Privacy Policy

Last updated: 9 September 2026

Who we are and what this notice covers

117 Partners LLC, 130 Canal St., #602, Pooler, GA 31322, United States, is responsible for the personal information it uses to operate its website, respond to enquiries and provide its services. Contact us at Tom@117partners.com. This notice covers general business enquiries, claims-related enquiries and administrative preparation support, including CLEU remission enquiries, and communications about our services. It explains our processing; it does not make website use consent to all processing or create an engagement.

Information we collect

Depending on your enquiry and the services requested, information may include your name, contact details, country or time zone, preferred contact channel, telephone or WhatsApp number and Telegram username; shareholdings, purchase and sale dates, transaction values, withdrawals, estimated losses, currencies and other recoveries; official notice or claim identifiers; promoter, platform or group details; your account of an alleged fraud; and correspondence, brokerage statements, trade confirmations or other supporting records provided later. General business enquiries may also include identity, address, business and transaction information relevant to the service. We may receive technical information such as IP address, browser/device information, pages visited, referral sources and form delivery or security logs through website and service providers.

Where information comes from

We receive information from you, people you authorise, service providers and, where permitted, public records, referral sources or shareholder communications providers. If a provider distributes a communication on our behalf, it may use its own or an intermediary’s records without giving us the underlying shareholder list. Where we receive recipient or response information, the categories may include contact details, relevant shareholding information, the source of a referral, delivery or response status and opt-out preferences. You may contact us to ask about the source of information we hold about you. Receipt of an outreach message does not establish eligibility for remission or mean that you have engaged us.

Why we use information

We use relevant information to respond to enquiries, assess whether administrative support may be suitable, check the completeness of records against published requirements, organise supporting information, prepare factual drafts for your review and submission, and communicate about your enquiry or engagement. We also use information to administer agreements and lawful fees, maintain business records, manage service providers, operate and secure the website, prevent misuse, resolve disputes, comply with legal obligations and record communication preferences. For CLEU matters, you remain responsible for reviewing and submitting your petition and certifications. We do not provide legal representation before DOJ or Kroll.

Legal bases and sensitive information

Where data protection law requires a legal basis, we rely as appropriate on steps you request before entering an agreement and performance of that agreement; legitimate interests in responding to enquiries, providing and securing our services and administering our business, balanced against your rights; legal obligations; or consent where required. We do not treat legitimate interests as a substitute for consent where marketing or other laws require consent. Information about an alleged fraud may include information about third parties or alleged offences; provide only information relevant to your matter. Where additional protections apply to sensitive information or offence-related data, processing must have the additional legal condition or authority required by applicable law. If you do not provide information needed to assess or support your enquiry, we may be unable to proceed.

Enquiry responses and shareholder outreach

Submitting an enquiry asks us to respond about that enquiry using the contact channel you select; it does not subscribe you to unrelated marketing. We may use communications providers to distribute information about our commercial services to shareholders or other potential clients where permitted by applicable law. Such outreach is from or on behalf of 117 Partners and is not an official DOJ or Kroll notice. Where consent is required, it must be obtained before the relevant marketing. You can opt out using the instructions in a message or by contacting us at Tom@117partners.com. You may also change your preferred channel or ask us to stop enquiry follow-up. We may retain limited suppression information to honour your choice and continue necessary service or legal communications.

Who may receive information

Access may be given, as needed for the purposes above, to our personnel and contractors and providers supporting website hosting, forms, email, messaging, document storage, customer administration, security and communications. We may disclose relevant information to professional advisers and to authorities where required by law or necessary to establish or protect legal rights. Claims information may be shared with a remission or claims administrator, including Kroll or DOJ, where you specifically authorise the disclosure or the law requires it; an enquiry alone does not authorise us to file or certify a petition for you. Administrators and authorities process information under their own rules and privacy notices. We do not use this notice as permission to sell your claims-intake information or disclose it to unrelated parties for their own marketing. Any disclosure for a separate claims transaction or introduction will be explained in the relevant service context.

International processing

117 Partners is based in the United States. Information may be stored or accessed in the United States and other countries where relevant personnel, contractors or providers operate. Those countries may have different data protection laws from your country. Where applicable law requires safeguards for an international transfer, the transfer must use an applicable adequacy decision, approved contractual safeguards or another legally permitted mechanism. Contact us for information about the countries and safeguards relevant to your information and, where applicable, a copy of the safeguards subject to necessary redactions. Submitting a form is not blanket consent to unrestricted international transfers.

How long information is kept

We retain personal information for as long as reasonably necessary for the purpose for which it was collected. Relevant criteria include whether an enquiry remains active or becomes an engagement; the status and duration of a claims or remission process; requirements for business, tax and accounting records; applicable limitation periods and legal holds; and the need to resolve disputes, maintain security or honour opt-outs. Records no longer needed for these purposes should be deleted or anonymised, subject to applicable requirements and backup cycles. You may ask us about retention for your particular records or request deletion; some information may need to be retained for legal or other permitted reasons.

Security and what to send

We use reasonable organisational and technical measures intended to protect personal information, proportionate to the information and processing involved. No website, email, messaging service or storage system is completely secure. Do not enter Social Security or tax identification numbers, passwords, brokerage or bank logins, one-time codes, identity documents or full financial account details in an initial interest form. If supporting documents are needed, we will arrange a separate document request. Avoid sending unrelated third-party information. Messaging platforms and external websites also apply their own terms and privacy practices.

Cookies and website services

Our website uses Webflow hosting and forms and Google Tag Manager to manage tags. Observed tags include Google Analytics, LinkedIn Insight and X (Twitter) advertising tags. These providers may receive online identifiers, IP addresses, device/browser details, page visits and interaction information for analytics, advertising measurement and related provider purposes; their own privacy notices also apply. Hosting, forms and anti-abuse services may use cookies, similar technologies and technical logs. Where applicable law requires consent for non-essential tracking, that consent is required before those technologies are used; this notice is not consent. Browser and provider controls may let you restrict cookies or advertising uses, although some site features may not work. Contact us to ask about the technologies and choices applicable to your visit.

Your rights and choices

Depending on where you live and the law that applies, you may have rights to access or obtain a copy of your information, correct it, request deletion, restrict or object to processing, receive portable data, withdraw consent, and complain to a relevant data protection authority. Where applicable, you may object to direct marketing at any time. Withdrawal does not affect processing already lawfully carried out. Rights may be subject to exceptions and identity verification; we will request only information reasonably needed to verify and respond to a request. Contact Tom@117partners.com with your request and country of residence so we can identify the applicable process. We will respond within the period required by applicable law. You can raise concerns with us or your local regulator, including the UK ICO or the relevant EEA supervisory authority where applicable.

Updates

We may revise this notice as our services, processing or legal obligations change. The updated date appears above. Where required, we will provide additional notice or seek consent for material changes. Please contact us if you need this notice in another accessible format.