Effective Date: August 2025

Last Updated: September 2025

Surplus Funds Secrets (“we,” “our,” or “us”), operated as the mentorship and educational division of Full Circle Asset Recovery, values your trust and is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website surplusfundssecrets.com, engage with our courses, mentorship programs, or download our resources.

By using our site and services, you agree to the terms of this Privacy Policy.

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1. Information We Collect

We may collect the following types of information:

• Personal Information: Name, email address, phone number, billing details, and other identifiers you voluntarily provide (e.g., when signing up for courses, mentorship, or newsletters).

• Non-Personal Information: Browser type, IP address, device data, and usage patterns collected through cookies and analytics tools.

• User-Generated Content: Comments, messages, or other submissions made via contact forms, forums, or community platforms.

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2. How We Use Your Information

We use your information for purposes such as:

• Delivering educational materials, courses, mentorship, and resources

• Sending updates, newsletters, and marketing communications (you may opt out anytime)

• Improving our website, programs, and user experience

• Processing payments securely through third-party providers

• Complying with legal requirements and protecting against fraudulent activity

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3. Sharing of Information

We respect your privacy. We do not sell, rent, or trade your personal information. However, we may share data in limited situations:

• With trusted service providers (payment processors, email platforms, IT support)

• With legal authorities if required by law or court order

• With affiliates or partners such as Full Circle Asset Recovery, strictly for program delivery and client support

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4. Cookies & Tracking Technologies

Our site may use cookies, pixels, and analytics tools (such as Google Analytics) to:

• Track visitor behavior and improve content

• Personalize user experience

• Deliver relevant advertisements

You can disable cookies in your browser settings, but some features may not function properly.

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5. Data Retention & Security

We retain your information only as long as necessary to fulfill the purposes outlined here or as required by law. We implement reasonable security measures to safeguard your data, but no system is 100% secure. Use of our site is at your own risk.

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6. Your Rights & Choices

Depending on your location, you may have rights under data protection laws, including the right to:

• Access, correct, or delete your personal information

• Opt out of marketing emails (unsubscribe link in every email)

• Request a copy of your data

To exercise these rights, contact us at info@surplusfundssecrets.com.

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7. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for their privacy practices and encourage you to review their policies.

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8. Children’s Privacy

Our services are not directed to children under 18, and we do not knowingly collect personal data from minors. If we become aware of such data, we will delete it promptly.

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9. Updates to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date.

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10. Contact Us

If you have questions about this Privacy Policy or how your information is handled, please get in touch with us:

• Email: info@surplusfundssecrets.com
• Phone: +1 307 323 4303
• Business Name: Surplus Funds Secrets (A Division of Full Circle Asset Recovery)
• Full Circle Asset Recovery LLC
  721 Belmont Street, Brockton, MA 02301