Privacy Policy

This Privacy Policy governs the manner in which Pro Back Office, LLC dba PBO Advisory Group (“Pro Back Office,” “we” or “us”) collects, uses, maintains and discloses information collected from users (each, a “User”) of the https://www.pboadvisory.com/ website (our “Site”). This privacy policy applies to our Site and all products and services offered by PBO Advisory Group (our “Services”).

Information We Collect:

PERSONAL IDENTIFICATION INFORMATION

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on our Site, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site-related activities.

NON-PERSONAL IDENTIFICATION INFORMATION

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

WEB BROWSER COOKIES

Our Site may use “cookies” to enhance User experience. Users’ web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies as set forth below, or to alert you when cookies are being sent. If you do so, note that some parts of our Site may not function properly.

Most web browsers are set to accept cookies by default but also give you the option to manage and/or disable cookies and other online tracking technologies. To opt out of the use of these technologies, you can usually change your browser options to stop accepting cookies or to prompt you before accepting cookies. Keep in mind that not all devices and browsers are the same so the methods for disabling cookies on one browser may not be the same for different browsers or devices and may change at any time. Opting out of cookies and other tracking technologies may not preclude advertising networks from which you have not opted out from displaying customized advertising.  In addition, opting out will not prevent any advertising network from displaying advertising that is not customized to you and your interests and, consequently, may be less relevant to you.  You will need to make these choices on each browser and device you may use to visit our Site.

When you elect to opt out of cookies for a particular Site, an opt-out cookie is placed on your device. Then when you visit the same Site, the opt-out cookie tells the Site you opted out. This means that if you choose to remove or reject cookies, this could affect the availability and functionality of our services, including preventing your consent choices from being stored.  As a result, we may not know about, or be able to honor, your election to opt-out.  We encourage you to refer to the relevant instructions for your particular device or browser to learn how to manage cookies and other tracking technologies.  For more information on how to disable cookies on the most common browsers, we’ve assembled the following information for you below:

• Other Options for Disabling Online Tracking. Blocking cookies in your browser may not prevent cross-site tracking of your online activity using other online tracking technologies. In addition to managing your cookie settings for your browser, you can opt-out of tracking directly with the businesses that operate the tracking technologies. To opt-out of certain analytic tracking by our service providers visit the links below:

• Do Not Track.  Some web browsers may transmit “do not track” signals (go here to learn more). Web browsers may incorporate or activate these features differently, making it unclear if users have consciously activated them.  As a result, we do not take steps to respond to such signals.

• EUROPEAN VISITORS – COOKIES NOTICE.

In connection with the EU General Data Protection Regulation (GDPR) applicable in the European Economic Area (EEA) and the UK-GDPR applicable in the UK, we eliminate or limit the use of cookies and similar technologies with visitors from the EEA and the UK (excluding our corporate website available at https://pboadvisory.com, which continues to use cookies for all users with proper consent as explained below).  Specifically:

o   If you visit a third-party site that uses our Services, we will not place any cookies on your device unless you have provided your consent and been provided with notice of our privacy practices and your ability to opt-out at any time. We will not seek your consent to use cookies in this instance, though the advertiser or their website publisher may do so.

o   If you visit one of our Sites, we will only place limited third-party cookies, such as those made available for analytics purposes by Google and Bing. In this case, we will seek your consent to use these third-party cookies and will only do so after you indicate your consent. If you do not consent, then no cookies will be written to your device.

o   If you are visiting our corporate website, https://pboadvisory.com, for the first time, or the first time after we make a material change, we will seek your consent to use cookies.

o   If you do not consent, you will still be able to use our Services, but certain functionality may be limited. To enable this feature, we use third-party tools to determine your geographic location; if these tools indicate that you are in the EEA, then we treat your visit as above. If you feel that you are subject to GDPR, but we have nonetheless used cookies in connection with your visit without consent (which may be due to a failure of the third party geolocation tools, your use of a proxy server, your location outside of the EEA at the time of your visit, or some other factor beyond our control) please notify us through our email, admin@pboadvisory.com, and make sure to include any relevant details so that we can ensure proper treatment of your data under GDPR.

HOW WE USE COLLECTED INFORMATION

PBO Advisory Group may collect and use Users personal information for the following purposes:

– To improve customer service.  Information you provide helps us respond to your customer service requests and support needs more efficiently.
– To personalize user experience.  We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
– To improve our Site.  We may use feedback you provide to improve our products and services.
– To process payments.  We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
– To run a promotion, contest, survey or other Site feature. 

– To send Users information they agreed to receive about topics we think will be of interest to them.
– To send periodic emails.  We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

–Remember that information collected through cookies and other tracking technologies is used along with other collected information for the purpose outlined in this Privacy Policy, including remembering User’s settings and choices and assessing and improving our services.

HOW WE PROTECT YOUR INFORMATION

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sensitive and private data exchange between our Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

HOW WE SHARE YOUR PERSONAL INFORMATION

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and our Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

THIRD PARTY WEBSITES

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

As you browse PBO Advisory Group, advertising cookies will be placed on your computer so that we can understand what you are interested in.  Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other sites based on your previous interaction with PBO Advisory Group. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number. You can visit this page to opt out of AdRoll and their partners’ targeted advertising.

CHANGES TO THIS PRIVACY POLICY

PBO Advisory Group has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

WHERE INFORMATION IS PROCESSED & STORED

PBO Advisory Group is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. These data transfers are performed only for the purposes described in this Privacy Policy and are necessary to provide the Services to you globally.  We utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States.  For EEA visitors, please read the “EUROPEAN VISITORS – COOKIES NOTICE.” section above to learn more about our use of cookies and other technology for visitors from EEA, as well as the “VISITORS OUTSIDE THE UNITED STATES” section below.

PRIVACY RIGHTS FOR CALIFORNIA, THROUGHOUT THE UNITED STATES, AND EEA

This Privacy Notice supplements the information contained in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California, or are a citizen of a European Economic Area (EEA) Member State.  If you reside in the United States (outside of California), and to the extent your state has more comprehensive requirements than California, we will comply with any more stringent requirements. Please review the applicable sections below to learn more about your privacy rights and how to exercise them.

CALIFORNIA RESIDENTS

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.

• Uses and Disclosure of Your Information.  For more information on what information we collect, including the sources we receive information from, please review the above section “INFORMATION WE COLLECT.” We collect and use these categories of personal information (or personal data) for the business purposes described in the sections “HOW WE USE COLLECTED INFORMATION” and “HOW WE SHARE INFORMATION” including to provide, manage and improve, our Services.
• To help you further understand what categories of information we collect, the chart below shows specific categories of personal information and whether we have or have not collected such information from Service users within the last twelve (12) months:

• Access To Specific Information And Data Portability Rights.  California residents have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  You have the right to request the following:

o   The categories of personal information we collected about you;

o   The categories of sources from which the personal information was collected;

o   The categories of third parties with whom we share that personal information.

o   The categories of third parties to whom the personal information was sold or disclosed for a business purpose;

o   The business or commercial purpose for collecting or selling that personal information;

o   The specific pieces of personal information we collected about you (also called a data portability request).

o   If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• Sales: identifying the personal information categories that each category of recipient purchased; and
• Disclosures for a business purpose: identifying the personal information categories that each category of recipient obtained.

To exercise this right, please see “Exercising Access, Data Portability, And Deletion Rights.” below.  Once we receive and confirm your verifiable consumer request meets the requirements explained in the section “Exercising Access, Data Portability, And Deletion Rights.,” we will provide the requested information.  Keep in mind, if we do not have information that permits us to verify your identity, we may deny your request to access data.

• Deletion Request Rights.  California residents have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  To exercise this right, please see Exercising Access, Data Portability, and Deletion Rights below.  Once we receive and confirm your verifiable consumer request meets the requirements explained in the section 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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.
• If we do not have information that permits us to verify your identity, we may deny your request to delete.
• Exercising Access, Data Portability, And Deletion Rights.

o   Make a verifiable consumer request.  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either completing our Data Access & Erasure Form or by emailing us at:  admin@pboadvisory.com.   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 are an authorized representative; and
• 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.  Making a verifiable consumer request does not require you to create an account with us.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

o   Response timing and format.  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.  If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also 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 usable 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 any California resident for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

o   Deny you goods or services;

o   Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

o   Provide you a different level or quality of goods or services; or

o   Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

• Personal Information Sales Opt-Out And Opt-In Rights.

Under California law, if you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the “Do Not Sell My Personal Information” Section of our website.  Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:  Accessing ‘Personal Data Consent’ in ‘Settings’ on applicable Product being used.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

• Other California Privacy Rights.  California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  Requests can be made no more than once per calendar year.  To make such a request, please contact us at the email or address below and specify “Shine the Light Request.”  We will respond to your request within thirty (30) days of receiving it.

Email: admin@pboadvisory.com

Postal Address: 

Pro Back Office, LLC dba PBO Advisory Group
3655 Nobel Drive Suite 520
San Diego, CA 92122

Attn: Privacy Team

VISITORS OUTSIDE THE UNITED STATES

This Privacy Policy is intended to cover collection of information on our Services from residents of the United States. The data protection and other laws of the United States might not be as comprehensive as those in your country. Where permitted by applicable law, we may transfer the personal data we collect about you to other jurisdictions other than where you reside that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Policy.

By visiting or using our Services in any way, you acknowledge and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy, regardless of the laws of your country of residence.

To the extent the laws of another jurisdiction apply to your data or use of our Services, we will comply with such laws. For example, for European Visitors, read the “EUROPEAN VISITORS – COOKIES NOTICE.” section of Cookies and Other Technologies to learn more about our use of cookies and similar technologies with visitors from the EEA.

EU Visitors

If you are an EU citizen or UK citizen, you may have additional rights under the EU General Data Protection Regulation or the UK-GDPR  (collectively, the “GDPR”) with respect to your Personal Data, as outlined below. For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users in connection with our provision of certain Services, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at:  admin@pboadvisory.com.

The legal bases for which we collect and use the information described above depends on what the information is and why we collected it. The four bases upon which we rely include:

• Contract. This means we need the information to perform our contracted Services with you. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require that data.
• Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy. For example, it is in our interest to protect your safety and security in the Services, so we collect and use information that has been flagged by users or requested by law enforcement; to make sure you are satisfied with how the services work, troubleshoot technical problems or develop new features, we collect and use information about how you and others use the services and to respond to your service inquiries, we collect and use information in that request and, if relevant to the inquiry, information about how you access and use the services.
• Legal Obligation. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.
• Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU and UK citizens have certain rights regarding your personal information, including: 

• Right to Object or Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal bases for using your information is based upon our legitimate interest. If you wish to object to our use of your information, you can send us a request to delete your account by sending an email to:  admin@pboadvisory.com.
• Right to Access or Erasure. You have the right to have your personal data erased and no longer processed. You also have the right to access the Personal Data we have collected about you.  You can send us a request to delete your account or access your information by completing our Data Access & Erasure Form or by sending an email to:  admin@pboadvisory.com. Upon receiving the request, we will make a reasonable effort to delete your personal information from the Service and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion.
• Withdrawal of Consent. If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data if such use or disclosure is necessary to enable you to utilize some or all of the Services. You can exercise your right to withdraw consent by completing our by sending us an email to:  admin@pboadvisory.com.
• Data Portability. You can exercise your right to export your personal data by completing our Data Access & Erasure Form or by sending us an email to:  admin@pboadvisory.com.
• File a Complaint. You have the right to complain to the data protection authority located in your Member State. To find contact details, click here.

As explained above, personal data collected in the EU or UK may be transferred to, and/or stored at, a destination outside of the EU and/or UK and processed by employees operating outside of the EU and/or UK who work for us, one of our business partners, or service providers. We have implemented sufficient GDPR compliant procedures to secure the transfer of your personal data to the United States. We utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States.

CHILDREN’S INFORMATION

The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from children under 13.

Additionally, we do not knowingly collect or solicit personal data from anyone under the age of 16 in countries subject to the EU GDPR, unless exempted by individual country exceptions.

If you are under 13, or 16 where applicable, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under the required minimum age, we will delete that information as quickly as possible. If you believe that a child under the required minimum age may have provided us personal information, please contact us at:  admin@pboadvisory.com.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of our Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

Pro Back Office, LLC dba PBO Advisory Group
3655 Nobel Drive Suite 520

San Diego, CA 92122

858-622-1681

admin@pboadvisory.com

This document was last updated on August 29, 2023