PRIVACY POLICY
Scope and Acceptance
Effective Date: [May, 2026]
This Privacy Policy describes how Palm Sterling LLC, a California limited liability company (“Palm Sterling,” “we,” “us,” or “our”), collects, uses, discloses, retains, and safeguards information obtained through [www.palmsterling.com] and any related pages, forms, member areas, and electronic communications that link to this Privacy Policy (collectively, the “Site”). This Privacy Policy applies solely to information collected through the Site and does not govern information collected offline, through separate written agreements, or through any third-party website, platform, or service, each of which is subject to its own terms and policies.
By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your information as described herein. If you do not agree with this Privacy Policy, you should discontinue use of the Site. This Privacy Policy is incorporated into, and forms part of, the Site’s Transparency and Disclosure terms.
Palm Sterling reserves the right to amend this Privacy Policy at any time. When we make material changes, we will post the revised Privacy Policy on this page and update the Effective Date above, and where required by applicable law, we will provide additional notice through the Site or by email. Your continued use of the Site after the posting of changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.
The Site is intended for general audiences in the United States and is operated from the United States. If you access the Site from outside the United States, you acknowledge that your information will be transferred to, processed, and stored in the United States, where data protection laws may differ from those of your jurisdiction.
Information We Collect and How We Use It
Information you provide directly. We collect information you choose to submit through the Site, including your name, email address, telephone number, company name, job title, mailing or site address, the contents of any inquiry, service request, or message, account credentials if you register for a member area, and your preferences regarding newsletters and other communications.
Information collected automatically. When you visit the Site, we and our service providers automatically collect certain technical information, including your Internet Protocol (IP) address, browser type and version, device type and operating system, referring and exit pages, pages viewed, time and duration of visits, and general geographic location derived from your IP address. We collect this information through cookies, pixels, web beacons, local storage, and similar technologies. Most browsers allow you to refuse or delete cookies; doing so may limit certain features of the Site.
Information from other sources. We may receive information about you from business contacts, referral sources, licensed or contracted partners engaged to fulfill a service you request, and publicly available sources, and we may combine that information with information we collect through the Site.
How we use information. We use the information described above to respond to inquiries and service requests; evaluate, arrange, and deliver services, including through licensed or contracted partners; send newsletters and updates to which you have subscribed; operate, maintain, secure, and improve the Site; analyze usage trends and Site performance; detect, prevent, and investigate fraud, security incidents, and other unlawful activity; comply with legal obligations, legal process, and lawful requests from public authorities; and establish, exercise, or defend legal claims and otherwise protect the rights, property, and safety of Palm Sterling, its affiliates, its clients, and others.
How we disclose information. We disclose information only as follows: to service providers that perform functions on our behalf, such as website hosting, form processing, email delivery, and analytics, under obligations to use the information solely to provide services to us; to licensed or contracted partners where necessary to fulfill a service you have requested; to our affiliates, officers, managers, and professional advisors, including attorneys, accountants, and insurers; to governmental authorities, courts, or other parties where we believe in good faith that disclosure is required by law, regulation, or legal process, or is necessary to protect rights, property, or safety; in connection with any actual or proposed merger, acquisition, financing, reorganization, sale of assets, or transfer of all or part of our business, in which case information may be transferred as a business asset; and with your consent or at your direction. [CONFIRM: Palm Sterling does not sell personal information and does not share personal information for cross-context behavioral advertising. If any advertising, retargeting, or third-party marketing pixels are installed on the Site, this sentence must be revised before publication.]
Third-party tracking. Third parties that provide analytics or other services on the Site may collect information about your online activities over time and across different websites when you use the Site. These third parties are governed by their own privacy policies.
Do Not Track. Some browsers transmit “Do Not Track” signals. Because no uniform standard for recognizing and responding to such signals has been adopted, the Site does not currently respond to Do Not Track signals. [If Palm Sterling becomes subject to the CCPA, it must honor Global Privacy Control signals as valid opt-out requests, and this paragraph will be updated accordingly.]
Retention. We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, tax, and reporting obligations, resolve disputes, and enforce our agreements, after which we delete or de-identify it.
Security. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No method of transmission over the internet or method of electronic storage is completely secure, and Palm Sterling cannot guarantee absolute security. You transmit information to the Site at your own risk.
Third-party websites. The Site may contain links to websites and services operated by third parties. Palm Sterling does not control and is not responsible for the content or privacy practices of those websites, and the inclusion of a link does not imply endorsement.
Children. The Site is intended for business use by adults and is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If we learn that we have collected such information, we will delete it promptly. If you believe a child has provided information to us, please contact us using the details below.
Your Rights, Choices, and Contact
Review and correction. You may request to review, correct, or update the personal information you have provided to us through the Site, or request that we delete it, by contacting us as described below. We will respond within a reasonable time and as required by applicable law. We may need to verify your identity before acting on a request, and we may retain certain information where permitted or required by law.
Email communications. You may unsubscribe from newsletters and marketing emails at any time by using the unsubscribe link in any such email or by contacting us. We will honor your request within the time required by law. Unsubscribing does not apply to transactional or service-related communications regarding a request you have made.
California privacy rights. If you are a California resident, you may have additional rights under California law, which are described in our California Privacy Notice, available at [link to CCPA page]. [CONFIRM headcount: If Palm Sterling has 20 or more employees, add: “Under California Civil Code Section 1798.83, California residents may request, once per calendar year, information regarding the disclosure of personal information to third parties for their direct marketing purposes. Palm Sterling does not disclose personal information to third parties for their direct marketing purposes.”] Palm Sterling will not discriminate against you for exercising any privacy right available to you under applicable law.
Accessibility. This Privacy Policy is available in alternative formats upon request. Please contact us using the details below.
Contact us. If you have questions about this Privacy Policy or wish to exercise any of the rights described above, please contact:
Palm Sterling LLC
Attn: Privacy
[privacy@palmsterling.com]