Policies

Who We Are

The Passage Trust website (https://passagetrust.com) is operated by Lobb & Plewe, LLP, which is the business responsible for the collection and use of personal information described in this Privacy Policy.

Data Controller: Lobb & Plewe, LLP
Email: derdmann@lobbplewe.com
Address: 4160 Temescal Canyon Rd. Suite 202, Corona, CA 92883

What Data We Collect

We collect the following categories of personal information when you use our website and when you submit information to us so our attorneys can prepare trust documents and follow up with you:

Contact and application form information: first and last name, email address, phone number, and information you provide about your assets and legal situation.

Cookie preference information: your cookie consent preferences and related records created when you set or update your choices through our consent management system.

Device and technical information: IP address, browser type, and related technical data needed for the website to load, function, and be protected against misuse.

Analytics information (with your consent): information about how visitors interact with the website collected through analytics services, which may use cookies or similar technologies when enabled.

We collect personal information from the following sources:

Directly from you when you submit our contact or application forms.
Automatically from your device when you access the website (for example, IP address and browser information).
From cookies and similar technologies, including analytics cookies, when you choose to allow them.

Providing form information is optional, but if you do not provide it, we may not be able to respond to your inquiry or evaluate potential trust and estate planning services. Device and technical information is required to operate and secure the website.

How We Use Your Data

We use your personal information for the following purposes, and we rely on the legal basis listed for each purpose:

To respond to your inquiries and communicate with you about The Passage Trust and related trust and estate planning services (contract).

To evaluate your submitted information so our attorneys can prepare trust documents and follow up with you regarding potential engagement (contract).

To protect the website, our business, and visitors against security threats, abuse, and fraud, including monitoring and investigating suspicious activity using technical and security information (legitimate interest).

To measure and understand website performance and visitor interactions using analytics technologies that require your permission (consent).

Who We Share Your Data With

We share personal information only as needed to operate and secure the website and to provide the services described above.

Google reCAPTCHA: We use Google reCAPTCHA to help protect our website and forms from spam and abuse. When reCAPTCHA is used, certain device and technical information may be processed to assess whether activity appears legitimate. Google processes this information under its own privacy policy.

Analytics service providers: If you allow analytics, we share certain information (such as device and interaction data collected through cookies or similar technologies) with our analytics service providers so we can understand how the website is used and improve it. These providers process information under their own privacy policies.

Consent management (Trustwards): We use our own consent management system (Trustwards) to record and manage your cookie preferences. This data is processed internally and not shared with third parties.

International Data Transfers

Some of our service providers are located outside the primary processing jurisdiction, specifically in the United States.

Google reCAPTCHA: Google LLC (United States). Google LLC is certified under the EU-U.S. Data Privacy Framework (DPF).

Trustwards: Our consent management system (Trustwards) is based in Spain (EU), so consent data is not transferred internationally.

How Long We Keep Your Data

Contact and application form submissions are retained only as long as necessary to respond to inquiries and evaluate potential trust and estate planning services. Client records and engagement files are retained in accordance with applicable legal recordkeeping and professional responsibility requirements for attorneys.

Cookie consent records: 10 years (to demonstrate compliance and address potential claims within legal limitation periods).

Security logs and technical records: 12 months.

Analytics data: until consent is withdrawn or according to the analytics tool retention settings.

Your Rights

If you are a California consumer, you have rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), including the right to know what personal information is collected, used, shared, or sold; the right to delete personal information; the right to correct inaccurate personal information; the right to opt-out of the sale or sharing of personal information (Do Not Sell or Share My Personal Information); the right to limit the use and disclosure of sensitive personal information; and the right to not be discriminated against for exercising your privacy rights.

To exercise your rights, contact us at derdmann@lobbplewe.com. We will take steps to verify your request before responding. For CCPA/CPRA requests, we generally respond within 45 days, and we may extend this period by an additional 45 days when reasonably necessary, with notice to you.

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you.

Children's Privacy

Our services are not directed at children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

Data Security

We implement appropriate technical and organizational measures designed to protect personal information. However, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security, but we take reasonable precautions to reduce risk.

Data Breach Notification

We maintain procedures designed to detect, report, and investigate security incidents. If we become aware of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay and provide information about the nature of the breach, likely consequences, and measures taken or proposed to address it. If you suspect a security issue involving our website, please contact us at derdmann@lobbplewe.com.

How to Lodge a Complaint

We encourage you to contact us first so we can try to resolve your concern.

California consumers may also submit complaints to the California Privacy Protection Agency (CPPA) and/or the California Attorney General. The CPPA website is https://cppa.ca.gov/.

If you are located outside California, you may have the right to lodge a complaint with the competent authority in your jurisdiction.

Updates to This Policy

We review and update this Privacy Policy periodically. The “Last updated” date at the top of this policy indicates when changes were last made. If we make significant changes, we will provide notice by posting an updated policy on the website and, where appropriate, by email. Changes take effect from the date indicated at the top of this policy. Where our processing relies on consent, we will request new consent when required.

Contact Us

Email: derdmann@lobbplewe.com
Address: 4160 Temescal Canyon Rd. Suite 202, Corona, CA 92883
Data Controller: Lobb & Plewe, LLP

California Privacy Rights (CCPA/CPRA)

This section applies to California consumers and serves as our Notice at Collection.

Categories of personal information collected in the last 12 months:

Identifiers: such as first and last name, email address, phone number, IP address, and online identifiers associated with cookie preferences.

Internet or other electronic network activity information: such as information about interactions with our website when analytics is enabled and technical information used to operate and secure the site.

Professional or employment-related information and other information you provide in forms: such as information you submit about your assets and legal situation for trust and estate planning evaluation and preparation of trust documents.

Business or commercial purposes for collecting personal information:

To respond to inquiries and communicate with you about The Passage Trust and related trust and estate planning services.
To evaluate your submitted information so our attorneys can prepare trust documents and follow up with you regarding potential engagement.
To operate, maintain, and secure the website, including protecting against spam and abuse.
To understand website performance and improve the website through analytics, when you allow analytics technologies.

Sale and sharing of personal information:

We do not sell personal information.
We do not share personal information for cross-context behavioral advertising.

Do Not Sell or Share My Personal Information:

Because we do not sell personal information and do not share personal information for cross-context behavioral advertising, we do not offer a separate opt-out mechanism for sale or sharing. If you believe our practices have changed or you have questions, contact us at derdmann@lobbplewe.com.

Global Privacy Control (GPC):

We honor Global Privacy Control (GPC) signals as valid opt-out requests for sale or sharing where applicable.

Right to limit the use and disclosure of sensitive personal information:

We do not collect or use sensitive personal information for purposes that would require offering a right to limit under the CCPA/CPRA. If you believe you have provided sensitive personal information and want to request a limitation, contact us at derdmann@lobbplewe.com.

How to submit a request and our verification process:

You may submit requests to know, delete, or correct by emailing derdmann@lobbplewe.com. To protect your information, we will verify your identity by requesting information reasonably necessary to confirm you are the person about whom we collected personal information, and we may request additional details to understand and respond to your request.

Response timing:

We generally respond within 45 days. If we need more time, we may extend by an additional 45 days and will notify you of the reason for the extension.

Non-discrimination:

We do not discriminate against you for exercising your CCPA/CPRA rights.