Privacy Policy

This Privacy Policy explains how ACW & Associates LLC (“ACW & Associates LLC”, “ACESBA”, “we”, “us” or “our”) collects, uses, discloses and protects personal information when you visit acesba.com (the “Site”), take the SBA Readiness Assessment, buy our products, attend our workshops or otherwise interact with us (together, the “Services”).

1. Who we are and what this policy covers

ACW & Associates LLC owns and operates ACESBA and is responsible for the personal information described in this policy. This policy applies to information collected through the Services. It does not apply to third-party websites or services we link to, such as sba.gov or a lender’s website, which have their own policies.

2. Information we collect

Information you give us

• Identity and contact details: your first name and email address.
• Business details: your business name and, if you choose to provide it, your business website.
• Assessment answers: your selections in the SBA Readiness Assessment, such as business structure, ownership and citizenship status of owners, industry, time in business, revenue range, cash-flow range, state of your financial records and tax filings, estimated personal credit score range, recent credit events, the amount and purpose of the financing you need, your available equity range, and whether a declared disaster has affected you. We ask for ranges and estimates, not exact figures or documents.
• Purchase information: the products you buy, the amount, the date and the email address used.
• Communications: messages you send through our contact form or by email, and any workshop registration details.
• Marketing preferences: whether you agreed to receive SBA funding tips and workshop news.

Information collected automatically

• Technical and log data: when you visit the Site, our hosting and security provider processes your IP address, browser and device type, pages requested, referring page and the date and time of each request, to deliver the Site, protect it against attacks and diagnose errors.
• Cookies and local storage: see Section 7.

Information from third parties

• Payment confirmation: Stripe tells us whether a payment succeeded and may share your email address, name, country and postal code as entered at checkout. We never receive your full card number or bank details.

Information we do not collect

We do not ask for and do not want your Social Security number, Employer Identification Number, Individual Taxpayer Identification Number, date of birth, driver’s license or passport number, bank or card account numbers, credit reports, tax returns or other financial documents. Please do not send them to us.

3. Sensitive information

Some assessment answers may be considered sensitive under certain state privacy laws, in particular the citizenship or immigration status and country of residence of your business's owners (which reflects SBA eligibility rules), and your estimated credit score range. By selecting these answers you consent to our processing them for the sole purpose of producing your report and its recommendations. We do not sell this information, use it for advertising or share it with lenders. You may decline to take the assessment, and you may ask us to delete your answers at any time (Section 11).

4. How we use information

• To provide the Services: to score your assessment, display your results, produce and email your detailed report, deliver purchased files, operate your account and sign you in with one-time codes, and run workshops.
• To process payments and keep records of transactions.
• To communicate with you: to send receipts, download links, sign-in codes and replies to your messages; and, if you complete every assessment question without completing your purchase, one reminder that your report is ready.
• For marketing, only with your consent: to send SBA funding tips and workshop news if you opt in.
• To improve the Services: to understand how our assessment and products are used and to improve them, using aggregated or de-identified information wherever possible.
• For security and legal reasons: to prevent fraud and abuse, protect the Services and our users, enforce our Terms of Service, and comply with law, including tax and accounting obligations.

We do not use your information to make decisions that produce legal or similarly significant effects about you. Your readiness score is an educational estimate shown only to you.

5. How we share information

We share personal information only as follows:

• Service providers that process it on our behalf, under contracts that limit their use of it to providing services to us:
  • Stripe (payment processing and fraud prevention);
  • Cloudflare (website hosting, database and file storage, content delivery and security);
  • Resend (sending transactional and, with consent, marketing email); and
  • Indian Type Foundry (Fontshare) (web fonts loaded from its servers, which receive your IP address and browser information when a page loads).
• Legal and safety: where required by law, subpoena or court order, or where necessary to protect the rights, property or safety of ACW & Associates LLC, our users or others.
• Business transfers: in connection with a merger, acquisition, financing or sale of all or part of our business, subject to this policy.
• With your direction: when you ask us to, for example by forwarding your report to someone yourself.

We do not share your information with lenders, brokers or the SBA.

6. No sale, no targeted advertising

We do not sell personal information, we do not share it for cross-context behavioral or targeted advertising, and we do not use advertising cookies or third-party advertising trackers. Because we do not sell or share personal information for these purposes, we do not offer an opt-out of sale; if you send a Global Privacy Control signal, we treat it as a request not to sell or share your information, which we already honor.

7. Cookies and similar technologies

• Sign-in cookie (acesba_session): a strictly necessary, secure cookie that keeps you signed in to your account for up to 30 days, or until you sign out.
• Assessment progress (browser storage): your browser stores a reference to an assessment in progress so you can resume it. It contains no answers or contact details.
• Security cookies: Cloudflare may set strictly necessary cookies to detect bots and protect the Site.

We do not use analytics, advertising or social media tracking cookies. Because the cookies we use are strictly necessary, the Site does not display a cookie banner. You can block or delete cookies in your browser, but you will then need to sign in each time you visit.

8. Emails we send

Transactional emails (sign-in codes, receipts, download links, reports you request, replies to your messages and the single reminder described in Section 4) are part of the Services. Marketing emails, including our weekly newsletter, the ACESBA Weekly Digest, are sent only if you opt in, and sign-ups through our website forms are confirmed by email before we send anything else. Every marketing email includes an unsubscribe link and our postal address. If you have purchased a Readiness Report, we use your score, readiness level, best-fit program and the area that needs the most work to tailor the newsletter we send you; we never include your individual answers. You can unsubscribe at any time without affecting transactional emails.

9. How long we keep information

• Paid reports, orders and account information: for as long as your account is active so you can access your reports and files, and for up to seven years after your last purchase to meet tax, accounting and legal obligations.
• Assessments that are not purchased: for up to 12 months, so you can return and complete your purchase, and then deleted or de-identified.
• Contact messages: for up to two years after our last exchange.
• Marketing preferences: until you unsubscribe, after which we keep a record of the opt-out so we do not email you again.
• Technical and log data: for the limited periods set by our hosting and security provider.

We may keep information longer where required by law or to resolve disputes and enforce our agreements.

10. How we protect information

We use administrative, technical and physical safeguards designed to protect personal information, including encrypted connections (HTTPS) for all pages, payment processing by Stripe so that card data never reaches our systems, one-time sign-in codes instead of passwords, session tokens stored only in hashed form, private file storage served only through signed, time-limited links, and access limited to people who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you as required by law.

11. Your privacy rights

Depending on where you live, including under the Texas Data Privacy and Security Act, the California Consumer Privacy Act and similar state laws, you may have the right to:

• know and access the personal information we hold about you and receive a copy in a portable format;
• correct inaccurate personal information;
• delete personal information, subject to legal exceptions such as records we must keep for tax purposes;
• opt out of the sale of personal information, targeted advertising and profiling in furtherance of significant decisions (we do none of these);
• withdraw consent to processing of sensitive information; and
• not be discriminated against for exercising any of these rights.

How to make a request. Email support@acesba.com from the email address associated with your account or purchase, or write to us at the address in Section 15. We may need to verify your identity before acting on a request, normally by confirming access to that email address. An authorized agent may submit a request on your behalf with your signed permission. We will respond within 45 days, or tell you if we need up to 45 more days and why.

Appeals. If we decline your request, you may appeal by replying to our decision or emailing support@acesba.com with the subject “Privacy appeal”. We will respond to an appeal within 60 days. If you are not satisfied with the outcome, you may contact the attorney general of your state; Texas residents may contact the Office of the Texas Attorney General.

12. Children

The Services are intended for adults operating businesses and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with information, contact us and we will delete it.

13. Where information is processed

The Services are offered to businesses in the United States. We store personal information with providers in the United States; our hosting provider’s network processes requests in data centers worldwide to deliver the Site quickly and securely. By using the Services from outside the United States, you understand that your information will be processed in the United States.

14. Changes to this policy

We may update this policy from time to time. We will post the revised policy on this page with a new effective date and, for material changes, notify account holders by email or by a notice on the Site before the changes take effect.

15. Contact

ACW & Associates LLC
Attn: Privacy
500 Crawford Street
Houston, TX 77002
United States
Email: support@acesba.com