WHAT INFORMATION WE COLLECT AND HOW WE USE THAT INFORMATION
You may use the Site without disclosing to us any personally identifiable information. We do not collect any personally identifiable information from you (e.g., name, address, telephone number, email address) when you use the Site. If you contact us, we may keep a record of your contact information and correspondence, and we reserve the right to use your contact information, and any other information that you provide to us in your message, to respond thereto. If you wish to change any information submitted to us, please do so by contacting us at the address provided above.
In the event of a sale or transfer of assets or of any portion of our business, we reserve the right to transfer any and all information that we collect from users, or that we otherwise collect in connection with the Site, to unaffiliated third parties or third parties.
Monitoring, Enforcement and Legal Requests
HS Financial Group, LLC has no obligation to monitor the Site or the use of the Site or to retain the content of any user session. However, HS Financial Group, LLC reserves the right, at all times, to monitor, review, retain and/or disclose any information, as necessary, to satisfy any applicable law, regulation, legal process or governmental request or to cooperate with law enforcement and other authorities in investigating a claim of illegal activity. We may use IP addresses to identify a user when we feel it is necessary to protect the Site, our service, clients, potential clients or others.
Effective: January 1, 2020
This California Consumer Privacy Act Disclosure (“CCPA Disclosure”) explains how HS Financial Group, LLC and its U.S. affiliates (collectively, “Law Offices of Timothy M Sullivan,” “we,” “us,” or “our”) collect, use, and disclose personal information subject to the California Consumer Privacy Act (“CCPA”). It also describes the privacy rights of California residents under the CCPA.
This CCPA Disclosure applies solely to California residents and supplements any other privacy policies or notices applicable to the HS Financial Group, LLC services that you visit or use.
What Personal Information Is Covered by the CCPA?
Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
The CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and certain other state or federal privacy laws.
This CCPA Disclosure also does not apply to information that we collect in connection with providing products or services to other businesses (such as our commercial or small business customers) or when receiving products or services from our suppliers. Similarly, it does not apply to information we collect in the context of a person’s role as a job applicant, employee, associate, contractor, or other member of our workforce.
Categories of Personal Information we collect
Most of the information we have collected has been collected in the context of providing collection services, and is therefore not subject to the CCPA.
In the past 12 months, we have collected the following categories of personal information, as defined in the CCPA, relating to California residents. The categories of personal information that we collect, use, and disclose about a California resident will depend on our specific relationship or interaction with that individual, and the examples provided in each category below are for illustrative purposes only.
|CCPA CATEGORIES||ILLUSTRATIVE EXAMPLES|
|Identifiers||Name, address, email address, online identifiers,
internet protocol address, Social Security numbers,
or other similar identifiers
as defined in the California Customer Records Act,
Cal. Civ. Code § 1798.80
|Contact and financial information|
|Commercial information||Information about past transactions or purchases|
|Internet or similar network activity information||Browsing history, search history,
information on a consumer’s interaction
with our website, application, or advertisement
|Geolocation data||Device location (IP Address)|
|Audio, electronic, visual, or similar information||Call and video recordings|
Categories of Sources of Personal Information
In the past 12 months, we have collected personal information relating to California residents from the following sources:
- Directly from you
- Business partners
- Service providers
- Consumer data resellers
- Government entities from which public records are obtained
Purposes for which We Use Personal Information
Most of the information we use is in the context of providing collection services, and is therefore not subject to the CCPA. We may use personal information relating to California residents for one or more of the following business purposes:
- Providing and maintaining our products and services
- Verifying your identity
- Detecting and preventing fraud
- Protecting against security risks
- Maintaining our facilities, systems, and infrastructure
- Carrying out our legal and business purposes, such as complying with federal, state, or local laws, responding to civil, criminal, or regulatory lawsuits or investigations, exercising our rights or defending against legal claims, resolving complaints and disputes, performing compliance activities, performing institutional risk control, and otherwise operating, managing, and maintaining our business
- As otherwise disclosed to you at or before the point of collecting your personal information
We may also use personal information relating to California residents for one or more of the specific “business purposes” listed in the CCPA:
- Certain auditing compliance with applicable standards
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use
- Performing services on behalf of HS Financial Group, LLC or its service providers, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, and processing payments.
- Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by HS Financial Group, LLC, and to improve, upgrade, or enhance the service that is owned or controlled by HS Financial Group, LLC.
Disclosure of Personal Information to Third Parties
In the past 12 months, we have disclosed each of the above-listed categories of personal information for our business purposes to one or more of the following categories of third parties:
- Business partners
- Service providers
- Government entities and others with whom we share information for legal or necessary purposes
In the past 12 months, we have not shared personal information relating to California residents in a manner that we consider a sale within the meaning of the CCPA.
Changes to This California Consumer Privacy Act Disclosure
We may change or update this CCPA Disclosure in the future. When we do, we will post the revised CCPA Disclosure on our website. This CCPA Disclosure was last updated and became effective on the date posted at the top of this page.
CCPA- Your rights:
- The right to request disclosure of a business’ data collection and sales practices in connection with the requesting consumer, including the categories of personal information that have collected, the source of the information, the use of the information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold;
- The right to request a copy of the specific personal information collected about a consumer during the 12 months before the request;
- The right to have such information deleted (with exceptions);
- The right to request that personal information not be sold to third parties, if applicable; and
- The right not to be discriminated against because a consumer exercised any of the new rights.
Consumers may only make a personal information request twice in a 12-month period, and HS Financial Group, LLC will need to collect information from the requesting party so that we can verify the consumer’s identity, and HS Financial Group, LLC will respond within 45 days of receiving a personal information request.
Submitting a personal information or erasure request:
There are two ways to make a personal erasure request.
- Call our toll free number- 1-888-774-0272. Ask for extension 122. Leave a message with your full name, address, phone number, account number, etc.
- Fill out the form linked HERE
Someone from the office will respond within 45 days.
Opt Out options
HS Financial Group, LLC does not sell any personal information to any third party for monetary or other valuable consideration.