Privacy Policy
Effective date: June 10, 2026. We update this policy as the practice grows and as the law changes. Material changes are flagged at the top of this page on the date they take effect.
Fiduciary Continuum Management Services, LLC ("we," "us," or "our") operates the website fiduciarycms.com. This page explains what information we collect through the website and through professional engagements, how we use and share it, how long we keep it, and the rights you have over it.
What we collect
Information you provide. When you contact us through a form, by phone, or by email, we receive whatever you choose to send — typically your name, contact details, and a description of your situation. Because the people who reach out are often describing sensitive personal, financial, medical, or family circumstances, we treat everything you send as confidential.
Website usage data. When you visit the site we receive limited technical information — your approximate city-level location, device and browser type, the pages you view, the links you click, and time stamps. This is handled in aggregate and is not used to build a profile of you.
Client engagement information. When you become a client through a signed engagement letter, we collect the information needed to perform the service, which for fiduciary work can include financial, medical, and family information. The specifics are described in the engagement letter. Where the engagement letter and this policy differ for client information, the engagement letter controls.
Cookies. The site currently uses only the cookies necessary for it to function and, at most, privacy-respecting aggregate analytics that do not identify you. We do not use advertising or cross-site tracking cookies. If we ever add analytics or tracking that collects personal information or sets non-essential cookies, we will first update this policy, show a cookie-consent banner, and obtain your consent where the law requires it. You can control cookies through your browser settings.
Sensitive information. We do not seek sensitive personal information through the public site. When it is collected in an engagement, it is used only for that purpose and is not used to infer characteristics about you. We do not use your information for automated decision-making that produces legal or similarly significant effects.
How we use the information
We use your information to respond to your inquiries, to perform the services described in a signed engagement letter, to send service-related and administrative messages, to improve the site using aggregate data, and to meet our legal and regulatory obligations. We do not send marketing email, we do not sell or rent personal information, and we do not use it for cross-context behavioral advertising.
How long we keep information
We keep information only as long as we have a reason to, then securely delete or anonymize it. Because different records are governed by different rules, and where more than one applies we follow the longest:
Website analytics: aggregate, non-identifying data kept up to 14 months. Inquiries that do not become engagements: kept up to 2 years from your last contact, then deleted. Client and fiduciary records: retained for at least 10 years, and longer where the law, a tax matter, an ongoing accounting obligation, or health-records rules require it.
How we protect the information
We use commercially reasonable safeguards: encrypted transmission of website data, access controls on internal systems, and limited access to client information. No system is perfectly secure, and we do not promise that one is. If a security incident compromises your unencrypted personal information, we will notify you and any required authority in accordance with California's data-breach-notification law (Cal. Civ. Code §1798.82) and other applicable law, without unreasonable delay.
With whom we share information
Service providers. We use Cloudflare (website hosting and security), Zoho Mail (business email), and SRFax (secure fax). Each receives only what it needs and is bound by its own privacy and security obligations.
Other professionals in your matter. With your consent, we coordinate with the attorneys, accountants, financial advisors, healthcare providers, and others working with you. The scope is set by the engagement letter and your instructions.
Legal obligations. We disclose information when the law requires it — for example, in response to a court order, subpoena, or a regulatory inquiry, including from the Professional Fiduciaries Bureau. Where we are permitted to, we will notify you first. We do not share information for marketing or advertising.
Children's privacy
This site is intended for adults and is not directed to minors. We do not knowingly collect personal information from anyone under 18 through the site. Consistent with the federal Children's Online Privacy Protection Act (COPPA), we do not knowingly collect information from a child under 13, and if we learn we have, we delete it promptly. Consistent with California law, we do not sell or share the personal information of a consumer we know to be under 16. This section concerns information collected through the public site; it does not limit information about a minor that an adult client lawfully provides during an engagement.
Health information
We operate as a professional fiduciary practice, not a health care provider. In some engagements, such as a conservatorship, we may receive protected health information while managing another person's affairs. When we do, we treat it as strictly confidential, use secure encrypted channels for any electronic exchange, and require any third party that handles it on our behalf to sign a Business Associate Agreement. If any part of our services becomes subject to HIPAA, we will comply with the applicable HIPAA rules and provide any required notice.
Your California privacy rights
We honor the following rights for California residents as a matter of good practice: the right to know what information we hold and how it is used and shared; to access a copy of it; to request correction or deletion (subject to records we must keep for legal, tax, or fiduciary reasons); and to limit the use of sensitive information. We do not sell personal information and do not share it for cross-context behavioral advertising, so no "Do Not Sell or Share" action is needed. We will not discriminate against you for exercising these rights. To make a request, contact us below; we will verify your identity first and respond within the time California law allows.
Changes to this policy
We update this policy as the practice grows and as the law changes. The current version is the binding one, and material changes are flagged at the top of the page on the date they take effect.
Contact
For questions about this policy or to exercise a privacy right, email office@fiduciarycms.com, call 760-33-TRUST (760-338-7878), or write to Fiduciary Continuum Management Services, 310 S. Twin Oaks Valley Rd., Suite 107-193, San Marcos, CA 92078.