Effective Date of Current Policy: November 1, 2011
CONSENT TO PROCESS INFORMATION
By using the Website and submitting information to it, you hereby consent to allow RBF to process information in accordance with this Policy. If you do not wish RBF to use your information in accordance with this policy, please do not submit such information to RBF.
COLLECTION OF INFORMATION
The Website collects no personal information about you, typically defined as personally identifying information (“PII”), such as your name, home address, business address, telephone number, e-mail address and profession, unless you voluntary submit it. You may be requested to provide personal information when signing up for a newsletter, the Client Login, an update or other communication from the Website. You may submit information by clicking on various links, such as “Contact Us.”
The Website may collect non-personal information about your activity at the Website. The Website may automatically recognize and store information about the type of browser you are using; your Internet Protocol (“IP”) address; the time, date, and length of your visit; and the referring site. This information, if collected, is collected via computer code sent to your computer (commonly referred to as “cookies”). The cookies may not expire, unless you manually delete them or set your browser to reject them. If you do not accept the cookies, however, you may have difficulty navigating the Website. Furthermore, the Website may utilize Web beacons, embedded Web links, and other commonly used information-gathering tools.
-Information Provided for Services
Additionally, we collect nonpublic personal information about you that is provided by you or obtained by us with your authorization to prepare your personal income tax returns and provide you with personal financial planning services.
We may collect non-public information from the following sources:
• Client interviews;
• Tax return organizers;
• Financial planning organizers; and,
• Financial history questionnaires.
We receive information from you to properly prepare your income tax return or provide financial planning services. This information is collected from you in written form, by phone, online, by mail and in personal interviews and consultations conducted by us, as well as by information we collect from others with your authorization.
Further, we collect and maintain information about your transactions with RBF, which includes information necessary for billing and payment for our income tax preparation and financial planning services, as well as all correspondence between you and RBF. Transaction information would also include your payment history with us, billing records and any collection effort engaged in by us for payment of services rendered to you.
Our computer systems are currently based in the United States and the content of our Website is directed to U.S. residents. Your personal data will be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world, such as in Canada and the European Union. BY VISITING THE RBF WEBSITE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY PERSONAL AND NON-PERSONAL INFORMATION COLLECTED OR OBTAINED BY RBF THROUGH VOLUNTARY SUBMISSIONS OR THROUGH THE CLIENT LOGIN, AND THAT UNITED STATES LAW GOVERNS ANY SUCH COLLECTION, PROCESSING AND USE.
RBF uses non-personal information to manage the Website. RBF may analyze the data about visits to the Website to make it more accessible and interesting for visitors. Further, RBF may share this data with third parties, usually to provide services for RBF associated with the maintenance of the Website.
Additionally, RBF may disclose any such information to the extent that it is required by law or to such an extent as it reasonable believes is necessary to protect its legal interests. The information collected from you may be transferred to a third party in the event of a sale, acquisition, merger or bankruptcy involving RBF.
RBF also reserves the right to utilize such information in other ways that it deems appropriate. If you would like to limit the use of your information in this regard, please follow the instructions in the Update and Opt-Out provision below.
If you submit personal information to the Website, the information will be used for the purpose you requested. That information may be stored and maintained for as long as is reasonably necessary to effectuate the service your request or for which the information was provided, and for a reasonable time thereafter. If you select to receive updates or other information, RBF may use your Personal Information to provide you with the information you select to receive. In addition, RBF may share this information with third parties to fulfill your request. Additionally, RBF may disclose any such information to the extent that it is required by law or to such an extent as it reasonable believes is necessary to protect its legal interests. The information collected from you may be transferred to a third party in the event of a sale, acquisition, merger or bankruptcy involving RBF.
To the extent you purchase goods or services on the Website, from RBF, you agree that RBF may retain such information for archival purposes for a reasonable time. You agree that RBF shall not be liable for any non-intentional data breaches and agree to hold RBF harmless therefrom.
Information Provided for Services
As tax preparers, we are prohibited by Internal Revenue Code Section 7216 from disclosing your income tax return information without your consent, other than for the specific purpose of preparing, assisting in preparing or obtaining and providing services in connection with the preparation of an income tax return for you. Furthermore, as a member of the Pennsylvania Institute of Certified Public Accountants engaged in income tax preparation or financial planning, we are generally prohibited from disclosing confidential client information about you to affiliates and nonaffiliated third parties without your specific consent.
We do not disclose any Information Provided for Services about our clients or former clients to our affiliates or to nonaffiliated third parties except as permitted by law, the Codes of Professional Conduct and Ethics Rulings of the Pennsylvania Institute of Certified Public Accountants and the American Institute of Certified Public Accountants (AICPA). Information Provided for Services about you and our former clients may be disclosed to both our affiliates and nonaffiliated third parties as permitted by law, our Codes of Professional Conduct and Ethics Rulings, as follows:
• Complying with a validly issued and enforceable subpoena or summons;
• In the course of a review of our firm’s practices as required by the American Institute of Certified Public Accountants (AICPA), the Pennsylvania Institute of Certified Public Accountants (PICPA) or Pennsylvania State Board of Accountancy. Any disclosure in this instance would be the subject of a confidentiality agreement prohibiting the use of such information for any purpose other than the required review of our firm’s practices;
• Initiating a complaint or responding to an inquiry made by the Professional Ethics Committee of the PICPA, the ethics division or trial board of AICPA, or any duly constituted investigative or disciplinary body having jurisdiction;
• A review of a professional practice in conjunction with a prospective purchase, sales, or merger of all or part of our practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser does not disclose information obtained in the course of the review;
• Participating in actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record; or,
• Providing information to affiliates of the firm and nonaffiliated third parties who perform services or functions for us pursuant to a contractual agreement, which prohibits the third party or affiliate from disclosing or using the information other than for the purposes for which the information was disclosed: for example, using an outside service bureau to process client’s tax returns, using a records-retention agency to store clients’ records, or using an information technology provider to facilitate online access to clients’ records.
CONFIDENTIALITY AND SECURITY
RBF will take reasonable steps to restrict access to the information discussed in this policy and the areas of the Website designated as being suitable for a secure file exchange remain secure. We cannot, however, guarantee the absolute security of such transmission tools or any information retained by RBF. You understand that your use of the Client Portal is subject to the Client Portal Terms, and if you use the Client Portal, you expressly agree to such terms.
UPDATE AND OPT-OUT
If you would like to update any information you have sent to RBF, or if you do not want to receive information from RBF, please contact us at email@example.com. RBF will make reasonable efforts to honor any request you make to forgo contacts with you in the future or delete your information. Please note that if you make an opt-out request, RBF will retain your contact information to make efforts to ensure that you are not contacted in the future. To the extent required by the CAN-SPAM Act, or other similar domestic and international regulation, commercial e-mail messages will also provide you with an opportunity to opt-out of receiving this information. Please note that changes to your preferences may not be effective immediately and will only be effective prospectively.
CALIFORNIA PRIVACY RIGHTS
Beginning on January 1, 2005, California Civil Code Section 1798.83, also known as S.B. 27, or the “Shine the Light” law, allows California residents to request certain information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties for their own direct marketing purposes. To make such a request, please contact us at firstname.lastname@example.org with “Request for California Privacy” in the letter subject line. You must include sufficient detail for us to locate your information; at a minimum, your name, email and postal address. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that the California Shine the Light law does not cover all information sharing. Our disclosure only includes information covered by the law.