Apercen Partners

Effective Date: February 11, 2022

Last Updated: January 01, 2024

Your privacy is very important to us. This Privacy Policy sets forth the policies of Apercen Partners LLC (“Apercen” or “us” or “we” or “our”) with respect to the personal information, including nonpublic personal information (collectively referred to as “Personal Information”) of our clients, prospective clients, and former clients and others whose Personal Information we collect and process (collectively for purposes of this policy only, “Clients”, “you”, or "your").

For those who reside in California, please see the section “California Privacy Rights” below for additional information.

Apercen believes that protecting the privacy of our Clients’ Personal Information is of the utmost importance, and we are committed to maintaining the privacy of our Clients’ Personal Information in our possession.

1. HOW WE COLLECT YOUR PERSONAL INFORMATION

In order to provide the agreed upon professional services, we receive and collect Personal Information about you when you provide it directly to us, when we obtain it from third parties with your authorization, when we obtain it from commercially available sources, or when we generate information about you in the course of our relationship with you (e.g., when you interact with our services). We may collect the following categories of Personal Information about you:

Identifiers and contact information, such as your name, postal address, phone number, email address, IP address, social security number, tax identification or employer identification number, tax account login credentials, driver’s license number, and other similar identifiers;
Certain protected characteristics, such as your age, marital status, gender, medical information, and disability information, generally to the extent we need this information to fulfill our legal obligations or to provide you with a requested service;
Commercial information, such as your records of personal property, and records of the products and services you purchased from us;
Professional or employment-related information, such as your employment history, professional degrees, and certifications;
Financial information, such as your bank and financial account information, your credit or other payment account information, your assets, and income information;
Electronic, visual, or similar information, such as from security cameras in our offices;
Internet or other electronic network information, such as your IP address, the approximate geolocation of the IP address, and interactions with our sites and client portals;
Communications information, such as the contents of your mail, email, and text messages, if directed by you; and
Other personal records that identify, relate to, describe, or are reasonably capable of being associated with you, such as your signature, educational background, other tax-related information, and insurance information.

In the course of providing services to you, we may receive the following categories of Personal Information about you, which may be considered sensitive in some jurisdictions (“Sensitive Personal Information”):

Authentication information, such as account log-in information, financial accounts, debit cards, or credit card numbers in combination with any required security or access codes, passwords, or credentials allowing access to an account;
Biographical information, including racial or ethnic origin, religious or philosophical beliefs, or union membership;
Information about criminal convictions and offenses, such as information about criminal history, or results of background check (where permitted under local law);
Financial information, such as tax status;
Information about your health, such as any medical condition and/or disability, and health insurance information;
Communications information, such as the contents of your mail, email, and text messages, if directed by you; and
Other information, such as your social security number, driver’s license, passport number, or similar government ID.

2. HOW WE USE YOUR PERSONAL INFORMATION

We collect the categories of your Personal Information described above primarily to perform services requested by you (“Services”). We may also collect each category of Personal Information for the following purposes:

To process payments from you;
To verify your identity;
To improve our Services to you, including to run analytics, assess the quality of our services, provide interactive or personalized elements on the Services, and other related internal business purposes;
To communicate with you to personalize your relationship with us, improve our understanding of your needs, and to respond to your inquiries;
To protect the rights, safety, and property of Apercen, you, or any third party; and
To comply with legal obligations as required by applicable law, court order, or governmental regulations.

We use Sensitive Personal Information for the following purposes:

To verify your identity;
To protect the rights, safety, and property of Apercen, you, or any third party;
To provide our Services (e.g., to file taxes or communicate with regulatory authorities on your behalf); and
To comply with legal obligations as required by applicable law, court order, or governmental regulations.

Apercen does not use or disclose Sensitive Personal Information for any other purpose, nor do we infer characteristics about you based on your Sensitive Personal Information.

We may also anonymize your Personal Information in such a way that you may not reasonably be re-identified by us or others and may use this anonymized information to provide services to you. We will not attempt to re-identify anonymized data.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your Personal Information to the following affiliates and non-affiliated third parties:

To our affiliates for everyday business purposes in connection with the provision of Services to you;
To professional advisors and service providers (such as attorneys, accountants, tax preparers, service providers, agents, and administrators) for our everyday business purposes, including as necessary for us to provide agreed-upon services and products to you consistent with applicable law. Any non-affiliated third parties are not allowed to use your Personal Information for their own purposes and are contractually or legally obligated to maintain strict confidentiality. We limit their use of your Personal Information to the performance of the specific services we have requested;
To you, and persons you have designated as, or we understand to be, your authorized agents or representatives;
In relation to a corporate transaction, such as if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control, including negotiation and diligence of such transactions;
To regulators, courts, and law enforcement if compelled to do so, to satisfy our regulatory, legal, and other obligations to such entities in accordance with applicable law, court order, or governmental regulations, or if you direct us to do so (e.g., to file tax documentation with a tax authority); and
With your consent, where permitted by applicable local law.

We do not sell your Personal Information to anyone. Nor do we disclose your Personal Information, including that of any individuals under 16 years of age, to third parties for their own marketing purposes or share it for cross-context behavioral advertising.

4. DISCLOSURES

California law requires that a business provide in its privacy notice policy a list of the categories of Personal Information it has in the preceding 12 months (1) disclosed for a business purpose, and (2) disclosed in exchange for valuable consideration or for purposes of targeted advertising (considered a “sale” or “sharing” under California law, even if no money is exchanged), as well as the categories of third parties to whom each category of Personal Information was disclosed for a business purpose or sold or shared. Apercen does not sell or share Personal Information under California law.

Generally, in the past 12 months, Apercen has:

Disclosed for our business purposes	Categories of third parties to whom this information was disclosed
Identifiers	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Certain protected characteristics	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Commercial information	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Professional or employment-related information	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Financial information	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Electronic, visual, or similar information	Service providers such as security surveillance providers
Internet or other electronic network information	Service providers such as electronic signature platforms, file sharing platforms, and video conferencing platforms
Other personal records	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives
Sensitive Personal Information	Affiliates, non-affiliated third parties and service providers such as tax return software providers, signature signing platforms, and file sharing platforms, regulators (as directed by you or your authorized agents), you and your authorized agents or representatives

5. RETENTION OF PERSONAL INFORMATION

We retain the Personal Information we collect about you in each of the categories above as needed to meet our professional and legal requirements for the purposes described above in "How We Use Your Personal Information". We also retain your information to meet our professional obligations, defend our legal rights, and for historical recordkeeping purposes as directed by you.

6. PROTECTING THE CONFIDENTIALITY AND SECURITY OF CLIENTS' PERSONAL INFORMATION

We retain records relating to professional services that we provide so that we are better able to assist you with your needs and, in some cases, to comply with legal or professional guidelines. In order to guard your Personal Information, we maintain physical, electronic, and procedural safeguards consistent with our professional standards and applicable law.

7. CALIFORNIA PRIVACY RIGHTS

You may have certain rights regarding your Personal Information, as applicable under California law.

Request to Know: You may have the right to confirm whether we collect or maintain Personal Information about you and request to know: (i) the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. You may exercise your right to request to know twice a year, free of charge.

Please note, in response to a request to know, we may be prohibited from disclosing certain Personal Information such as your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password or security questions and answers.

Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate Personal Information that we maintain about you.

Request to Delete: You may request that we delete the Personal Information we have collected about you. However, we may deny your request under certain circumstances, such as if we need to retain the Personal Information in order to comply with our legal obligations, to complete a transaction for which your Personal Information was collected, or to use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided the information. If we deny your request to delete, we will let you know the reason.

Right to Opt-Out of the Sale or Sharing of Personal Information, including Targeted Advertising: Apercen does not sell or share personal information and has not sold or shared personal information in the 12 months preceding the effective date of this Notice. This includes that we do not use your information for targeted advertising purposes.

Right to Opt-Out of Profiling: You may be entitled to opt out of certain processing that has legal or similarly significant effects on you. Apercen does not use your Personal Information for such profiling purposes.

Right to Non-Discrimination for the Exercise of Your Privacy Rights: You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by applicable privacy law.

These rights may be limited or denied in some circumstances. For example, we may retain your Personal Information where required or permitted by applicable law.

Exercising your Rights: To exercise the rights described above, please submit, or have your authorized agent, as described below, submit, a request by either calling us at (888) 521-2011 or clicking here. You may also contact us using these methods to appeal any decision we make relating to your request to exercise your rights. We will not discriminate against you for exercising any of your rights under applicable law.

We cannot fulfill your request to access, correct, or delete Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will use our records to verify your identity by requiring you to confirm three pieces of Personal Information that we have on file, for example, from a previously filed tax return (e.g., driver’s license number, bank account number, passport number, financial details from a previously filed tax return).

Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent permission to do so. If an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your Personal Information.

8. CONTACT US

If you have any questions about this Privacy Policy or about our privacy practices, please contact us at (888) 521-2011 or privacy@apercen.com because your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.

9. UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be updated at any time. If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page. If we make any material changes to the ways in which we process or protect your Personal Information we will provide additional notification of the changes in accordance with applicable law.