Effective October 16, 2023
1. Scope of This Policy
2. Agreement to Terms
3. Information We Collect
We may collect the following categories of personal information (a) directly from you (such as when you respond to our forms or when you contact us, (b) from the device and browser that you use to access the Site, and (c) from cookies and similar technologies.
- Identifiers. We may collect your first name, last name, email address, and phone number.
- Device Information. We may collect device information when you visit our Site. Device information may include your device type, browser type, online and/or unique identifiers, IP address, and geolocation information.
- Internet Activity. We may collect information concerning your interaction with the Site, including when you access the Site and your browsing activity on the Site (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Site.
We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on the Site are generally divided into the following categories:
- Strictly Necessary Cookies. These are required for the operation of the Site. These cookies are session cookies that are erased when you close your browser.
- Analytical/Performance Cookies. These allow us to recognize and count the number of visitors to the Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located). We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics—learn more by going to https://tools.google.com/dlpage/gaoptout.
- Marketing Cookies. These record your visit to the Site and the pages you have visited and the links you have followed, to recognize you as a previous visitor, and to track your activity on the Site and other websites you visit. These cookies are used to display ads on other websites based on your visits to our Site and other online activity. These cookies qualify as persistent cookies because they remain on your device.
You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Site, however, you might not be able to access or use important functions or features of our Site, and you may, for example, be required to re-enter your log-in details.
At this time, we do not recognize automated “do-not-track” browser signals.
5. Children’s Privacy
The Site is not intended for users under the age of 16 and ASP does not knowingly collect personal information from individuals under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Site without permission, please notify us immediately by contacting us as detailed in the How to Contact Us section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
6. Our Use of Personal Information
We collect and use your personal information for the following purposes:
- Providing the Site to you and providing products or services requested by, or reasonably anticipated within the context of our relationship with, you;
- Managing our relationship with you, and responding to your inquires or requests, and requesting feedback;
- Analyzing use of the Site;
- Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
- Complying with legal and regulatory obligations.
7. Our Disclosure of Personal Information
We may share your personal information with the following third parties:
- Service providers, including IT outsourcing and analytics providers. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
- Our Partners/Clients.
- Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
- With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
- Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect the information we receive from you through the Site. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.
9. Links to Other Websites
For your convenience, we may link to third-party sites and services, or otherwise display third-party content through our Site to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.
11. How to Contact Us