Teeple Hall, LLP | CTA Portal

Last Updated August 15, 2024

Teeple Hall, LLP (“TH,” “us,” “we,” or “our”) is serious about protecting your online privacy. In this Privacy Policy, we explain how the Teeple Hall, LLP CTA Portal (the “CTA Portal”) collects, shares, retains, and transfers information received from you. We also let you know your rights. “You” or “your” in this Privacy Policy shall refer to both you and the Reporting Company you represent as the “CTA Compliance Representative” of such Reporting Company.

We use data received from you to assist you with your reporting requirements under the CTA. We may also use such data to improve our CTA Portal and its services. By using the CTA Portal, you agree to the collection and use of such data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Before disclosing information to us, please familiarize yourself with our privacy practices so you can understand how such information may be used by the CTA Portal.

1. Information We Collect and Use

We collect several different types of information for various purposes to provide and improve the CTA Portal and its services to you.

Types of Data Collected:

A.1. Personal Data

While using the CTA Portal, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

First name and last name
Email address
Date of birth
Phone number
Business name
Website URL
Identification
Address, State, Province, ZIP/Postal Code, City
Any personal data that you choose to post on our website
Data about how you use our website
Technical data such as your Internet Protocol (IP) address, your login data, details about your browser, time zone settings, and other technology on the devise you use to access our website
Your marketing and communication preferences
Any information that you directly provide to us whether through our contact form, over the phone, by email, or otherwise
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing, or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at [email protected].

A.2. Non-Personal Data

Information of a type or in a form that does not permit direct identification of, or association with, any specific individual is ‘non-personal information.’ Combinations of personal and non-personal information are considered personal information if the combined information can be used to identify or contact any specific individual(s). Aggregated data is considered non-personal information for the purposes of this Privacy Policy as long as it cannot be used to identify or contact any specific individual. IP addresses and certain other identifiers may be considered personal information under various local laws; we endeavor to comply with the laws and regulations that are applicable to us.

B. Usage Data

We may also collect information on how the CTA Portal is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of the CTA Portal that you visit, the time and date of your visit, the time spent on such pages, unique device identifiers, and other diagnostic data.

C. Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on the CTA Portal and to hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze the CTA Portal.

You may choose to restrict cookies to only essential cookies or no cookies on our websites. Or you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the CTA Portal.

Examples of Cookies We Use:

Essential Cookies:

Session Cookies. We use Session Cookies to operate the CTA Portal.
Security Cookies. We use Security Cookies for security purposes.

Non-Essential Cookies:

Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

2. How we use your Data

TH uses the collected data for various purposes:

To provide and maintain the CTA Portal
To notify you about changes to the CTA Portal
To allow you to participate in interactive features of the CTA Portal when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve the CTA Portal
To monitor the usage of the CTA Portal
To detect, prevent, and address technical issues
To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), TH’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

TH may process your Personal Data because:

We need to enter into a contract with you
You have given us permission to do so
The processing is in our legitimate interests and is not overridden by your rights
For payment processing purposes
To comply with the law

3. Retention of Data

TH will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

TH will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the CTA Portal, or we are legally obligated to retain this data for longer time periods.

4. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

TH will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

5. Disclosure of Data

A. Business Transaction

If TH is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

B. Disclosure for Law Enforcement

Under certain circumstances, TH may be required to disclose your Personal Data if specifically required to do so by law or in response to valid requests by public authorities (e.g., a state, federal, or international court or government agency).

Legal Requirements

TH may disclose your Personal Data in the good faith belief that such action is necessary:

To comply with a legal obligation
To prevent or investigate possible wrongdoing in connection with the CTA Portal
To protect the personal safety of users of the CTA Portal or the public
To protect against legal liability
For the security of such data

C. “Do Not Track” Signals

“Do Not Track” is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable “Do Not Track” by visiting the Preferences or Settings page of your web browser.

6. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TH takes reasonable steps to allow you to correct, amend, delete, and/or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you, and if you want it to be removed from our systems, please contact us at [email protected].

Under the GDPR you have the following data protection rights:

The right to access, update, or delete the information we have about you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have about you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You have the right to withdraw your consent at any time where TH relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

7. Service Providers, Processors, and Subprocessors

We may employ third-party companies and individuals to facilitate the CTA Portal (“Service Providers,” “Processors,” or “Subprocessors”), to provide the services of the CTA Portal on our behalf, to perform CTA Portal-related services, or to assist us in analyzing how the CTA Portal is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use your Personal Data for any other purpose.

8. Log Files

As part of standard protocols, TH servers automatically gather certain information and store it in log files. This information may include date/time stamp of access, IP addresses, device type, operating system, browser and version, language, log-in details, Internet Service Provider (ISP), referring page, exit page, and other data.

These log files are useful for a number of purposes including helping TH maintain security, measure relative usage, understand and analyze trends regarding users, server access, load, or server problems, more effectively and efficiently administer the CTA Portal and related software, products, services, and/or communications, and gather non-personal demographic information about our users. Consistent with the provisions of this Privacy Policy, TH may use the data in its Log Files in a variety of ways useful to its business or to provide better experiences for its users and clients.

9. Social Media

TH may collect certain information from you if you interact with us via social media such as Facebook, X (formerly Twitter), LinkedIn, Pinterest, Snapchat, Instagram, and other such services. For example, you may be given the option to register for events, take advantage of special offers, receive mailings and/or newsletters, or the like, via your social media account. The information we receive or collect from such social media, and our ability to collect it, may depend on the social media site, its policies, and its requirements and/or its technology. We may collect the information you provide from these social media interactions and may use it for various purposes to improve our services or your experience, or to contact you regarding the reason you connected with us or with additional offers in the future. You have the opportunity to opt out at any time, provided we do not require a means of contacting you to fulfill your request.

10. Analytics

We may use third-party Service Providers to monitor and analyze the use of the CTA Portal.

A. Google Analytics

Google Analytics is a web analytics service offered by Alphabet Inc. that tracks and reports website traffic. Google, a subsidiary of Alphabet Inc., uses the data collected to track and monitor the use of the CTA Portal. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the CTA Portal available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

B. Behavioral Remarketing

TH may use remarketing services to advertise on third party websites to you after you’ve visited the CTA Portal. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to the CTA Portal.

C. Google AdWords

Google AdWords remarketing service is provided by Alphabet Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-Out Browser Add-On provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

D. X Corp. (formerly Twitter)

X Corp. remarketing service is provided by X Corp. You can opt-out from X Corp.’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of X Corp. by visiting its Privacy Policy page: https://twitter.com/privacy

E. Facebook

Facebook remarketing service is provided by Meta Platforms, Inc. (“Meta”). You can learn more about interest-based advertising from Meta by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Meta’s interest-based ads follow these instructions from Meta: https://www.facebook.com/help/568137493302217. Meta adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Meta and other participating companies through the Digital Advertising Alliance in the USA: https://www.aboutads.info/choices/ , the Digital Advertising Alliance of Canada in Canada” https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: https://www.youronlinechoices.eu/ , or opt-out using your mobile device settings. For more information on the privacy practices of Meta, please visit Meta’s Data Policy: https://www.facebook.com/privacy/explanation.

11. Payments

We may provide paid products and/or services within the CTA Portal. In that case, we use third-party services for payment processing (e.g., payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The CTA Portal may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Children’s Privacy

Protecting children's privacy is important to TH . It is our policy to comply with the Children's Online Privacy Protection Act of 1998 and all other applicable laws. Therefore, we restrict our website use to persons eighteen (18) years or older. We do not knowingly collect personal information from children under the age of eighteen (18). If we learn that TH has inadvertently collected or received the personal information of a child under the age of eighteen (18), we will take steps to delete such information.

[PLEASE NOTE: You must be eighteen (18) years of age or older to use the CTA Portal, and to purchase the software, products, and/or services offered via the CTA Portal without a parent or legal guardian present.]

DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEBSITE, NO INFORMATION OBTAINED VIA THIS WEBSITE FALLS WITHIN THE CHILDREN'S ONLINE PRIVACY PROTECTION ACT (COPPA), AND IT IS NOT MONITORED AS DOING SO.

Notwithstanding the foregoing, if we discover or form a reasonable belief that we have received any information from a child under eighteen (18) in violation of this policy, we will delete that information. If you believe the CTA Portal has any information from a child under eighteen (18) years of age, please contact us at the following address: [email protected]

13. Notice of Compliance to California Residents

Your California Privacy Rights Under the California Consumer Privacy Act, the California Privacy Rights Act, and the California Business and Professions Code:

This privacy policy identifies the categories of personally identifiable information that we collect through the CTA Portal about individual consumers who use or visit the CTA Portal and the categories of third-party persons or entities with whom we may share such personally identifiable information.

See the section below entitled "Changes To This Privacy Policy" for a description of the process by which we notify users and/or clients who use or visit the CTA Portal of material changes to this Privacy Policy.

The effective date of this Privacy Policy is listed at the top of this Privacy Policy under the heading, "Updated."

For the purposes of this policy and California compliance under the CCPA and CPRA, you have the following rights:

To know what information has been collected
To know if personal information is sold
To opt-out of sale of personal information
To opt-out of sharing of personal information
Access
Rectification (correction)
Deletion
Data portability
Limit use and disclosure of sensitive personal information
Not be discriminated against for exercising their rights

TH will never sell or share your data with anyone unless it is legally required to do so to provide the services of the CTA Portal, such as with FinCEN.

All information entered into the CTA Portal for the purpose of seeking legal advice is protected by attorney-client privilege.

To exercise any of these rights, please contact us at: [email protected]. Please include the phrase "California Privacy Request" in the subject line. In such email, please include the domain name of the website you are inquiring about along with your name, address, and e-mail address. We will respond to you within thirty (30) days of receiving such a request.

14. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting such new Privacy Policy on this page.

Upon any such update to this Privacy Policy, we will let you know via email and/or a prominent notice on the CTA Portal, as well as update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you would like to: access, correct, amend, or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Support Team at [email protected] or by mail at:

Teeple Hall, LLP

Re: CTA Portal

9255 Towne Centre Drive, Suite 500

San Diego, CA 92121