ACE Account Setup Service — 117 PartnersLLC
Effective Date: April 2, 2026
These Terms and Conditions ("Terms") govern your useof the website and services operated by 117 Partners LLC (also operating as 117Castell Advisory Group LLC) ("117 Partners," "we,""us," or "our") in connection with our ACE Account SetupService. By submitting your information through this website, you acknowledgethat you have read, understood, and agree to be bound by these Terms in theirentirety. If you do not agree, do not submit your information or use thisservice.
117 Partners offers to assist eligible US importers withsetting up an account on the Automated Commercial Environment ("ACE")portal operated by US Customs and Border Protection ("CBP"), inconnection with potential refunds of IEEPA tariff duties. This assistance isprovided free of charge.
YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT:
• Submission of your information does not create anattorney-client, customs broker, fiduciary, or any other professional orregulated engagement between you and 117 Partners.
• 117 Partners is not a licensed customs broker,attorney, financial advisor, or trade compliance professional. Nothing providedconstitutes legal, tax, financial, or customs advice.
• This service covers ACE portal account setup only. Wedo not set up, enroll, or manage your ACH electronic refund banking detailswith CBP. ACH enrollment is your responsibility.
• This service is provided as a courtesy. We make norepresentation that we are obligated to complete any ACE setup on your behalf.
• You remain solely responsible for verifying theaccuracy of all information submitted, confirming your eligibility for anyrefund, and complying with all CBP regulations and deadlines.
THE SERVICE IS PROVIDED ON AN "AS IS" AND "ASAVAILABLE" BASIS. TO THE FULLEST EXTENT PERMITTED BY LAW, 117 PARTNERSEXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:
• Any warranty that the service will result in asuccessful ACE account setup;
• Any warranty that you will receive any IEEPA tariffrefund, in whole or in part;
• Any warranty regarding the timeliness, completeness, oraccuracy of information on this website regarding the IEEPA refund process, CBPprocedures, or applicable deadlines;
• Any warranty that CBP's CAPE system or anyadministrative process will proceed as currently anticipated.
IN NO EVENT SHALL 117 PARTNERS, ITS MEMBERS, MANAGERS,EMPLOYEES, AGENTS, PARTNERS, OR AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT,INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF ORRELATED TO YOUR USE OF THIS SERVICE, INCLUDING BUT NOT LIMITED TO: MISSEDREFUND DEADLINES, FAILED CBP SUBMISSIONS, LOSS OF REFUND ELIGIBILITY, ORRELIANCE ON ANY INFORMATION PROVIDED ON THIS WEBSITE. THIS LIMITATION APPLIESREGARDLESS OF THE THEORY OF LIABILITY AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITYOF SUCH DAMAGES.
YOUR SOLE REMEDY FOR DISSATISFACTION WITH THIS SERVICE IS TOCEASE USE OF IT.
We may use your name, business name, Employer IdentificationNumber (EIN), importer of record details, contact information, and othersubmitted data to apply to CBP on your behalf for an ACE portal account, if youhave requested such assistance.
You acknowledge and agree that 117 Partners may share yoursubmitted information with third parties and business partners, including butnot limited to:
• Customs brokers, trade compliance professionals, ortechnology service providers engaged to assist with ACE account setup;
• Business partners, affiliates, nominees, and assigns of117 Partners in connection with claim evaluation, claim acquisition, or relatedcommercial activities;
• Third parties to whom 117 Partners may refer yourmatter or with whom 117 Partners may co-operate in connection with IEEPArefund-related services;
• CBP, Treasury, or other government agencies as requiredto provide the service.
By submitting your information, you expressly consent to thesedisclosures. We do not sell your personal information to unaffiliated thirdparties for unrelated marketing purposes.
117 Partners may contact you by email, phone, or other meansto: (a) follow up on the status of your ACE setup; (b) provide updates on theIEEPA refund process; (c) discuss additional services related to your IEEPArefund claim; and (d) inquire whether you have an interest in selling,assigning, or otherwise transferring your IEEPA refund claim or receivable to athird party, including to 117 Partners or its affiliates, nominees, or assigns.You are under no obligation to sell or assign your claim. Any such transactionwould be entirely voluntary and subject to a separate written agreement.
We may retain your submitted information indefinitely forinternal business purposes, including evaluating potential claim acquisitionopportunities, unless you submit a written deletion request to us.
You represent and warrant that all information you submit istrue, accurate, current, and complete to the best of your knowledge. Youacknowledge that submitting false or inaccurate information to CBP through theACE system may constitute a violation of federal law, including 18 U.S.C. §1001. 117 Partners assumes no liability for any consequence arising frominaccurate or incomplete information you provide.
The IEEPA tariff refund process is subject to ongoinglitigation, administrative proceedings, and regulatory development. Nothing onthis website constitutes a guarantee that a refund will be issued, that CBP'sCAPE system will launch on any particular timeline, or that your entries willbe eligible for refund. We strongly recommend consulting a licensed customsbroker or trade attorney to independently protect your refund rights.
You agree to indemnify, defend, and hold harmless 117 PartnersLLC (also operating as 117 Castell Advisory Group LLC), its members, managers,employees, agents, partners, and affiliates from and against any and allclaims, liabilities, damages, losses, costs, and expenses (including reasonableattorneys' fees) arising out of or related to: (a) your use of this service;(b) any information you submit; (c) your violation of these Terms; or (d) anyclaim by a third party arising from our processing of your information asdescribed herein.
These Terms are governed by the laws of the State of Delaware,without regard to conflict of law provisions. Any dispute shall be resolvedexclusively in state or federal courts in Delaware. TO THE EXTENT PERMITTED BYLAW, YOU WAIVE ANY RIGHT TO A JURY TRIAL IN CONNECTION WITH ANY DISPUTE ARISINGUNDER THESE TERMS.
117 Partners reserves the right to modify these Terms at anytime. We will update the Effective Date when changes are made. Continued use ofthis website after modification constitutes acceptance of the revised Terms.
These Terms constitute the entire agreement between you and117 Partners with respect to this service. If any provision is foundunenforceable, the remaining provisions remain in full force and effect.
Questions regarding these Terms or requests to delete yourinformation:
117 Castell AdvisoryGroup LLC
Email: support@117partners.com
Website: ACEAccounts.com
ACE Account Setup Service — 117 PartnersLLC
Effective Date: April 2, 2026
117 Partners LLC (also operating as 117 Castell Advisory GroupLLC) ("117 Partners," "we," "us," or"our") is committed to being transparent about how we collect, use,share, and retain information you provide through our ACE Account Setup Servicewebsite. This Privacy Policy explains our practices in plain terms. Bysubmitting information through our website, you consent to the practicesdescribed in this Policy.
We collect information you voluntarily provide when you submitour opt-in form, including:
• Full name and business name
• Email address and phone number
• Employer Identification Number (EIN) or other importerof record identifiers
• Estimated annual import value or import volume
• Any other information you choose to include in yoursubmission
We may also collect standard technical data automatically,including IP address, browser type, and pages visited, through cookies andsimilar technologies. See Section 7 for more detail.
We use the information you provide for the following purposes:
• To assist with setting up your ACE portal account withUS Customs and Border Protection ("CBP"), as requested;
• To communicate with you about the status of your ACEaccount setup and the IEEPA refund process generally;
• To evaluate whether your IEEPA tariff refund claim maybe of interest for acquisition by 117 Partners or its affiliates, nominees, orassigns;
• To contact you regarding the potential purchase,assignment, or transfer of your IEEPA refund claim;
• To refer your matter to, or co-operate with, businesspartners and third parties in connection with IEEPA refund-related services;
• To comply with applicable legal obligations;
• For internal business analysis and record-keeping.
We may share your information with the following categories ofrecipients:
We may share your information with customs brokers, tradecompliance professionals, technology vendors, or other service providers whoassist us in delivering the ACE setup service. These parties are engaged tosupport our operations and are expected to handle your information responsibly.
We may share your information with business partners,co-investors, affiliates, nominees, and assigns of 117 Partners in connectionwith the evaluation or acquisition of IEEPA refund claims, claim brokerage, orrelated commercial activities. These parties may independently contact youregarding your claim.
If we determine that a third party may be better placed toassist you, or if we co-operate with a third party in connection with yourclaim, we may share your information with that party. We will endeavor to shareonly the information necessary for that purpose.
We will share your information with CBP, the US Department ofthe Treasury, or other government agencies as necessary to submit your ACEaccount application or comply with legal requirements.
We may disclose your information if required to do so by law,court order, or government authority, or if we believe disclosure is necessaryto protect our legal rights or prevent harm.
We do not sell your personal information to unaffiliated thirdparties for purposes unrelated to the IEEPA refund or claim acquisitionactivities described in this Policy.
We retain your submitted information for as long as it isrelevant to our business purposes, including ongoing evaluation of IEEPA refundclaim acquisition opportunities. Given the multi-year nature of potentialrefund proceedings and litigation, this may mean we retain your information forseveral years. You may request deletion of your personal information at anytime by contacting us in writing at the address in Section 10. We will honordeletion requests to the extent not prevented by legal obligation or legitimatebusiness need.
Depending on your jurisdiction, you may have certain rightswith respect to your personal information, including the right to:
• Access the personal information we hold about you;
• Request correction of inaccurate information;
• Request deletion of your information, subject to ourretention obligations;
• Opt out of future communications from us.
To exercise any of these rights, please contact us at thedetails in Section 10. We will respond to requests within a reasonabletimeframe.
Our website may use cookies and similar tracking technologiesto improve user experience and analyze site traffic. You may configure yourbrowser to refuse cookies, though some features of the website may not functionproperly as a result. We do not use cookies to build advertising profiles orsell data to advertising networks.
We take reasonable technical and organizational measures toprotect the information you submit from unauthorized access, disclosure, ormisuse. However, no internet transmission or electronic storage system iscompletely secure. We cannot guarantee the absolute security of yourinformation and are not liable for unauthorized access beyond our reasonablecontrol.
We may update this Privacy Policy from time to time. We willupdate the Effective Date at the top of this page when changes are made. Weencourage you to review this Policy periodically. Your continued use of ourwebsite following any update constitutes acceptance of the revised Policy.
If you have questions about this Privacy Policy, wish toexercise your data rights, or want to opt out of communications, pleasecontact:
117 Castell AdvisoryGroup LLC
Email: support@117partners.com
Website: ACEAccounts.com
© 2026 117 Castell Advisory Group LLC. All rights reserved.