Introduction

Full Circle Asset Recovery LLC ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our asset recovery platform and related services (collectively, the "Service").

We operate as an attorney-represented asset recovery company specializing in tax lien/deed surplus recovery, mortgage foreclosure surplus, heirship/probate recovery, Medicaid estate recovery, and redemption assistance. By using our Service, you consent to the data practices described in this policy.

Information We Collect

Personal Information You Provide

We collect personal information that you voluntarily provide when using our Service, including:

• Account Information: Name, email address, phone number, mailing address, and password
• Case Information: Property addresses, surplus fund amounts, county and state information, deal structures, and contract details
• Claimant/Heir Information: Full name, date of birth, relationship to deceased/property owner, contact information, and supporting documentation
• Financial Information: Bank account details (via secure third-party integrations), payment information, and transaction records
• Attorney/Professional Information: Bar license numbers, state admissions, malpractice insurance details, and professional credentials
• Identity Verification Documents: Government-issued identification, death certificates, marriage certificates, and other vital records

Information Collected Automatically

When you access or use our Service, we automatically collect certain information:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages viewed, features accessed, time spent on pages, click patterns
• Log Data: Access times, error logs, and referring URLs
• Cookies and Tracking Technologies: Session cookies, persistent cookies, and similar technologies

Information from Third-Party Sources

We may collect information from third-party sources to provide our services effectively:

• Skip Trace Providers: Contact information, address history, and public records (via TLOxp, TruePeopleSearch, and similar services)
• Financial Data Providers: Bank account verification and transaction data (via Plaid)
• Property Data Providers: Property valuations, foreclosure data, and tax records (via ICE SiteXPro and county records)
• Vital Records: Birth, death, and marriage records from government registries (including international sources)
• Public Records: Court records, probate filings, and government databases

How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: Process asset recovery claims, manage cases, and facilitate surplus fund distributions
• Heirship Verification: Verify family relationships and identify rightful heirs to unclaimed funds
• Attorney Coordination: Facilitate communication and case management with our attorney network
• Financial Processing: Process payments, calculate commissions, and manage accounting records
• Legal Compliance: Comply with court requirements, filing obligations, and regulatory mandates
• Fraud Prevention: Detect, prevent, and investigate fraudulent claims or unauthorized access
• Service Improvement: Analyze usage patterns to improve our platform and services
• Communication: Send case updates, service notifications, and (with consent) marketing communications
• AI-Assisted Processing: Utilize machine learning and artificial intelligence to improve case evaluation, document processing, and decision-making

Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Attorney Network: With licensed attorneys handling your case for legal representation and filings
• Service Providers: With trusted third-party vendors who assist in operating our platform (payment processors, cloud hosting, communication services)
• Financial Institutions: With banks and payment processors to facilitate fund transfers
• Government Agencies: With courts, tax authorities, and regulatory bodies as required for case processing
• County/State Officials: With government officials to verify claims and process surplus fund distributions
• Legal Requirements: When required by law, subpoena, court order, or to protect our legal rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Consent: When you have provided explicit consent for specific sharing

Data Security

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption: We use encryption for data in transit (TLS) and at rest where technically appropriate
• Access Controls: Role-based access controls limit data access to authorized personnel
• Audit Logging: Access to personal information is logged for security and compliance purposes
• Secure Infrastructure: We host our Service on enterprise-grade cloud infrastructure
• Password Security: User passwords are hashed using industry-standard algorithms
• Security Practices: We maintain security monitoring and assessment practices

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security. For more details about our data processing practices, see our Data Processing Addendum.

Third-Party Integrations

Our Service integrates with the following third-party services, each with their own privacy policies:

• Plaid: Bank account linking and financial data aggregation - Plaid Privacy Policy
• QuickBooks Online: Financial management and accounting
• Google Cloud Services: Cloud infrastructure and data storage
• DocuSign: Electronic signature services
• Sentry: Error tracking and monitoring

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy:

• Active Cases: Data is retained for the duration of case processing plus applicable statute of limitations periods
• Closed Cases: Records are retained for a minimum of 7 years for legal and tax compliance
• Account Information: Retained until you request deletion, subject to legal retention requirements
• Audit Logs: Maintained for security and compliance purposes

Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to legal retention requirements
• Portability: Request transfer of your data in a machine-readable format
• Objection: Object to processing of your personal information for certain purposes
• Withdraw Consent: Withdraw consent for optional data processing at any time
• Opt-Out: Opt out of marketing communications

How to Submit a Privacy Request

To exercise your privacy rights, you may submit a request through the following methods:

Contact Methods

• Email: privacy@fullcircleassetrecovery.com (preferred method)
• Mail: Full Circle Asset Recovery LLC, Attn: Privacy Requests, 721 Belmont St, Suite 1A, Brockton, MA 02301

What to Include in Your Request

To help us process your request efficiently, please include:

• Your full name and email address associated with your account
• The specific right(s) you wish to exercise
• Any details that will help us locate your information (e.g., case numbers)
• Your preferred contact method for our response

Identity Verification

To protect your privacy, we must verify your identity before processing certain requests. Depending on the request, we may ask you to:

• Confirm information we have on file (email, phone number, address)
• Provide a copy of government-issued identification (for deletion or access requests)
• Answer security questions related to your account

If you are submitting a request on behalf of another person (authorized agent), we will require written authorization from the data subject.

Response Timelines

We will respond to your request within:

• Acknowledgment: Within 10 business days of receipt
• Substantive Response: Within 45 days (may be extended by an additional 45 days for complex requests, with notice)
• CCPA/CPRA Requests: Within 45 days as required by California law
• GDPR Requests: Within 30 days as required by EU law (if applicable)

Limitations

We may not be able to fulfill all requests in certain circumstances:

• Legal or regulatory requirements that require retention
• Ongoing legal matters or disputes
• Legitimate business needs (e.g., fraud prevention)
• Requests that are manifestly unfounded or excessive

If we cannot fulfill your request, we will explain the reasons and any alternatives available.

California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, and shared
• Right to delete personal information (with certain exceptions)
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising privacy rights

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Required for platform functionality and security
• Functional Cookies: Remember your settings and preferences
• Analytics Cookies: Help us understand how users interact with our Service

For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

Children's Privacy

Our Service is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Email: privacy@fullcircleassetrecovery.com

Legal Inquiries: legal@fullcircleassetrecovery.com

Address: Full Circle Asset Recovery LLC, 721 Belmont St, Suite 1A, Brockton, MA 02301