Attorney Client Trustees & Services and its affiliates (“ACTS Fi,” “we,” “us,” and “our”) respect your privacy and are committed to protecting it through compliance with this privacy policy (“Policy”). This Policy applies to ACTS Fi’s website at www.actsfi.com as well as all other Attorney Client Trustees & Services online properties (the “Site(s)”), mobile applications, social media pages, communications between you and ACTS Fi, and all other ACTS Fi services (collectively the “Services”).
This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
This Policy describes the types of Information we may collect from you when you use our Services and our practices for collecting, using, maintaining, protecting, and disclosing that Information.
Please read this Policy to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use our Services. By accessing our Services, you agree to this Policy.
ACTS Fi may change this Policy at any time, at its discretion. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Policy is subject to and governed by the terms of use for the Site (“Terms of Use”) available at the Site here.
We collect personally-identifiable information (“Information”) from you directly, from the devices you use to interact with us, and from third parties. We may combine Information from the Services with other data we obtain from our business records. We may use and share Information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (remove all unique identifiers such that it cannot be linked to a particular individual) at our discretion.
We collect Information:
- Directly from you when you provide it to us.
- Through our communications with you.
- From third parties.
- When you use our Services.
- Automatically as you navigate through the Site.
- Through Google Analytics.
- Information that you provide when you create an account on our Site or subscribe to our mailing list.
- Information that you provide by filling in forms on our Site. We may also ask you for Information when you report a problem with our Site. And it may be necessary for you to provide us with Information so we can communicate with you about an inquiry you have.
- Information contained in your communications with us, including call recordings of customer service calls.
- Your responses to surveys.
- Details of transactions you carry out through the Site and through our Services.
- Contact and professional information, including name, email address, telephone number, and job title, as well as company name and size.
- Demographic information.
- Audiovisual information.
- Payment information, including credit card information.
- Any other information you submit to us.
- The Internet Protocol Address and domain name used when you visit the Site. The Internet Protocol address is a numerical identifier assigned either to your internet service provider or directly to your computer. We use the Internet Protocol address to direct internet traffic to you.
- The type of browser and operating system you use when you visit the Site.
- The date and time you visited the Site.
- The web pages or services you accessed at the Site.
- The website you visited prior to coming to the Site.
- Cookies, which are small text files that a web server (such as ACTS Fi or its chosen web hosting company server) places on a user’s computer. With that number, our web server can tailor its content to the needs of the specific browser, and we can optimize the Site for your use.
We also may have the following Google Analytics Advertising Features Implemented: Demographics and Interest reporting, Remarketing, GDN Impression Reporting and Double Click Campaign Manager. These features collect data using Google advertising cookies and anonymous identifiers. ACTS Fi and third-party vendors use these first-party cookies to access the success of online marketing campaigns, inform future campaigns and improve usability on the Site. To learn how to opt-out of the Google Analytics Advertising Features we use, please see Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.
We use Information that we collect about you or that you provide to us, including any Information, for the following purposes:
- To present our Site and the Site Contents (as defined in the Terms of Use) to you.
- To provide you with the Services. For example, if you register an account through the Site, we will use the contact information you give us to communicate with you about the Services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Site or any Services we offer.
- To communicate with you regarding our Services, including for marketing purposes. This may include information about other services.
- To personalize our services and advertising to you.
- In any other way we may describe when you provide the Information.
- To fulfill any other purpose for which you provide it.
- For any other purpose with your consent.
- To improve our Site, products, and Services and to develop new products and Services.
- To protect and secure our Services.
- To comply with legal obligations and related needs.
Site statistics are compiled into traffic reports, which help ACTS Fi understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Site, we are likely to highlight that information on the Site home page. This Information helps us create a better overall experience for Site users.
ACTS Fi will retain your Information for as long as necessary to provide the Services you requested, comply with our legal obligations, resolve disputes, enforce our agreements, and achieve other business purposes.
We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
We may disclose Information that we collect, or you provide as described in this Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business, as described further below, including banking, third party payment and facilitators, online advertising partners, social media platforms, and other vendors.
- To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ACTS Fi assets, including any related due diligence.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the Information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ACTS Fi or others.
ACTS Fi does not sell any of your Information in exchange for monetary consideration. Our California section contains additional related disclosures that are specific to California law.
We use third parties to host the Site, design and operate the Site features, and to perform administrative, analytics, and payment processing related to our Services. Services these third parties provide include sending information to ACTS Fi about the use of the Site and viewing of our content. We may disclose your Information to these companies so they can carry out these operations. These companies are bound by contractual obligations to keep Information confidential.
The Site is not directed at children, and ACTS Fi does not knowingly collect any Information from children under 16 years of age. If ACTS Fi learns that a child under 16 years of age has provided Information, ACTS Fi will delete this Information from its databases. If you are under 16, do not use this Site or provide any Information about yourself to ACTS Fi, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please contact us at info@actsfi.com.
We are not responsible for the practices employed by websites or services linked to or from the Site, including the information or content contained therein. Our Policy does not apply to third-party websites or services.
Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Site does not respond to DNT signals.
If you choose not to provide Information, you may be unable to access all or portions of the Site or use our Services. If you no longer wish to receive marketing or promotional communications from us, click on the “unsubscribe link” provided in such communications or send us an email at info@actsfi.com.
If you opt out of receiving marketing/promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. Please report your concerns about collection or use of Information through the Site to info@actsfi.com.
When you apply for a job with us, we may collect Information from you, including:
- Information you provide in connection with your application.
- Information that you make available publicly in your social media accounts.
- Information about you that is available publicly.
- Information that you authorize us to collect via third parties, including former employers or references.
In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of Information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect Information that is subject to the CCPA, that information, our practices, and your rights are described below.
You have the right to know about our Information collection, use, and disclosure practices. The following table summarizes the categories of Information we collect; the categories of sources of that Information; whether we disclose, sell, or share that Information to service providers or third parties; and the criteria we use to determine the retention period for such Information. The categories we use to describe Information are those enumerated in the CCPA. We collect this Information for the purposes described above in “How We Use Your Information.”
We determine the retention period for each of the categories of Information listed above based on (1) the length of time we need to retain the Information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such Information, (3) internal operational needs, and (4) any need for the Information based on any actual or anticipated investigation or litigation.
Entities to whom we disclose Information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using Information for any purpose that is not related to our engagement or that is otherwise not permitted by law.
Entities to whom we “sell” or with whom we “share” Information are third parties. Under the CCPA, a business “sells” Information when it discloses Information to a company for monetary or other benefit. A company may be considered a third party either because we disclose Information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using Information for purposes unrelated to the service it provides to us. A business “shares” Information when it discloses Information to a company for purposes of cross-context behavioral advertising.
You have the right to request access to Information collected about you and data regarding the source of that Information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct Information that we have collected about you and to delete Information that we have collected directly from you. Please contact us to exercise these rights.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Information to third parties for their own direct marketing purposes in the preceding calendar year. Please contact us to obtain this information.
Privacy notices provided to ACTS Fi employees and job applicants in California supersede this Policy.
To exercise the access, data portability, and deletion rights described in the jurisdiction-specific sections above, please submit a form on this page or make a request by email to info@actsfi.com. There are exceptions, so not all of these rights may apply to you. If you have questions regarding these exceptions, please contact us at info@actsfi.com. Authorized agents may submit their request though those means as well.
We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against Information we may have collected from you previously. We may need to follow up with you to request more data to verify identity. We will not use Information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Information. You may also make a verifiable consumer request on behalf of your minor child. We will likely request additional information that will enable us to verify your identity.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial. You may only make a verifiable consumer request for access or data portability once within a 12-month period.
California residents may also exercise their rights by accessing the Your Privacy Rights and associated Site page.
ATTN: Legal Department,
451 A Street,
Suite 1600,
San Diego, CA 92101
Headquartered in
San Diego, California
Attorney Client Trustees & Services and its affiliates (“ACTS Fi,” “we,” “us,” and “our”) respect your privacy and are committed to protecting it through compliance with this privacy policy (“Policy”). This Policy applies to ACTS Fi’s website at www.actsfi.com as well as all other Attorney Client Trustees & Services online properties (the “Site(s)”), mobile applications, social media pages, communications between you and ACTS Fi, and all other ACTS Fi services (collectively the “Services”).
This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.
This Policy describes the types of Information we may collect from you when you use our Services and our practices for collecting, using, maintaining, protecting, and disclosing that Information.
Please read this Policy to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use our Services. By accessing our Services, you agree to this Policy.
ACTS Fi may change this Policy at any time, at its discretion. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.
This Policy is subject to and governed by the terms of use for the Site (“Terms of Use”) available at the Site here.
We collect personally-identifiable information (“Information”) from you directly, from the devices you use to interact with us, and from third parties. We may combine Information from the Services with other data we obtain from our business records. We may use and share Information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (remove all unique identifiers such that it cannot be linked to a particular individual) at our discretion.
We collect Information:
- Directly from you when you provide it to us.
- Through our communications with you.
- From third parties.
- When you use our Services.
- Automatically as you navigate through the Site.
- Through Google Analytics.
- Information that you provide when you create an account on our Site or subscribe to our mailing list.
- Information that you provide by filling in forms on our Site. We may also ask you for Information when you report a problem with our Site. And it may be necessary for you to provide us with Information so we can communicate with you about an inquiry you have.
- Information contained in your communications with us, including call recordings of customer service calls.
- Your responses to surveys.
- Details of transactions you carry out through the Site and through our Services.
- Contact and professional information, including name, email address, telephone number, and job title, as well as company name and size.
- Demographic information.
- Audiovisual information.
- Payment information, including credit card information.
- Any other information you submit to us.
- The Internet Protocol Address and domain name used when you visit the Site. The Internet Protocol address is a numerical identifier assigned either to your internet service provider or directly to your computer. We use the Internet Protocol address to direct internet traffic to you.
- The type of browser and operating system you use when you visit the Site.
- The date and time you visited the Site.
- The web pages or services you accessed at the Site.
- The website you visited prior to coming to the Site.
- Cookies, which are small text files that a web server (such as ACTS Fi or its chosen web hosting company server) places on a user’s computer. With that number, our web server can tailor its content to the needs of the specific browser, and we can optimize the Site for your use.
We also may have the following Google Analytics Advertising Features Implemented: Demographics and Interest reporting, Remarketing, GDN Impression Reporting and Double Click Campaign Manager. These features collect data using Google advertising cookies and anonymous identifiers. ACTS Fi and third-party vendors use these first-party cookies to access the success of online marketing campaigns, inform future campaigns and improve usability on the Site. To learn how to opt-out of the Google Analytics Advertising Features we use, please see Google Analytics’ currently available opt-outs for the web at https://tools.google.com/dlpage/gaoptout.
We use Information that we collect about you or that you provide to us, including any Information, for the following purposes:
- To present our Site and the Site Contents (as defined in the Terms of Use) to you.
- To provide you with the Services. For example, if you register an account through the Site, we will use the contact information you give us to communicate with you about the Services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Site or any Services we offer.
- To communicate with you regarding our Services, including for marketing purposes. This may include information about other services.
- To personalize our services and advertising to you.
- In any other way we may describe when you provide the Information.
- To fulfill any other purpose for which you provide it.
- For any other purpose with your consent.
- To improve our Site, products, and Services and to develop new products and Services.
- To protect and secure our Services.
- To comply with legal obligations and related needs.
Site statistics are compiled into traffic reports, which help ACTS Fi understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Site, we are likely to highlight that information on the Site home page. This Information helps us create a better overall experience for Site users.
ACTS Fi will retain your Information for as long as necessary to provide the Services you requested, comply with our legal obligations, resolve disputes, enforce our agreements, and achieve other business purposes.
We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
We may disclose Information that we collect, or you provide as described in this Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business, as described further below, including banking, third party payment and facilitators, online advertising partners, social media platforms, and other vendors.
- To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ACTS Fi assets, including any related due diligence.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the Information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ACTS Fi or others.
ACTS Fi does not sell any of your Information in exchange for monetary consideration. Our California section contains additional related disclosures that are specific to California law.
We use third parties to host the Site, design and operate the Site features, and to perform administrative, analytics, and payment processing related to our Services. Services these third parties provide include sending information to ACTS Fi about the use of the Site and viewing of our content. We may disclose your Information to these companies so they can carry out these operations. These companies are bound by contractual obligations to keep Information confidential.
The Site is not directed at children, and ACTS Fi does not knowingly collect any Information from children under 16 years of age. If ACTS Fi learns that a child under 16 years of age has provided Information, ACTS Fi will delete this Information from its databases. If you are under 16, do not use this Site or provide any Information about yourself to ACTS Fi, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please contact us at info@actsfi.com.
We are not responsible for the practices employed by websites or services linked to or from the Site, including the information or content contained therein. Our Policy does not apply to third-party websites or services.
Some browsers incorporate a “Do Not Track” (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Site does not respond to DNT signals.
If you choose not to provide Information, you may be unable to access all or portions of the Site or use our Services. If you no longer wish to receive marketing or promotional communications from us, click on the “unsubscribe link” provided in such communications or send us an email at info@actsfi.com.
If you opt out of receiving marketing/promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. Please report your concerns about collection or use of Information through the Site to info@actsfi.com.
When you apply for a job with us, we may collect Information from you, including:
- Information you provide in connection with your application.
- Information that you make available publicly in your social media accounts.
- Information about you that is available publicly.
- Information that you authorize us to collect via third parties, including former employers or references.
In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of Information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect Information that is subject to the CCPA, that information, our practices, and your rights are described below.
You have the right to know about our Information collection, use, and disclosure practices. The following table summarizes the categories of Information we collect; the categories of sources of that Information; whether we disclose, sell, or share that Information to service providers or third parties; and the criteria we use to determine the retention period for such Information. The categories we use to describe Information are those enumerated in the CCPA. We collect this Information for the purposes described above in “How We Use Your Information.”
We determine the retention period for each of the categories of Information listed above based on (1) the length of time we need to retain the Information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such Information, (3) internal operational needs, and (4) any need for the Information based on any actual or anticipated investigation or litigation.
Entities to whom we disclose Information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using Information for any purpose that is not related to our engagement or that is otherwise not permitted by law.
Entities to whom we “sell” or with whom we “share” Information are third parties. Under the CCPA, a business “sells” Information when it discloses Information to a company for monetary or other benefit. A company may be considered a third party either because we disclose Information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using Information for purposes unrelated to the service it provides to us. A business “shares” Information when it discloses Information to a company for purposes of cross-context behavioral advertising.
You have the right to request access to Information collected about you and data regarding the source of that Information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct Information that we have collected about you and to delete Information that we have collected directly from you. Please contact us to exercise these rights.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Information to third parties for their own direct marketing purposes in the preceding calendar year. Please contact us to obtain this information.
Privacy notices provided to ACTS Fi employees and job applicants in California supersede this Policy.
To exercise the access, data portability, and deletion rights described in the jurisdiction-specific sections above, please submit a form on this page or make a request by email to info@actsfi.com. There are exceptions, so not all of these rights may apply to you. If you have questions regarding these exceptions, please contact us at info@actsfi.com. Authorized agents may submit their request though those means as well.
We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against Information we may have collected from you previously. We may need to follow up with you to request more data to verify identity. We will not use Information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Information. You may also make a verifiable consumer request on behalf of your minor child. We will likely request additional information that will enable us to verify your identity.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial. You may only make a verifiable consumer request for access or data portability once within a 12-month period.
California residents may also exercise their rights by accessing the Your Privacy Rights and associated Site page.
ATTN: Legal Department,
451 A Street,
Suite 1600,
San Diego, CA 92101
Headquartered in
San Diego, California