.jpg)
ASCI Privacy Notice
Effective date: [to be set on publication]
Download or print the ASCI Privacy Notice (PDF, opens in a new tab)
Who "ASCI" Means
In this Privacy Notice, "ASCI," "we," "us," and "our" mean Associated Service Companies International, LLC ("ASCOM") and ASCI Federal Services, LLC, together with all of their current and future subsidiary and affiliated companies.
Assistance For The Disabled
Alternative formats of this Privacy Notice are available upon request to individuals with a disability. Please contact Privacy@asciLLC.com for assistance.
1. About This Privacy Notice
This Privacy Notice explains how ASCI collects, uses, discloses, and protects personal information. “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. This Privacy Notice applies to:
Our website at www.asciLLC.com and any related pages we operate, as they may be updated or modified from time to time (“Website”);
Our self-service digital products (the Procurement Process Auditor and other products we may release), including the checkout, download, and any setup or review calls that come with them;
Our proprietary operational tools, including SmartTracker, SmartStager, SmartBOMS, and other operational or AI-assisted tools we develop; and
Our general business interactions, such as when you contact us, request a proposal, subscribe to a newsletter, or work with us as a customer, supplier, or partner.
It does not change or override the terms of any signed contract between ASCI and a client. Where a contract addresses data handling, that contract controls for the work performed under it. See Section 3.
This Privacy Notice does not cover personal information that we handle in our role as an employer. ASCI does not handle personal information of individuals in their role as consumers, i.e., individuals seeking or purchasing products or services for personal or household use. ASCI only provides products and services to other businesses and therefore does not collect consumer data.
Other Sites: Our Website may contain links to other websites not operated or controlled by us (“Third Party Sites”). The policies and procedures we describe here do not apply to Third Party Sites. The links from our Website do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
2. The Short Version
We collect the personal information we need to sell and deliver our products, to perform our services, to run our Website, and to communicate with you.
We do not sell your personal information.
Most of our self-service products run locally on your own computer, so the business data you put into them stays on your device and does not come to us.
When we perform services for a client under a commercial or federal contract, we handle data under that client's or agency's rules and the contract, not under this Privacy Notice.
We use reputable third-party providers (for example, a payment processor and an email platform) that have their own privacy commitments.
You have choices and, depending on where you live, legal rights over your personal information. See Section 10.
3. Our Different Roles (Please Read This First)
ASCI handles personal information in three different contexts, and our responsibilities differ in each.
3.1. Personal Information We Control (Website, Marketing, and Product Sales)
When you visit our Website, contact us, subscribe to communications, or buy one of our self-service products, ASCI decides how and why your personal information is used. For that information, ASCI acts as the controller, and this Privacy Notice applies in full.
3.2. Personal Information You Keep on Your Own Device (Self-Service Products)
Most ASCI self-service products run locally inside an AI tool’s environment on your own computer. The business information and files you load into a product stay on your device. ASCI does not receive a copy of that material through the product itself. You remain responsible for the information you input into or generate with the product, including any personal information about your own employees, customers, or suppliers, and for your own legal obligations to those people. If you separately send us material in connection with a setup or review call, Section 3.1 applies to what you send.
3.3. Personal Information We Handle for Clients Under Commercial and Federal Contracts
When ASCI performs warehousing, logistics, supply chain, staffing, or related services for a client, and when ASCI operates its proprietary tools (such as SmartTracker, SmartStager, or SmartBOMS) in the course of that work, ASCI generally handles data on behalf of that client and under the terms of the governing contract.
In that context:
The client's privacy policies, data-handling rules, and the contract govern how the data is used, not this Privacy Notice.
For work performed under federal government contracts, ASCI also follows the applicable federal regulations, agency requirements, and contract clauses that apply to that engagement, which may include requirements for handling controlled or sensitive government information.
ASCI acts as a service provider or processor for that data and uses it only to perform the services and as the contract permits.
If you are an individual whose personal information is handled through a client's or government agency's use of an ASCI tool or service, and you have a privacy request, please contact that client or agency, since they control the data. We will support them as the contract requires.
4. Personal Information We Collect
The categories below describe personal information ASCI collects in the contexts where ASCI is the controller (Section 3.1). We do not collect more than we need.
Contact and identity information: name, business name, job title, email address, phone number, and mailing address.
Order and transaction information: the product and tier you buy, order date, amounts, split-payment election, upgrade-credit status, and records of calls scheduled or delivered. We do not collect or store full payment-card numbers; those are handled by our Payment Processor (Section 6).
Communications: messages you send us by email, web form, or during a call, our responses, and metadata about those communications, e.g., time sent. On occasion, we may record calls or otherwise capture your communications with us in real time, supported by our service providers.
Marketing preferences: your subscription and unsubscribe choices.
Website usage and device information: IP address, browser and device type, clicks and views within emails we sent to you, Website pages viewed, and similar analytics data, some of which is collected through cookies and similar technologies (Section 5).
Personal information you choose to send us in connection with a setup or review call or a support request, which may include business documents.
Sources. We collect this personal information directly from you, automatically through our Website or other technologies, and from the service providers who help us run our checkout, communications, and analytics.
5. Cookies and Analytics
Our Website uses cookies and similar technologies to make the site work, remember your preferences, understand how the site is used, and support our marketing. You can control cookies through your browser settings. We also include small graphic images or other web programming code, called web beacons (also known as "pixel tags", “web bugs” or "clear GIFs"), on the Website. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of web users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on web pages and are about the size of the period at the end of this sentence. Rejecting cookies using browser settings may not stop web beacons from tracking you.
Depending on the jurisdiction, we may provide a pop-up notice and interactive settings options for you to manage your preferences for tracking technologies on the Website.
6. How We Disclose Personal Information
We disclose personal information to the following categories of recipients.
Service providers and subprocessors. We use trusted providers to operate our business, for example, a payment processor, a website and hosting provider, an email and marketing platform, a calendar and scheduling tool, and the AI environment provider (Anthropic) that powers our Cowork-based products.
Professional advisors. Our attorneys, accountants, and similar advisors, as needed.
Affiliated companies. Other companies within the ASCI family, for example, to provide you with our products and services.
Legal and safety. When required by law or legal process, or to protect the rights, property, or safety of ASCI, our customers, or others.
Business transfers. In connection with a merger, acquisition, sale of all or part of our business, or other corporate change.
Under client and government contracts. As described in Section 3.3, where the contract and the client's or agency's rules govern.
Sales and “Sharing”:
As is common practice among businesses operating online, we may allow third parties to receive information about you via cookies and other tracking technologies. In the last 12 months, we have disclosed Website Usage and Device Information, to our marketing partners (marketing and analytics partners, advertisers, and social media platforms). We disclose this personal information in order to deliver marketing messages, tailor advertising on the Website and in other interactions that you have with us while online, and to help us understand the effectiveness of those marketing and advertising efforts. We have not, and have no actual knowledge that we have, sold or “shared” the personal information of children under 16 years of age, in the last 12 months.
7. How We Use Personal Information
We use personal information to:
Provide our products and services, including:
To deliver our products, operate our tools for clients under their contracts, and perform our services.
To process payments and manage upgrade credits and reminders.
To communicate with you, including order, service, and administrative messages.
To improve our products and services, develop new products and services, and conduct research on further improvements.
Provide customer support and marketing, including:
To respond to any requests, queries, suggestions, feedback, or comments you may have.
To send you marketing information about our products and services, including notifying you of marketing events and promotions, in accordance with applicable law.
To inform you of any changes to the services, your account (if applicable), this Privacy Notice, or any other policies or terms in relation thereto.
To maintain the services and the Website, including to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
Conduct monitoring, maintain security, and ensure compliance, including:
To administer and protect our business and our Website (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse).
To store, host, or backup (whether for disaster recovery or otherwise) our services or any data contained therein.
To protect the rights, property, or safety of ASCI, you, or others.
In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of ASCI or any of its subsidiaries or affiliates.
To report suspected criminal conduct to law enforcement and cooperate in investigations.
To support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel.
To ensure compliance with applicable laws and regulatory obligations.
Note on email addresses:
Customer’s email address provided at checkout is used for: (a) order delivery; (b) scheduling any included services; (c) optional program invitations (such as case-study programs) where the product Addendum describes them; (d) any incentive reminders defined in the product Addendum (such as upgrade-credit reminders); and (e) ASCI marketing communications, sent in compliance with applicable email-marketing laws, from which Customer may unsubscribe at any time without affecting Customer’s right to use the Product.
Aggregated and deidentified information:
We may aggregate and/or deidentify information, use it internally, and disclose it to third parties. Neither Aggregated Information nor Deidentified Information (defined below) is personal information.
“Aggregated Information” refers to information about a group of individuals from which the individually identifiable information has been removed. An example of Aggregated Information would be the statistic that 20 people used our Website’s contact form on a given day.
“Deidentified Information” means information subjected to reasonable measures to ensure that the deidentified information cannot be associated with the individual. An example of Deidentified Information would be the data point that an unidentified visitor first entered our Website through our main web page. We maintain Deidentified Information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly.
8. Data Retention
We keep personal information for as long as we need it for the purposes described in this Privacy Notice, including to meet legal, tax, accounting, and contractual requirements, and then we delete or deidentify it. Data handled under a client or government contract is retained and returned or destroyed as that contract requires.
9. How We Protect Personal Information
We use reasonable administrative, technical, and physical safeguards to protect personal information. Our self-service products are designed so that your business data stays on your own device, which reduces exposure.
Please note that some of our products work in software environments that we cannot control. For example, our Cowork-based products depend on third-party AI tools; we are not responsible for the third-party’s own data-handling practices, and we encourage you to review your chosen third-party’s published policies.
Despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal information.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to close your browser after you have completed your visit to the Website.
10. California Privacy Rights
Subject to applicable law, California residents have the following rights:
Right to Know: The right to submit a verifiable request for specific pieces of their personal information and for information about ASCI’s collection, use, and disclosure of their personal information. In addition, California residents have a right to know the categories of their personal information that ASCI sold or shared for cross-context behavioral advertising and the parties to which those categories were sold or shared.
Right to Delete: The right to submit a verifiable request for the deletion of personal information provided to ASCI.
Right to Correct: The right to submit a verifiable request for the correction of inaccurate personal information maintained by ASCI, taking into account the nature of the personal information and the purposes of processing the personal information.
Right to Opt out of Sale and Sharing: California residents have the right to opt out of the sale of personal information and the disclosure of their personal information for cross-context behavioral advertising (sharing).
Note on Sensitive Personal Information: ASCI does not anticipate collecting sensitive personal information, e.g., race, personal financial account numbers, etc. and we ask that you not provide us with such information. However, to the extent we did collect sensitive personal information, we would not infer characteristics about an individual from such information. ASCI would only use sensitive personal information as necessary to perform the services or provide the goods the average person would reasonably expect when requesting those goods or services, to ensure security and integrity, short term transient use, to maintain the quality of our products and services, or for other purposes permitted by the California Consumer Privacy Act and implementing regulations (“CCPA”) without the right to opt out.
How to exercise California privacy rights:
ASCI will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. California residents can exercise their rights to know, delete, and correct by using the contact information in Section 14.
To opt out of the “sale” or “sharing” of their personal information through cookies and other tracking technologies on the Website, California residents may implement a browser setting or extension to communicate their selling and sharing preferences automatically to the websites they visit. In accordance with applicable law, we honor the right to opt out of the sale and sharing of personal information as signaled by a universal opt out signal or Global Privacy Control (“GPC”). To enable GPC, California residents can visit the Global Privacy Control page at https://globalprivacycontrol.org. If a California resident downloads a supported browser or extension and exercises their applicable privacy rights with GPC, we will turn off certain third-party cookies on our Website after our Website detects a GPC signal. However, if the user visits our Website from a different device or from a different browser on the same device, they will need to enable the GPC or other universal opt-out signal for that browser and/or device.
How we will verify your request:
To verify your identity for requests to know, delete, and correct, we match personal information that you provide us against personal information we maintain in our files. The more risk entailed by the request (e.g., a request for specific pieces of personal information), the more items of personal information we may request to verify your identity. If we cannot verify your identity to a sufficient level of certainty to respond securely to your request, we will let you know promptly and explain why we cannot verify your identity.
Authorized agents:
You may designate an authorized agent to exercise your right to know, to correct, or to delete. If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.
In the alternative, you can provide a power of attorney compliant with the California Probate Code.
ASCI’s non-discrimination policy:
ASCI will not unlawfully discriminate against you for exercising your privacy rights.
Please note that, because much of the data we handle belongs to our clients under contract (Section 3.3), the way a right applies may depend on the context in which we hold your personal information. [Confirm with counsel: the specific state-law rights to enumerate, the response timelines, the verification and appeal mechanics, and any required "Do Not Sell or Share" or "Limit the Use of My Sensitive Personal Information" links, based on the states ASCI reaches.]
11. Children's Privacy
ASCI's Website, products, and services are intended for businesses and adults. They are not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, you are not authorized to use ASCI's Website, products, or services.
12. Where We Operate
ASCI offers and markets its products and services in the United States. We do not target or knowingly solicit individuals or organizations outside the United States. If you access our Website or products from outside the United States, you do so on your own initiative and are responsible for compliance with the laws of your own location.
13. Changes to This Privacy Notice
We may update this Privacy Notice from time to time. When we do, we will change the "Effective Date" above and post the updated Privacy Notice on our Website. Material changes will be identified as required by law.
14. Contact Us
For privacy questions or to exercise a privacy right, contact:
ASCI (Associated Service Companies International, LLC and ASCI Federal Services, LLC) 721 Depot Drive, Anchorage, AK 99501
Email: Privacy@asciLLC.com
Phone: 907-345-2724
Website: www.asciLLC.com
