Privacy Policy

Last modified: November 6, 2024

Introduction

Fauver, Large, Archbald & Spray, LLP (“FLAS,” the “Company,” or “We” or “Our”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you, or that you may provide, when visiting flasllp.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy also describes your rights with respect to the information that we collect from you, or that you provide to us, including your right to require the deletion of such information.

Please note that FLAS works with certain advertising partners, such as Google Analytics, with respect to its marketing efforts. These advertising partners may engage in the activities described by this Privacy Policy on behalf of FLAS. To learn more about, or to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates, subsidiaries, and service providers); or
Any third party (including our affiliates, subsidiaries, and service providers) including through any application or content (such as advertising) that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not (a) use the Website; (b) provide FLAS with any information using the Website or its features, including, but not limited to, information about yourself, such as your name, address, telephone number, email address, or screen name; or (c) contact us using the Website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us by calling (805) 966-7000.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Collection of Your Information

Types of Information Collected and Manner of Collection
We may collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (collectively, information of this nature is referred to herein as “personal information”); and
- About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties.
Information You Provide to Us
The information we collect on or through our Website about you may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting services or contacting us. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your search queries on the Website.
You can choose not to provide us with certain types of information, but doing so may affect your ability to use some features of our website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We may collect personal information automatically through our advertising partners. This information may be tied to personal information about you that we collect from other sources, or that you provide to us.
Do-Not-Track Signals and Similar Mechanisms.
Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. FLAS currently does not comply with or in any respond to such signals.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide through it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

Disclosure of Information

We may disclose aggregated information about our users, and information that does not identify any individual (“deidentified information”), without restriction.

We will never reidentify the deidentified information that we collect and/or retain about you.

Selling and Sharing Your Information
We may disclose personal information that we collect about you or that you provide to us to the following third-parties:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- 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 FLAS’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FLAS about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FLAS, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Non-Personal Information. We also may share data in a manner that does not identify you (for example, information that has been aggregated with other records) for general business purposes. For example, we may disclose the number of visitors to our websites.

Choices About How We Use And Disclose Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ services, you can opt-out by sending us an email stating your request to info@FLASllp.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This choice to opt out does not apply to information provided to the Company as a result of a service experience or other transactions.

Choices About How Third Parties Use and Disclose Information

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

Please note that, despite your opt-out selections, where permitted by applicable laws, we may send you communications regarding transactions or services you have specifically requested or to inform you of important changes to our services, products or policies.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Assessing and Correcting Your Personal Information

You may email us at info@FLASllp.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Changes to Our Privacy Notice

FLAS reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which FLAS collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Phone: (805) 966-7000
Website: flasllp.com
Email: info@flasllp.com

Postal Address:

Fauver, Large, Archbald & Spray, LLP
820 State Street, 4^th Floor
Santa Barbara, CA 93101

Fauver, Large, Archbald & Spray, LLP

California Privacy Rights Notice

Last modified: November 8, 2024

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Many of these privacy rights are described here: https://oag.ca.gov/privacy/ccpa and within this California Privacy Rights Notice (this “Notice”). This Notice is applicable only to visitors, users, and others who reside in the State of California (“consumers” or “you”). This Notice does not replace the general Fauver, Large, Archbald & Spray, LLP Privacy Policy applicable to all users set forth above, and instead acts as a supplemental policy. Fauver, Large, Archbald & Spray, LLP (“FLAS”, the “Company” and “us”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2022 (“CPRA”), and any terms defined in the CCPA or CPRA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). You have a right to know what personal information we collect from you, and how this personal information is utilized by us. In particular, FLAS has historically collected the following categories of personal information from its consumers through its website:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO
L. Sensitive Personal Information.	Private personal information which includes, but is not limited to personal identification numbers, (such as social security, driver’s license, passport, or state ID card numbers), financial account and payment card information, precise geolocation information, biometric information, information disclosing a person’s race, ethnicity, religion, union membership, private personal communications, and sex life or sexual orientation.	NO

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

FLAS obtains the categories of personal information listed above from the following sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties.

Retention Period

Generally, all personal information that we collect is retained by us within our secured data management system indefinitely, subject to our receipt of a request for deletion of such personal information made in compliance with CCPA and CPRA, as outlined below.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to process your payment. We may also save your information to facilitate future purchases.
To provide, support, personalize, and develop our Website, products, and services.
To process your requests, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FLAS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FLAS about our Website users is among the assets transferred.

FLAS will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice

Selling or Sharing of Personal Information

FLAS may disclose your personal information to certain third parties for a business purpose (see Your Rights and Choices). FLAS does not sell your personal information or disclose your personal information in connection with cross-context behavioral advertising. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To our subsidiaries and affiliates.

Your Rights and Choices

The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that FLAS disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclose your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that FLAS delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Request Correction of Personal Information
You have the right to request that we correct any inaccurate personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request for correction (see Exercising Access, Data Portability, and Deletion Rights), we will correct (and direct our service providers to correct) your personal information, unless an exception applies.
Right to Opt-Out of the Sharing of Personal Information
You have the right to opt-out of the sale or sharing of your personal information with third parties. You may opt-out by sending us an email stating your request to info@FLASLLP.com.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, correction, restriction and deletion rights described above, please submit a verifiable consumer request to us by:

Calling us at (805) 966-7000
Emailing us at info@FLASLLP.com
Writing us at:
Fauver, Large, Archbald & Spray, LLP
820 State Street, 4^th Floor
Santa Barbara, CA 93101

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA and/or CPRA rights. Unless permitted by the CCPA and/or CPRA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@FLASLLP.com or write us at:

Fauver, Large, Archbald & Spray, LLP
820 State Street, 4^th Floor
Santa Barbara, CA 93101

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions are processed through a third-party payment processor. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Notice

FLAS reserves the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

Phone: (805) 966-7000
Website: flasllp.com
Email: info@flasllp.com

Postal Address:

Fauver, Large, Archbald & Spray, LLP
820 State Street, 4^th Floor
Santa Barbara, CA 93101

Privacy Policy

California Privacy Rights Notice

Santa Barbara Office

DIRECTIONS TO OUR OFFICE