Privacy Policy

1. OVERVIEW

Lloyd Capital ("Company," "we," "us," or "our"), located at 3887 Okemos Road, Williamston, MI 48854, is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us through various channels including SMS text messaging communications.

This policy complies with applicable federal and state privacy laws, including:

• Gramm-Leach-Bliley Act (GLBA)
• Fair Credit Reporting Act (FCRA)
• Health Insurance Portability and Accountability Act (HIPAA) where applicable
• Telephone Consumer Protection Act (TCPA)
• A2P 10DLC messaging requirements
• Michigan Consumer Protection Act
• Michigan Identity Theft Protection Act

2. INFORMATION WE COLLECT

2.1 Personal Information

We collect the following categories of personal information:

• Contact Information: Full name, residential/business address, email address, telephone number, mobile phone number
• Business Information: Company name, job title, business address, industry type, number of employees
• Financial Information: Bank account information, routing numbers, payroll data, tax identification numbers (EIN, SSN when required)
• Employment Information: Employee names, addresses, Social Security numbers, wage information, tax withholding data, benefits elections
• Health Information: Limited health information for insurance purposes (collected only with explicit consent and handled per HIPAA requirements)
• Government-Issued Identification: Driver's license, state ID numbers when required for verification purposes

2.2 Automatically Collected Information

When you visit our website or use our services, we automatically collect:

• IP address and geographic location
• Device information (type, operating system, browser type and version)
• Website usage data and analytics (pages visited, time spent, referring URLs)
• Cookies and similar tracking technologies
• Call recordings for quality assurance (with prior consent)
• Email open rates and click-through data

2.3 SMS/Text Messaging Information

When you opt in to receive SMS communications, we collect:

• Mobile phone numbers provided for SMS communications
• Carrier information
• Message delivery status and engagement data
• Opt-in timestamps and consent records
• Opt-out preferences and requests
• Message content for customer service and compliance purposes

3. HOW WE USE YOUR INFORMATION

3.1 Primary Business Purposes

We use your information to:

• Provide payroll processing and administration services
• Administer employee benefits and insurance programs
• Process payments and maintain accurate financial records
• Calculate, file, and remit federal, state, and local taxes
• Generate required tax forms (W-2, 1099, 941, etc.)
• Comply with federal and Michigan state tax and regulatory requirements
• Communicate about services, account updates, and important notices
• Provide customer support and respond to inquiries

3.2 Marketing and Communications

With your consent, we use your information to:

• Send promotional materials about our payroll and insurance services
• Deliver SMS notifications, alerts, and marketing messages
• Send email newsletters and educational content
• Conduct surveys and gather feedback
• Provide personalized service recommendations
• Inform you about new products, services, and special offers

3.3 Legal and Compliance Purposes

We use your information to:

• Meet federal and Michigan state legal and regulatory obligations
• Prevent fraud, identity theft, and protect security
• Resolve disputes and enforce our agreements
• Maintain business records as required by law
• Respond to legal process, court orders, and government requests
• Protect the rights, property, and safety of Lloyd Capital, our customers, and others

4. SMS/TEXT MESSAGING TERMS (A2P 10DLC COMPLIANCE)

4.2 Types of SMS Messages You May Receive

Transactional Messages:

• Payroll processing confirmations and notifications
• Payment confirmations and alerts
• Tax deadline reminders and compliance alerts
• Appointment confirmations and reminders
• Account security alerts and two-factor authentication codes
• System maintenance and service interruption notifications
• Important regulatory or policy updates

Promotional/Marketing Messages (with explicit opt-in consent):

• Service announcements and new feature updates
• Educational content about payroll and benefits best practices
• Special offers, promotions, and discounts
• Newsletter highlights and blog post notifications
• Event invitations and webinar announcements

Customer Service Messages:

• Support responses to your inquiries
• Follow-up communications regarding your requests
• Survey requests for feedback

4.3 Message Frequency

• Transactional messages: As needed based on your account activity (no limit)
• Promotional messages: Up to 10 messages per month (you can opt out separately)
• Customer service messages: As needed to respond to your inquiries

4.4 Opt-Out Instructions and Customer Support

To stop receiving ALL text messages:

• Reply STOP, END, QUIT, CANCEL, or UNSUBSCRIBE to any message
• You will receive a one-time confirmation message that you have been unsubscribed
• You will no longer receive SMS messages from Lloyd Capital
• Opting out of SMS does not affect other communication methods (email, phone, mail)

For help or customer support:

• Reply HELP or INFO to any message
• Call us at 1 (312) 728-8538
• Email us at [email protected]

To opt back in: Text START to any of our SMS numbers or contact customer service

4.5 Supported Carriers

Our SMS service is available on all major U.S. mobile carriers including AT&T, T-Mobile, Verizon, Sprint, Boost, Cricket, MetroPCS, U.S. Cellular, Virgin Mobile, and others.

4.6 Your SMS Responsibilities

You are responsible for:

• Providing accurate and current mobile phone numbers
• Notifying us promptly if your phone number changes
• Any message and data rates charged by your mobile carrier
• Ensuring your device is capable of receiving SMS text messages
• Understanding that message delivery times may vary

5. INFORMATION SHARING AND DISCLOSURE

5.1 Service Providers and Business Partners

We may share your information with trusted third-party service providers who assist us in operating our business, including:

• Payroll Processing Vendors: For payroll calculation, direct deposit, and check printing services
• Financial Institutions: Banks and credit unions for payment processing and ACH transactions
• Insurance Carriers: Health, life, and medical insurance providers for benefits administration
• Tax Authorities: IRS, Michigan Department of Treasury, and local tax agencies
• Technology Service Providers: CRM systems, messaging platforms, cloud storage, and IT infrastructure
• Professional Service Providers: Legal counsel, accounting firms, auditors, and compliance consultants
• Background Check Providers: When authorized for employment verification purposes

All third-party service providers are contractually obligated to protect your information and may only use it for the specific purposes for which it was disclosed.

5.2 Legal Requirements and Government Authorities

We may disclose your information when required by law or in response to:

• Federal regulatory authorities (IRS, Department of Labor, SEC)
• Michigan state agencies (Michigan Department of Treasury, Department of Licensing and Regulatory Affairs)
• Court orders, subpoenas, and legal proceedings
• Law enforcement investigations and requests
• Government audits and examinations
• Reporting requirements under federal and Michigan state law

5.3 Business Transfers

If Lloyd Capital is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, your information may be transferred as part of that transaction. You will be notified via email and/or prominent notice on our website of any change in ownership or use of your personal information, and any choices you may have regarding your information.

5.4 With Your Consent

We may share your information with other parties when you have given us explicit permission to do so.

5.5 We Do Not Sell Your Information

Lloyd Capital does not sell, rent, or trade your personal information to third parties for their marketing purposes.

6. DATA SECURITY

6.1 Security Measures

We implement comprehensive physical, technical, and administrative security measures to protect your information, including:

• Encryption: Industry-standard encryption for data in transit (TLS/SSL) and at rest (AES-256)
• Access Controls: Multi-factor authentication, role-based access controls, and principle of least privilege
• Network Security: Firewalls, intrusion detection/prevention systems, and regular security monitoring
• Secure Data Centers: SOC 2 compliant facilities with 24/7 physical security
• Regular Security Assessments: Penetration testing, vulnerability scans, and security audits
• Employee Training: Mandatory security awareness and data protection training for all staff
• Vendor Management: Due diligence and security requirements for all third-party providers
• Incident Response Plan: Documented procedures for detecting, responding to, and recovering from security incidents

6.2 Data Breach Response

In the unlikely event of a security incident that compromises your personal information, we will:

• Investigate the incident promptly and take immediate action to contain the breach
• Notify affected individuals without unreasonable delay as required by Michigan law (MCL 445.72)
• Provide notification to the Michigan Attorney General if required
• Report to applicable federal authorities and regulatory agencies
• Offer appropriate assistance, such as credit monitoring services when applicable
• Implement additional safeguards to prevent future incidents
• Maintain documentation of the incident and response actions

6.3 Your Security Responsibilities

You can help protect your information by:

• Keeping your account credentials confidential
• Using strong, unique passwords
• Enabling multi-factor authentication when available
• Being cautious of phishing attempts and suspicious communications
• Reporting any suspected unauthorized access immediately

7. YOUR RIGHTS AND CHOICES

7.1 Access and Correction Rights

You have the right to:

• Request access to the personal information we hold about you
• Receive a copy of your personal information in a readable format
• Correct inaccurate or incomplete personal information
• Update your contact preferences and account information

7.2 Marketing Communications Preferences

You can control marketing communications by:

• Email: Click the "unsubscribe" link in any promotional email
• SMS: Reply STOP to any text message
• Phone: Request to be placed on our internal do-not-call list
• Mail: Contact us to opt out of direct mail
• Account Settings: Update your communication preferences in your online account

Note: Even if you opt out of marketing communications, we will still send you transactional and service-related messages necessary for your account.

7.3 Cookie and Tracking Preferences

You can manage cookies and tracking technologies through:

• Your browser settings (most browsers allow you to refuse cookies)
• Our cookie consent banner (if applicable)
• Opting out of third-party analytics services
• Using browser privacy tools and extensions

7.4 California Consumer Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information is collected, used, and shared
• Right to delete personal information (with certain exceptions)
• Right to opt out of the sale of personal information (we do not sell information)
• Right to non-discrimination for exercising your privacy rights

8. MICHIGAN-SPECIFIC PRIVACY RIGHTS

9. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

9.1 Retention Periods

• Payroll Records: Minimum 4 years (IRS requirement), typically 7 years for comprehensive records
• Tax Records: 7 years as required by federal and Michigan tax law
• Employment Records: 4 years under Fair Labor Standards Act (FLSA)
• Benefits Records: 6 years under ERISA requirements
• Financial Transaction Records: 7 years for audit and compliance purposes
• Marketing Data: Until you opt out or request deletion (subject to legal requirements)
• SMS Consent Records: 4 years minimum for TCPA compliance

9.2 Secure Deletion

When information is no longer needed and retention requirements have been met, we securely delete or anonymize it using industry-standard methods.

10. CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18 years of age. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at the contact information provided below.

11. THIRD-PARTY LINKS AND SERVICES

Our website and communications may contain links to third-party websites, services, or applications that are not owned or controlled by Lloyd Capital. This Privacy Policy does not apply to those third-party services.

We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit before providing personal information.

11.1 Third-Party Services We May Use

• Payment processors (for secure financial transactions)
• Analytics providers (Google Analytics, etc.)
• CRM and marketing platforms
• Cloud service providers
• Insurance carrier portals

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this policy
• Post the revised policy on our website
• For material changes: Notify you via email to the address associated with your account
• For material changes: Provide prominent notice on our website
• For SMS-related changes: Send notification via text message if you are opted in

Your continued use of our services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you may discontinue using our services.

13. CONTACT INFORMATION

13.1 Response Time

We will respond to privacy-related inquiries within:

• General inquiries: 5 business days
• Access requests: 30 days
• Correction requests: 30 days
• Urgent security matters: 24-48 hours

14. REGULATORY COMPLIANCE

14.1 Federal Laws and Regulations

• Gramm-Leach-Bliley Act (GLBA) - Financial privacy protections for financial services companies
• Fair Credit Reporting Act (FCRA) - Consumer credit information protection and accuracy requirements
• Health Insurance Portability and Accountability Act (HIPAA) - Protected health information safeguards (where applicable)
• Telephone Consumer Protection Act (TCPA) - Restrictions on telemarketing and automated communications
• CAN-SPAM Act - Requirements for commercial email messages
• A2P 10DLC Requirements - Application-to-person messaging compliance and registration
• Fair Labor Standards Act (FLSA) - Record retention requirements for payroll and employment records
• Employee Retirement Income Security Act (ERISA) - Benefits plan record requirements

14.2 Michigan State Laws

• Michigan Identity Theft Protection Act (MCL 445.61 et seq.) - Personal information security and breach notification
• Michigan Consumer Protection Act (MCL 445.901 et seq.) - Unfair, unconscionable, or deceptive trade practices prevention
• Michigan Freedom of Information Act (FOIA) - Public records transparency (where applicable)
• Michigan Data Security Laws - Requirements for protecting personal information of Michigan residents

14.3 Industry Standards and Best Practices

• SOC 2 Type II compliance standards
• Payment Card Industry Data Security Standard (PCI DSS)
• NIST Cybersecurity Framework
• ISO 27001 information security standards

14.4 Professional Licensing and Oversight

Lloyd Capital operates under the regulatory oversight of:

• Michigan Department of Insurance and Financial Services (DIFS)
• Internal Revenue Service (IRS) as an authorized e-file provider
• State of Michigan Department of Treasury
• Other applicable federal and state regulatory agencies

Last Updated: January 1, 2025
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