Privacy Policy

Last Revised: May 2023

Sanguine Strategic Advisors (hereinafter “Company” or “us” or “we”) is dedicated to protecting your privacy and providing you with the highest level of service. This Policy explains what Company does to keep information about you private and secure. This Policy covers only information that you provide to Company or that it obtains about you from companies that you have chosen to do business with. Please read this Policy carefully and contact us if you have any questions.

This Privacy Policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

Agreement to this Privacy Policy: By using this Website, you consent to this Privacy Policy, including your consent to our use and disclosure of information about you in the manner described herein. Exceptions to the aspects of this policy may apply depending on where you may reside.

Conflict Between this Policy and Local Laws and Regulations: When local laws and regulations require a higher level of protection for your PII, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

Personal Information We Collect

We collect, and have collected in the past twelve months, information that personally identifies, relates to, describes, or is capable of being associated with a person (“Personal Information”), including:

  1. identifiers (e.g., name, social security number, taxpayer identification number, driver’s license number, date of birth, IP address, security questions & answers, mailing address, email address, phone number);
  2. commercial information (i.e. account numbers, purchase history, payment activity)
  3. internet connection, the equipment you use to access our Website and usage details;
  4. characteristics of protected classifications under California and federal law (i.e. age)
  5. professional or employment-related information (i.e. employer and/or job title)
  6. geolocation
  7. inferences drawn from the above categories
  8. personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.

Some of the Personal Information listed above may be considered sensitive under relevant privacy laws. This includes social security number, driver’s license and other government identification card information, and your customer account login credentials. We refer to this type of Personal Information as “Sensitive Personal Information” in this Policy. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Although we do not make credit inquiries (i.e. pull your credit), we may request information from data sources, such as credit bureau and data aggregators relating to your payment histories, creditworthiness, annual income, or ability to satisfy your obligations.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.

 

How We Collect Personal Information

We collect information in the following ways:

  • When you provide to us over the phone or in documents or applications;
  • We collect information to verify your identity, including your name, date of birth, social security number, social insurance number, driver’s license number, passport number, government-issued identification details, and similar information to verify your identity.
  • When we access your accounts or request your credit card statements or other reports relating to your debt;
  • From business acting on your behalf;
  • From our partners and affiliates;
  • From consumer reporting agencies and other sources.

Third party data sources

We may also receive personal information about you from other third parties where you have provided consent or where permitted by applicable law. Our third-party sources may vary over time and depend upon how you use our services. For example, we receive information from:

  • We may receive information from information services and data licensors that provide demographic and preference information to us.
  • We receive information from government agencies, including from various tax agencies, such as your tax filing confirmation from the IRS.
  • We may receive information business acting on your behalf so we can process applications and information relating to these requests.

Information from cookies or other tracking technologies:

Cookies are small blocks of data created by a web server while a user is browsing a website. This data is stored on your hard drive containing non-personally identifiable information about you. This data functions as your computer’s identification and enables us to improve your experience by maintaining your authenticated session and preferences. We and our third-party vendors use “cookies” and similar tools to track your use of the Website when you use our services. Our systems automatically log information about your computer, tablet or phone.

You may choose to set your web browser to notify you when you receive a cookie or refuse cookies altogether. If you do so, some parts of the Site may not function as intended.

We reserve the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing personally identifiable information.

Internet, device or other activity

We may collect certain non-personally identifiable information about you and your desktop computer, tablet or mobile device when you visit the Site. This non- personally identifiable information includes, without limitation, the type of browser that you use, your IP address, the type of operating system that you use and the domain name of your Internet service provider. We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your experience. We also may use this information in the aggregate to analyze usage of the Site.

Referring exit pages/Advertising

Our company, as well as third party entities such as Google®, use cookies, pixels and other tracking technology (collectively, “tracking technology”) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site.

Our Company, and its third-party partners, use this tracking technology to target applicable Users with advertisements featuring products/services we offer, as well as third-party products/services that may be of interest to applicable Users.

Disclosure Of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by our Company is among the assets transferred.
  • To fulfill the purpose for which you provide or provided by third parties on acting your behalf. For example, if you give us an e-mail address to use the "e-mail a friend" feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • We may also disclose your personal information:
    • 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 or terms of sale and other agreements, including for billing and collection purposes.

If we believe that disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Use Of Information

We collect and use Personal Information for internal purposes, such as to:

  • Provide you with our Website and services;
  • Evaluate your eligibility for government applications, products, and services;

 

  • Communicate with you or third parties, such as sending you electronic notifications concerning requests made on your behalf;
  • Process or complete transactions requested by you or third parties acting on your behalf;
  • Improve the Website and services, including customization and personalization;
  • Notify you of products and services via mail, email, telephone, and/or text messaging;
  • Communicate with you about the Website, our services, and other matters via mail, email, telephone, and/or text messaging; and
  • Compile information and analyses to enhance the customer experience and improve our business; and
  • Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions with our business partners and clients.
  • We may use Sensitive Personal Information for the following purposes:
    • Social Security Number – To verify your identity and/or in connection with credit determination
    • Driver’s license and other government identification number – To verify your identity and/or in connection with credit determinations performed by our clients related to transactions initiated by you.
    • To act on your behalf as legal or professional representative

How Do We Share Your Information

With limited exception discussed below, we may sell or share your personal information to third parties for any purpose relating to transactions that you have requested or may have been requested on your behalf or as otherwise permitted by law. We may also disclose such information in order to effect or carry out any transaction that you have requested of us or as necessary to complete our contractual obligations with you. We may also share your information with service providers or affiliates that perform business operations for us, companies that act on our behalf to market our services, or others only as permitted or required by law, such as to protect against fraud or in response to a subpoena. We may also share or transfer our information in the event we transfer or sell your account or our business assets to another provider.

We may share your Personal Information as necessary and otherwise permitted by law. For example in the last twelve (12) months we may have shared your information with the following:

  • With service providers and vendors. Third parties include: web host provider, other SaaS providers, such as an email hosting service, payment processors, or outside contractors we hire to perform marketing, maintenance, or assist us in securing our Services. We may also hire third parties to operate, maintain, repair, or otherwise improve and preserve our Services or its underlying files or systems.
  • When you request us to share certain information with third parties, with consent or to perform a contract with you. With your permission or upon your direction, we will disclose Personal Data about you to relevant third parties.
  • With professional advisors or government related programs.
  • For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share Personal Data about you with regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share Personal Data about you to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.

How Long We Retain Your Data

We retain your Personal Information for as long as we have a relationship with you or applicable third parties. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations.

Notice to California Connecticut, Colorado, Utah and Virginia Residents

You have additional rights to access and control your Personal Information as described more fully below. We will retain a record of your request for at least two years and in compliance with applicable laws.

Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories and, if requested, specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we sold or shared your Personal Information; and (v) the business or commercial purpose for which we sold or shared your Personal Information.

You have the right to receive your personal data from us in a structured, commonly used and machine-readable form, so that you can transfer it to another party, if you have given us permission to process your data and when the processing was done automatically.

We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your information by mail or electronic delivery.

To request access to your Personal Information. Or a portable version of such information, you may submit a request or call us at 888-417-3853 from the contact information contained below.

Right to Deletion

You may have the right to request that we delete certain types of Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.

To request deletion of your Personal Information, you may submit a request, or call us at toll free number.

Right to Correction

You have the right to request that we correct any Personal Information that we have on file about you that you believe to be erroneous. When you make your request, please be sure to provide us the specific information that you believe is inaccurate and the correct information. You should also provide us with any documentation you believe supports your proposed correction, and we will take that documentation into consideration. We will only correct the information if we determine, based on the totality of the circumstances, that your correction is more likely than not accurate. We may also choose to delete the allegedly inaccurate information instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.

To request correction of your Personal Information, you may submit a request or call us at 888-417-3853 from the contact information contained below.

Right to Opt-Out from the Sale or Sharing of Personal Information

You have the right to direct us not to sell your Personal Information to Third Parties or to share it with Third Parties for targeted or cross-context behavioral advertising purposes. You may exercise your Right to Opt-Out by calling us at 888-417-3853or submitting a request from the contact information contained below.

Right to Limit Use of Sensitive Personal Information

If you are a California resident, you have the right to request that we limit the use of your Sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.

If you are a Connecticut, Colorado, Utah, or Virginia resident, and you make a request to limit the user of your Sensitive Personal Information as defined under your applicable state’s law, we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information subject to any exemptions available under applicable law.

We will process requests to Limit Use of Sensitive Personal Information within 15 business days subject to any applicable exceptions and extension permitted by law.

You may exercise your Right to Limit Use of Sensitive Personal information by calling us at 888-417-3853 or submitting a request from the contact information contained below.

Right to Appeal

If we deny your privacy request, in full or in part, you may appeal our decision. If we deny your appeal, you may also contact your state Attorney General to lodge a complaint and we will provide you with an online mechanism to do so. We will process requests to appeal within the timeframes established under applicable law, but typically within 45 days. Please note that if you have a password-protected online account with us, we will fulfill your request via such account; otherwise, we will give you the option to receive your fulfillment by mail or electronic delivery.

You may exercise your Right to Appeal by calling us at toll free number or submit a request using the contact information contained below.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

How We Protect Your Information

We train our employees to protect all customer information. We maintain appropriate physical, electronic and procedural controls that comply with government standards. We authorize our employees, agents and contractors to get information about you only when they need it to do their work with us. You can help to maintain the security of your online transactions by not sharing your personal information or password with anyone. Remember, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

Updates to this Policy

The Sanguine Strategic Advisors Web Site may contain bulletin board services, chat areas, news groups, forums, communities, personal web pages, calendars, and/or other message or communication facilities designed to enable you to communicate with the public at large or with a group (collectively, “Communication Services”), you agree to use the Communication Services only to post, send and receive messages and material that are proper and related to the particular Communication Service. By way of example, and not as a limitation, you agree that when using a Communication Service, you will not:

Company reserves the right to change this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on our website so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

 

If you have any questions about your privacy or our security practices, please contact us using the following information:

Mailing and Physical Address: 1051 W. Cornelia Avenue, 3rd Floor Chicago, IL 60657

If by email: support@lnjured.org

If by phone: 888-417-3853

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