Privacy Policy

Last Effective Date: January 22, 2025

INTRODUCTION

This Privacy Policy explains how SS KS LLC DBA SUNSHINE SACHS MORGAN & LYLIS and its subsidiaries (“Company”; “we”; “us”; or “our”) collects and processes information through our website at https://ssmandl.com/ (“Website”). Please read this Privacy Policy carefully to understand our policies and practices regarding such information. If you do not agree with our policies and practices, you should not use the Website. By accessing or using this Website, you agree to this Privacy Policy.

For more information about how users with disabilities can access this Privacy Policy please see our Accessibility Statement found on our website https://ssmandl.com/sample-page/.

You can exercise certain rights regarding your information as described in the YOUR RIGHTS, CHOICES AND OPT OUT section below. Users in certain jurisdictions, such as residents of a U.S. state with a comprehensive consumer privacy law, the European Union and the United Kingdom, have specific rights which are set forth below.

INFORMATION COLLECTION

Our Website collects information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Company collects the following categories of personal information and has collected the following categories of personal information from individuals within the last twelve (12) months, for the following categories of purposes and from the following categories of sources, and Company shares personal information with the following categories of third parties:

Category	Examples	Purposes for Which Such Information Was Collected in the Preceding 12 Months or Will be Used	Categories of Sources From Which Personal Information Has Been Collected in the Preceding 12 Months or will be Collected	Categories of Third Parties With Whom the Website Shares or Sells Personal Information
Identifiers	Name Email address IP address	As described below in HOW WE USE YOUR INFORMATION	From you directly	As described below in DISCLOSURE OF YOUR INFORMATION
Internet or other electronic network activity information	Non-precise location information Analytical information (such as referring websites)	As described below in HOW WE USE YOUR INFORMATION	From you directly	As described below in DISCLOSURE OF YOUR INFORMATION
Professional or employment-related information	Contact information Employment history	To evaluate and manage an application for employment with Company	From you directly	As described below in DISCLOSURE OF YOUR INFORMATION

COOKIES

Browsing information is automatically collected through various means such as cookies and pixels through our Website or in our emails. “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, pixels, tags, etc…) through our Website to customize your visit, to analyze how you use our Website and for other purposes to make your visit more convenient, to manage your account or to enable us to enhance our Website. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge, but may be used to store your login credentials.

By way of example, we use Google Analytics on this Website. For information about Google Analytics please see “How Google uses information from sites or apps that use our services”, located at www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, please copy and paste “tools.google.com/dlpage/gaoptout” into your browser and download the Google Analytics opt-out browser add-on.

Based on your web browser, you may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the services. Further information on cookies is available at www.allaboutcookies.org.

HOW WE USE YOUR INFORMATION

We use information that we collect from you:

To deliver our Website to you and analyze its usage;
To provide you with information, such as email newsletters;
To market our services to you;
To evaluate an application for employment;
To carry out our obligations and enforce our rights;
In any other way we may describe when we collect the information from you; and
For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose your information as described in this Privacy Policy or otherwise with your consent:

To contractors, service providers, and other third parties we use to support our business. However, such parties are only authorized by us to use the information for the benefit of us;
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 of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by Company about our Website users is among the assets transferred;
To companies within the same corporate family as Company;
To comply with any court order, law, or legal process, including to respond to any lawful government or regulatory request;
To enforce or apply our policies or investigate fraud; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our users, clients or others.

LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We do not endorse any other websites and providers by providing such links, and our privacy policy applies only to your use of our Website. We are not responsible for the privacy policies of any websites and services we link to on our Website, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.

DATA RETENTION

We will retain your information for as long as your account is active or as needed for us to manage and provide our services and for our business needs. Even if we delete some or all of your personal information, we may continue to retain and use de-identified or aggregate data previously collected.

YOUR RIGHTS, CHOICES AND OPT OUT

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana or another state with a similar comprehensive consumer privacy law (collectively, “Covered States”), you may have specific rights regarding your personal information (sometimes called personal data) under: the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act and other applicable laws (collectively, “State Privacy Laws”). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of a Covered State and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your personal information.

The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.

In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:

Right to know. You may have the right to know whether we process your personal information and to access such personal information. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal information.
Right to data portability. You may have the right to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.
Right to delete. You may have the right to delete personal information that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws. We may also keep a record of your request.
Right to correct. You may have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it.
Right to opt out. We do not use your personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you or (iv) selling/sharing (as defined by the CCPA).
Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:
- Deny you goods or services; or
- Provide you a different level or quality of goods or services.

EXERCISING YOUR U.S. STATE PRIVACY RIGHTS.

To exercise any of the rights described above, you may email us at [email protected].

Only you, or a person or business entity that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. You may also make a request on behalf of your minor child. If you are an authorized agent or an adult acting on behalf of your minor child, please reach out by emailing to [email protected] so we could verify your authority.
In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by confirming that you are the owner of the email address to which the request relates.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the State Privacy Laws allow us up to 90 days to respond. We will still contact you within 45 days from when you contacted us to let you know we need more time to respond.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

EEA & UK Users – If you are a situated in the European Economic Area, United Kingdom or Switzerland and the General Data Protection Regulation (“GDPR”) or a similar law applies, as a data subject, you have the following rights:

Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning them is being processed and provide access to such personal data. It also allows individuals to request details of the processing of their personal data including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
Right to rectify – This right allows individuals to rectify any inaccurate personal data about them.
Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

SS KS LLC DBA SUNSHINE SACHS MORGAN & LYLIS is the Controller of all personal data we collect through the Website.

We shall only process your personal data pursuant to a lawful basis, which will usually be with your consent, when we have a legitimate interest, or to perform a contract to which we are subject. Additionally, if we rely on consent for the processing of your personal data, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

To exercise your rights under the GDPR, please contact us at [email protected]. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

If you are situated in the EU, UK or Switzerland and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority.

SECURITY

At Sunshine Sachs Morgan & Lylis, safeguarding your personal information is a top priority. We implement reasonable security measures and perform annual risk assessments to protect your data from unauthorized access, misuse, alteration, or disclosure. Our security protocols align with industry best practices and are continually updated to address evolving threats and vulnerabilities. While we take extensive precautions to ensure the security of your information, it is important to note that no method of data transmission over the Internet or electronic storage is 100% secure. We are committed to ongoing improvements in our security practices to maintain the integrity and confidentiality of your personal information

CHANGES TO OUR PRIVACY POLICY

We may change this Privacy Policy at our discretion at any time. If we do make any changes, such change will appear on this page of our Website. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of the Website following any changes means that you have accepted, consent to, and agree to be bound by such revised Privacy Policy.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under 13, please contact us at [email protected].

UNITED STATES OF AMERICA / CROSS BORDER DATA TRANSFERS:

Our Website is maintained in the United States of America. By using the Website, you authorize the export of personal information to the USA and its storage and use as specified in this Privacy Policy. We transfer personal information from the EU, UK and Switzerland to the USA and other countries, some of which have not been determined by the European Commission or other regulators to have an adequate level of data protection. Information stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected].