Effective Date of Current Policy: November 30, 2024
This Privacy Policy governs the way in which ‘68 Partners LLC may collect and use personal information
and non-personal information we learn about you from your visit to this website (the “Website”).
Additionally, this policy discusses our treatment of information you provide to us in connection with our
services. By using the Website and submitting information to it, you hereby consent to allow ‘68
Partners LLC to process information in accordance with this Policy. If you do not wish ‘68 Partners LLC to
use your information in accordance with this policy, please do not submit such information to ‘68
Partners LLC.
Please also refer to the Website Terms of Use, which are expressly incorporated as if fully recited herein,
if you have not already done so.
COLLECTION OF INFORMATION
Personal Information
The Website collects no personal information about you, typically defined as personally identifying
information (“PII”), such as your name, home address, business address, telephone number, e-mail
address and profession, unless you voluntary submit it. You may be requested to provide personal
information when signing up for a newsletter, the Client Portal, an update or other communication from
the Website. It is possible to submit information by clicking on various links, such as “Contact” or “Book
Consult”.
Non-Personal Information
The Website may collect non-personal information about your activity at the Website. The Website may
automatically recognize and store information about the type of browser you are using; your Internet
Protocol (“IP”) address; the time, date, and length of your visit; and the referring site. This information,
if collected, is collected via computer code sent to your computer (commonly referred to as “cookies”).
The cookies may not expire, unless you manually delete them or set your browser to reject them. If you
do not accept the cookies, however, you may have difficulty navigating the Website. Furthermore, the
Website may utilize Web beacons, embedded Web links, and other commonly used information-
gathering tools.
Information Provided for Services
Additionally, we collect nonpublic personal information about you that is provided by you or obtained
by us with your authorization to provide you with ’68 Partners Core Solutions.
We receive information from you to properly prepare your Compliance Program or provide other Core
Solutions from ’68 Partners LLC. This information is collected from you in written form, by phone, online,
by mail and in personal interviews and consultations conducted by us, as well as by information we
collect from others with your authorization.
Further, we collect and maintain information about your transactions with ‘68 Partners LLC, which
includes information necessary for billing and payments. Transaction information might also include
your credit card number, payment history with us, billing records and any collection effort engaged in by
us for payment of services rendered to you.
Territoriality
Our computer systems are currently based in the United States and the content of our Website is
directed to U.S. residents. Your personal data will be processed by us in the United States, where data
protection and privacy regulations may or may not be to the same level of protection as in other parts of
the world, such as in Canada and the European Union. BY VISITING THE ‘68 PARTNERS LLC WEBSITE, YOU
UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE
UNITED STATES OF ANY PERSONAL AND NON-PERSONAL INFORMATION COLLECTED OR OBTAINED BY
‘68 PARTNERS LLC THROUGH VOLUNTARY SUBMISSIONS OR THROUGH THE CLIENT PORTAL, AND THAT
UNITED STATES LAW GOVERNS ANY SUCH COLLECTION, PROCESSING AND USE.
USE
Non-Personal Information
‘68 Partners LLC uses non-personal information to manage the Website. ‘68 Partners LLC may analyze
the data about visits to the Website to make it more accessible and interesting for visitors. Further, ‘68
Partners LLC may share this data with third parties, usually to provide services for ‘68 Partners LLC
associated with the maintenance of the Website.
Additionally, ‘68 Partners LLC may disclose any such information to the extent that it is required by law
or to such an extent as it reasonable believes is necessary to protect its legal interests. The information
collected from you may be transferred to a third party in the event of a sale, acquisition, merger or
bankruptcy involving ‘68 Partners LLC. ‘68 Partners LLC reserves the right to utilize such information in
other ways that it deems appropriate.
Personal Information
If you submit personal information to the Website, the information will be used for the purpose you
requested. That information may be stored and maintained for as long as is reasonably necessary to
effectuate the service your request or for which the information was provided, and for a reasonable
time thereafter. If you select to receive updates or other information, ‘68 Partners LLC may use your
Personal Information to provide you with the information you select to receive. In addition, ‘68 Partners
LLC may share this information with third parties to fulfill your request.
Additionally, ‘68 Partners LLC may disclose any such information to the extent that it is required by law
or to such an extent as it reasonable believes is necessary to protect its legal interests. The information
collected from you may be transferred to a third party in the event of a sale, acquisition, merger or
bankruptcy involving ‘68 Partners LLC.
To the extent you purchase goods or services on the Website, from ‘68 Partners LLC or through which
‘68 Partners LLC processes credit card information, you agree that ‘68 Partners LLC may retain such
information for archival purposes for a reasonable time. You agree that ‘68 Partners LLC shall not be
liable for any non-intentional data breaches and agree to hold ‘68 Partners LLC harmless therefrom.
Information Provided for Services
We are generally prohibited from disclosing confidential client information about you to affiliates and
nonaffiliated third parties without your specific consent.
We do not disclose any Information Provided for Services about our clients or former clients to our
affiliates or to nonaffiliated third parties except as permitted by law. Information Provided for Services
about you and our former clients may be disclosed to both our affiliates and nonaffiliated third parties
as permitted by law, our Codes of Professional Conduct and Ethics Rulings, as follows:
Complying with a validly issued and enforceable subpoena or summons;
In the course of a review of our firm’s practices as required by the American Bar Association or
other regulatory review. Any disclosure in such instances would be the subject of a
confidentiality agreement prohibiting the use of such information for any purpose other than
the required review of our firm’s practices;
Initiating a complaint or responding to an inquiry made by a Professional Ethics Committee, or
any duly constituted investigative or disciplinary body having jurisdiction;
A review of a professional practice in conjunction with a prospective purchase, sales, or merger
of all or part of our practice, provided that we take appropriate precautions (for example,
through a written confidentiality agreement) so the prospective purchaser does not disclose
information obtained in the course of the review;
Participating in actual or threatened legal proceedings or alternative dispute resolution
proceedings either initiated by or against us, provided we disclose only the information
necessary to file, pursue, or defend against the lawsuit, and take reasonable precautions to
ensure that the information disclosed does not become a matter of public record; or,
Providing information to affiliates of the firm and nonaffiliated third parties who perform
services or functions for us pursuant to a contractual agreement, which prohibits the third party
or affiliate from disclosing or using the information other than for the purposes for which the
information was disclosed: for example, using an outside service bureau to process client’s tax
returns, using a records-retention agency to store clients’ records, or using an information
technology provider to facilitate online access to clients’ records.
CONFIDENTIALITY AND SECURITY
‘68 Partners LLC will take reasonable steps to restrict access to the information discussed in this policy
and the areas of the Website designated as being suitable for a secure file exchange remain secure. We
cannot, however, guarantee the absolute security of such transmission tools or any information retained
by ‘68 Partners LLC. You understand that your use of the Client Portal is subject to the Client Portal
Terms, and if you use the Client Portal, you expressly agree to such terms.
UPDATE AND OPT-OUT
If you would like to update any information you have sent to ‘68 Partners LLC, or if you do not want to
receive information from ‘68 Partners LLC, please contact us at info@68partners.com
‘68 Partners LLC will make reasonable efforts to honor any request you make to forgo contacts with you
in the future or delete your information. Please note that if you make an opt-out request, ‘68 PartnersLLC will retain your contact information to make efforts to ensure that you are not contacted in the
future.
To the extent required by the CAN-SPAM Act, or other similar domestic and international regulation,
commercial e-mail messages will also provide you with an opportunity to opt-out of receiving this
information. Please note that changes to your preferences may not be effective immediately.
REVISIONS TO THE PRIVACY POLICY
The internet and the benefits it offers are evolving rapidly, as are the ways in which people use the
internet and the laws surrounding such use. ‘68 Partners LLC therefore reserves the right to update and
revise this Privacy Policy at any time. You can determine if this Privacy Policy has been revised since your
last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of
our Website constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us,
and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.
