Athena Group LLC d.b.a Athena Advocacy ("Athena," "we," "us," or "our") provides
professional fiduciary services, including guardianship and conservatorship services, power
of attorney, trust and estate administration, and VA fiduciary services. Our fiduciary
engagements are concentrated in Vermont, New Hampshire, Massachusetts, and New York,
and we also serve clients in other states through our Reservation of Services program and
other arrangements.

This Policy applies wherever you are located.

This Policy applies to: information we collect through our website at
www.athenaadvocacy.com (the "Site"), through online forms, through email and telephone inquiries, and in the course of evaluating prospective clients and job applicants.

This Policy does NOT govern: the confidential records of individuals for whom Athena
serves as guardian, conservator, agent under a power of attorney, trustee, personal
representative, VA fiduciary, or in any other fiduciary capacity. Those records are governed
by our fiduciary duties, applicable court orders, governing instruments, our written
engagement agreements, and state and federal law — including, where applicable, health
information privacy law. Where this Policy and those obligations differ, those obligations
control. Nothing in this Policy expands, limits, or modifies any fiduciary duty we owe.

2.1 Information You Provide Directly
• Contact and inquiry information: name, email address, telephone number, mailing
address, and the substance of your message when you use a contact form, request a
consultation, or email or call us.
• Prospective client information: information you or a referring party provide during
intake, which may include the name and circumstances of the person who may need
services, family relationships, county and court of jurisdiction, the general nature of
financial or care needs, and the identity of other involved professionals.
• Employment application information: resume, work history, references,
responses to screening questions and assessments, and other information submitted
through our application forms.
• Payment and billing information: if you make a payment through the Site or
through a payment link we provide, billing name, address, and payment details are
collected and processed by our third-party payment processor.
• Subscription enrollment information: if you enroll in a recurring or subscription-
based program, the information necessary to establish and administer that enrollment.

2.2 Information Collected Automatically
When you visit the Site, we and our service providers may automatically collect:

• IP address and approximate general location derived from it
• Browser type and version, operating system, and device type
• Pages viewed, time spent, links clicked, and referring website
• Date and time of access

This is collected through cookies, pixels, and server logs. See Section 6.

2.3 Information From Third Parties
We may receive information about you or about a prospective client from: attorneys, courts
and court staff, hospital and facility discharge planners, physicians and clinicians, adult
protective services, the U.S. Department of Veterans Affairs, financial institutions, family
members and other interested parties, and professional referral sources. We may also receive
information from public records.

2.4 Sensitive and Health Information
Because of the nature of our work, information submitted to us — particularly during intake
— may include health, disability, cognitive-status, or financial information about you or
another person. Please do not include detailed health or financial information in a
website form or unencrypted email. Provide only enough information for us to
determine whether we can help and how to contact you. We will arrange a secure method of
communication before discussing details.

If you submit information about another person (for example, a parent or family member),
you represent that you have the authority or legal right to do so.

We use information to:

• Respond to inquiries and communicate with you
• Evaluate whether a prospective engagement is appropriate and whether we can accept
it, including screening for conflicts of interest
• Prepare and deliver engagement agreements and proposals
• Provide, administer, bill for, and document our services
• Administer subscription and reservation-of-services programs, including renewals and
payment processing
• Comply with court orders, reporting and accounting requirements, statutes, regulations,
and lawful requests
• Maintain the records we are required to keep as a fiduciary and as a professional
services firm
• Evaluate candidates for employment
• Operate, secure, and improve the Site
• Send administrative or informational communications about our services
We do not sell personal information. We do not share personal information for
cross-context behavioral advertising or targeted advertising.

We disclose personal information only as follows:

• Service providers. We use third-party vendors to operate our business, including
customer relationship management, time and billing, accounting, online form intake,
email and file storage, website hosting, and payment processing. These vendors are
permitted to use the information only to provide services to us.
• Courts, agencies, and required reporting. As a court-appointed fiduciary or
agency-appointed fiduciary, we are required to file accountings, inventories, status
reports, and other filings, and to respond to court orders and lawful requests. These
filings may be part of a court record and may be accessible to interested parties or, in
some cases, to the public.
• Care and financial coordination. For clients we serve, we disclose information as
necessary and appropriate to carry out our duties — for example, to physicians,
facilities, insurers, benefit programs, banks, and tax preparers — consistent with our
authority and the client's best interests.
• Professional advisors. To our own attorneys, accountants, insurers, and auditors.
• Legal compliance and safety. Where we reasonably believe disclosure is required by
law, necessary to report suspected abuse, neglect, or exploitation, or necessary to
prevent serious harm.
• Business transfer. In connection with a merger, acquisition, reorganization, or sale of
assets, subject to any court approval required for client matters.
• With your direction or consent.

We use administrative, technical, and physical safeguards designed to protect personal
information. These include restricting access to information to staff who need it for their
work, authentication requirements on our business systems, encryption of information in
transit, selecting reputable service providers, and requiring confidentiality of our staff and
contractors. We review these practices often and update them as our systems and applicable
requirements change.

No method of transmission or storage is completely secure. If we become aware of a breach of
security affecting your personal information, we will notify you and any applicable regulator
as required by law.

The Site uses cookies and similar technologies that are strictly necessary for the Site to
function, and may use analytics cookies to understand how visitors use the Site. We use
Google Analytics for this purpose.

You can control cookies through your browser settings. Blocking all cookies may affect Site
functionality.

Global Privacy Control and Do Not Track. We honor the Global Privacy Control (GPC)
signal where our systems can detect it. Because we do not sell personal information or use it
for targeted advertising, there is no advertising activity for these signals to disable.

We retain information for as long as necessary to fulfill the purposes described in this Policy
and to satisfy our legal, professional, and record-retention obligations — which, for fiduciary
engagements, can extend for many years after an engagement ends and is often governed by
court rules, statutes of limitation, and tax and accounting requirements.

Inquiry information from prospective clients who do not engage us is retained for a
reasonable period for conflict-checking and business-record purposes and then deleted or
archived. Employment application materials are retained for one year consistent with
applicable recordkeeping requirements.

Everyone:
• You may ask us what personal information we hold about you, ask us to correct
inaccurate information, or ask us to delete information.
• You may unsubscribe from non-essential emails using the unsubscribe link or by
contacting us. We will still send communications necessary to administer an active
engagement.
• You may decline to provide information, though this may prevent us from evaluating or
providing services.

Important limitation. Our ability to honor deletion and certain other requests is
constrained by law. We cannot delete records we are required to maintain as a fiduciary,
records subject to a court order or pending proceeding, records required for tax or accounting purposes, or records necessary to defend a legal claim. Where we cannot comply with a request, we will tell you why.

Requests about a third party. If you are asking about information concerning someone
else, we generally cannot confirm or provide it without appropriate legal authority (such as a
court order, a valid power of attorney, consent from a guardian or power of attorney, or the
individual's written authorization).

Rights under your state's law. Some states give residents additional statutory rights
regarding personal information — for example, rights to access, correct, delete, or obtain a
copy of it, and to appeal a decision on such a request. Where a state law grants you rights that go beyond what this Policy describes, we will honor those rights as that law requires. To
exercise any right, or to appeal a decision on a request, contact us using Section 12. We will
respond within the time required by applicable law, and in any event within 45 days.

Verification. To protect against improper disclosure, we will take reasonable steps to verify
your identity before responding to a request.

The Site is intended for adults and we do not direct it to children. We do not knowingly
collect personal information from anyone under 18 through the Site. If we learn that we have
done so, we will delete it. If you believe a minor has submitted information through the Site,
contact us using Section 12.

Separately, in the course of our services we may hold information about minors — for
example, a minor beneficiary of a trust or estate. That information is handled under the
obligations described in Section 1, not under this section.

The Site may link to third-party websites, including court websites, benefit programs, and
professional organizations. We do not control those sites and are not responsible for their
privacy practices. Review their policies before providing information.

We may update this Policy. We will change the "Last Updated" date and, if the changes are material, provide more prominent notice. Continued use of the Site after the effective date of a change constitutes acceptance of the updated Policy.

Athena Advocacy
160 Palmer Court, A3, White River Junction, Vermont 05001
802-765-2004
hello@athenaadvocacy.com

To submit a privacy request, please write "Privacy Request" in your subject line.