise any of these rights, please contact us at the information listed in Section 15. We will respond to verified requests within 45 days, with up to a 45-day extension where reasonably necessary.
9. Additional State Privacy Rights
Residents of Colorado, Connecticut, Virginia, Texas, and other states with comprehensive privacy laws may have similar rights to access, correct, delete, and opt out of certain processing of personal information. To exercise any such rights, please contact us at the information in Section 15. We will honor verified requests in accordance with applicable state law.
10. International Users and GDPR Notice
Our Site is operated in the United States. If you are accessing the Site from the European Union, European Economic Area, United Kingdom, or other regions with laws governing data collection and use, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.
If you are located in the EU/EEA or UK, we process your personal information on the following legal bases under the GDPR:
- Consent: Where you have explicitly opted in to receive communications from us.
- Legitimate Interests: Where processing is necessary for our legitimate business interests and those interests are not overridden by your rights.
- Legal Obligation: Where processing is required to comply with applicable law.
EU/EEA/UK residents have the right to access, rectify, erase, restrict, or object to processing of their personal data, and the right to data portability. To exercise these rights or to lodge a complaint with a supervisory authority, please contact us using the details in Section 15.
11. Security of Your Information
We implement reasonable and appropriate administrative, technical, and physical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. In the event of a data breach that affects your rights, we will notify you as required by applicable law.
12. Your Choices and Rights
- Opt-Out of Marketing: You may opt out of receiving promotional emails from us by following the unsubscribe instructions provided in those emails. For SMS communications, reply STOP.
- Access and Correction: You may request access to, correction of, or deletion of your personal information by contacting us at the address below.
- Do Not Track: Our Site currently does not respond to “Do Not Track” signals from browsers.
13. Children’s Privacy
Our Site and services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information promptly.
14. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time. When we make changes, we will revise the “Last Updated” date at the top of this page. Continued use of the Site after changes are posted constitutes your acceptance of the revised Policy.
15. Contact Information
If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us at:
Oliver Twists LLC d/b/a Cody Lassen & Associates
1501 Broadway, 12th Floor
New York, NY 10036
Email: info @codylassen.com
Phone: (646) 598-9560
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