Privacy Policy

1. Information We Collect

We collect information that identifies, relates to, or could reasonably be linked with you ('Personal Information'). The categories of information we collect include:

• Identifiers: Name, physical address, email address, phone number, Social Security Number (SSN), and Individual Taxpayer Identification Number (ITIN).
• Government Identifiers: Social Security Numbers (SSNs), Individual Taxpayer Identification Numbers (ITINs), and Employer Identification Numbers (EINs) used for tax filing and resolution.
• Financial Data: Income statements, bank statements, asset lists, employment history, tax records, IRS correspondence, Offer in Compromise (OIC) applications, and Installment Agreement documentation.
• Tax Return Information: Information obtained from IRS Form 1040, 941, 940, state tax returns, and related schedules and attachments, all of which is subject to confidentiality protections under IRC Section 6103.
• Internet Activity: IP addresses, browser type, operating system, pages visited on our website, and interaction data collected via cookies and similar technologies.

2. How We Use Your Information

We use your data strictly to provide tax resolution and accounting services. Specific uses include:

• Preparing and filing federal and state tax returns (Form 1040, 941, 940, and related forms)
• Submitting Offer in Compromise (OIC) requests to the IRS
• Negotiating and administering Installment Agreements with the IRS and state tax authorities
• Filing back-tax returns and seeking penalty abatements
• Providing accounting, bookkeeping, and CFO advisory services
• Communicating with you regarding your account, appointments, and service updates
• Responding to IRS or state tax authority inquiries on your behalf under a valid power of attorney

3. Confidentiality of Tax Return Information (IRC Section 6103)

Your tax return information obtained from the IRS or state tax authorities is confidential under Internal Revenue Code Section 6103. This means:

• We do not disclose tax return information except as required for tax preparation, representation, and resolution services you have authorized
• SSNs and ITINs are used solely for tax identification purposes and are stored with encryption at rest
• Full SSNs are never displayed in any client-facing documents or communications
• As a firm practicing before the IRS, we are subject to IRS Circular 230 regulations, which impose additional obligations regarding client data confidentiality

4. Data Sharing & Disclosure

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information in the following circumstances:

A. Taxing Authorities

We share your information with the Internal Revenue Service (IRS), state Departments of Revenue, and other taxing authorities as required for tax preparation, filing, and resolution services you have requested and authorized.

B. Service Providers

We share your information with trusted service providers who assist in our operations, including:

• Tax preparation and filing software providers (e.g., Drake Software, ProConnect Tax Online)
• Client relationship management systems (CRM)
• Cloud storage and document management providers
• Payment processing providers (for installment agreement payments)
• SMS and text messaging service providers (for appointment reminders and service communications)

All service providers are contractually bound to protect your personal information and use it only for the purposes we have authorized. Each service provider signs a data processing agreement that includes confidentiality obligations, security requirements, and restrictions on further disclosure.

5. SMS & Mobile Messaging

By providing your phone number, you consent to receive SMS messages from Union National Tax regarding your account, appointments, service updates, and tax-related notifications. Message frequency varies based on your account status. Standard SMS rates may apply.

SMS messages are sent in compliance with the Telephone Consumer Protection Act (TCPA) and CAN-SPAM regulations. You can opt out of SMS messages at any time by replying STOP to any message. Opt-out requests are processed within 24 hours.

Mobile information will NOT be shared with third parties or affiliates for marketing or promotional purposes.

6. Email Marketing & Communications

If we send marketing or promotional emails, each such email will: (a) clearly identify that it is a marketing communication; (b) include our physical postal address; (c) provide a clear opt-out mechanism; and (d) process opt-out requests within 10 business days. You may opt out of marketing emails at any time by clicking the unsubscribe link in any email or contacting us directly.

7. Data Retention Policy

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including for tax compliance, legal obligations, and service continuity. Specific retention periods:

• Tax Records and Returns: Minimum seven (7) years from the filing date, as required by IRS guidelines
• Client Account Information: Duration of the client relationship plus seven (7) years
• IRS Correspondence (OIC, Installment Agreements): Duration of the agreement plus seven (7) years
• SMS and Communication Records: Five (5) years from the date of communication
• Security Logs: Three (3) years from the date of log entry

Upon expiration of retention periods, your data is securely destroyed using industry-standard methods: digital data is overwritten using secure deletion protocols, and physical documents are cross-cut shredded. Data under legal hold or active dispute may be retained until the matter is fully resolved.

8. Security Measures

We implement bank-level security to protect your sensitive tax data, including:

• Encryption at rest and in transit (TLS/SSL for all data transmission)
• Strict role-based access control limiting data access to authorized personnel only
• Multi-factor authentication (MFA) for all staff accessing client data
• Physical security for office and server infrastructure
• Annual security awareness training for all employees
• Incident response procedures and regular security audits

9. Your Rights to Access, Correct, and Delete

You have the right to:

• Access: Request a copy of all personal information we hold about you. We will provide this within 30 days of your request.
• Correct: Request correction of any inaccurate personal information. We will process corrections within 15 business days.
• Delete: Request deletion of your personal information, subject to legal retention requirements (see Section 7: Data Retention Policy).
• Portability: Request your data in a structured, commonly used, machine-readable format.

To exercise any of these rights, contact us at the email address provided in the 'Contact Us' section below. We will verify your identity before processing any request. You will not be charged for exercising these rights unless requests are excessive or repetitive.

10. California Consumer Rights (CCPA/CPRA)

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of: (1) categories of personal information collected; (2) specific pieces of personal information collected; (3) purposes for collection; (4) sources of information; (5) third parties with whom information is shared.
• Right to Delete: Request deletion of your personal information, except where retention is required by law (including IRS record-keeping requirements for tax records for minimum 7 years).
• Right to Correct: Request correction of inaccurate personal information. We will respond within 30 days.
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising. If this changes, we will update this policy and provide opt-out mechanisms.
• Right to Limit Use of Sensitive Personal Information: We use SSNs and ITINs only for tax filing and resolution purposes as required by law.
• Non-Discrimination: We will not discriminate against you for exercising any CCPA rights.

To submit a verifiable consumer request under CCPA, contact us at the email address provided in the 'Contact Us' section. We will verify your identity and respond within 45 days.

11. EU/EEA Data Subject Rights (GDPR)

If you are located in the European Union or European Economic Area, you have the following rights regarding your personal data under the General Data Protection Regulation (GDPR):

• Right of Access (Art. 15): Request a copy of your personal data and information about how it is processed.
• Right to Rectification (Art. 16): Request correction of inaccurate personal data.
• Right to Erasure (Art. 17): Request deletion of your personal data, subject to legal retention requirements for tax records (minimum 7 years under IRS regulations).
• Right to Restriction of Processing (Art. 18): Request limitation of processing in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interests.
• Right to Lodge Complaint: File a complaint with your local supervisory authority.

We process personal data under one or more of the following legal bases under GDPR Article 6: (a) Consent — where you have given explicit consent; (b) Contract — processing necessary to perform a contract with you; (c) Legal Obligation — processing required to comply with applicable tax laws including IRS regulations and IRC 6103; (d) Legitimate Interests — processing for legitimate business purposes that do not override your rights.

If your data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses or adequacy decisions.

12. Data Breach Notification Procedures

In the event of a data breach that affects your personal information, we will:

1. Notification Timeline: Notify affected individuals within 60 days of discovering the breach, in accordance with applicable state and federal requirements.
2. Content of Notification: Include: (a) description of the breach and types of information affected; (b) timeline of breach; (c) steps we are taking to address the breach; (d) contact information for questions and concerns.
3. IRS Reporting: If the breach involves SSNs, ITINs, or tax return information, we will follow IRS guidance on reporting and may be required to notify the IRS separately.
4. Remediation: Conduct a thorough investigation, implement corrective measures, and take steps to prevent future breaches.

For suspected data breaches, contact us immediately at the email address provided in the 'Contact Us' section below.

13. Children's Privacy

Our services are not directed to individuals under 18 years of age, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected information from a child under 13, we will delete that information promptly. Parents or guardians who believe we may have collected information from a child under 13 should contact us immediately.

14. Health Information

In the course of tax preparation and resolution services, we may encounter health-related information necessary for accurate tax filing (such as medical expense deductions, health insurance premiums, or HSA/FSA distributions). This information is treated with strict confidentiality and protected under our security measures described in Section 8.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of any material changes by posting the updated policy on our website with a revised 'Last Updated' date. We encourage you to review this policy periodically.

16. Contact Us

If you have questions about this Privacy Policy, wish to exercise any of your rights, or believe we may have collected information from a child under 13, please contact us:

Email: privacy@unionnationaltax.com

Physical Address: [Street Address, City, State, ZIP — INSERT ACTUAL ADDRESS]

This Privacy Policy is a template for informational purposes and does not constitute legal advice. Consult with a qualified attorney for legal advice specific to your situation. Requirements may vary based on jurisdiction, business model, and specific services offered.