We may collect, use, store and transfer different kinds of information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a particular consumer or device (your “Personal Information”), which we have grouped into the following categories:
- Identity Data includes your real first and last name, alias, title, date of birth, gender, or unique personal identifier.
- Contact Data includes billing address, servicing address, email address, and telephone numbers.
- Technical Data includes internet protocol (IP) addresses, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, sensory data (e.g., audio, electronic, visual, thermal, olfactory or similar information), or other technology on the devices you use to access the Website.
- Usage Data includes information about how you use the Website, products, and services.
- Employment Data includes the details of your past and current employment history, performance evaluations, and/or education records.
Additionally, if you communicate with us regarding our Website or our services, we will collect any information that you provide to us in any such communication.
We use Personal Information primarily for our own internal purposes, such as providing, maintaining, evaluating, and improving our services and Website, fulfilling requests for information, and providing customer support.
We have set out below, in a table format, a description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Note that we may process your Personal Information for more than one lawful reason depending on the specific purpose for which we are using your Personal Information. Please contact us if you would like additional information about the specific legal basis on which we are relying to process your Personal Information where more than one reason has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful Basis for Processing and Basis of Legitimate Interest|
|To register you as a new client||(a) Identity|
|To provide you with a quote for our services upon your request||(a) Identity|
|Necessary for our legitimate interests (to operate our business, offer our products, and perform our services)|
|To manage our relationship with you, which includes:|
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Necessary to comply with a legal obligation|
(b) Necessary for our legitimate interests (to keep our records updated and to conduct product/service research)
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)|
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and to measure its success||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to conduct market research and improve our products/services)|
|To use data analytics to improve our Website, products/services, marketing, customer relationships, and experiences||(a) Technical|
|Necessary for our legitimate interests (to define conduct market research, to update our Website, and to calibrate marketing strategy)|
|To provide suggestions and recommendations to you that you may find interesting||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.
If we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.
While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.
We use “cookies” on this Website. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our Website. Cookies can also enable us to track and target the interests of our users to enhance the experience on our Website. Usage of a cookie is in no way linked to any personally identifiable information on our Website.
We will not sell or otherwise provide the information we collect to outside third parties for the purpose of direct or indirect mass email marketing.
We will disclose Personal Information and/or an IP address when required by law or in the good-faith belief that such action is necessary to:
- Cooperate with the investigations of purported unlawful activities and conform to the edicts of the law or comply with legal process served on our company
- Protect and defend the rights or property of our Website and related properties
- Identify persons who may be violating the law, the rights of third parties, or otherwise misusing our Website or its related properties.
Please keep in mind that whenever you voluntarily disclose Personal Information online – for example through e-mail, discussion boards, or elsewhere – that information can be collected and used by others. In short, if you post Personal Information online that is accessible to the public, you may receive unsolicited messages from other parties in return.
Ultimately, you are solely responsible for maintaining the secrecy of your Personal Information. Please be careful and responsible whenever you are online.
This Website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of any other site that collects personally identifiable information.
Surveys & Contests
From time to time our Website may request information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and email address), and demographic information (such as zip code, age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Website.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. Please contact us via telephone at (714) 921-2929 or via mail XOA TAX, ATTN: Privacy Officer, 10015 Garden Grove Blvd Garden Grove, CA 92844 if you would like to:
- Request access to your Personal Information – you will receive a copy of the Personal Information we hold about you, which will allow you to check that we are lawfully processing it. Upon your request, we will provide you the following about our collection and use of your Personal Information over the previous twelve (12) months:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purpose for collecting or selling your Personal Information;
- The categories of third parties with whom we share your Personal Information;
- The specific pieces of Personal Information we collected about you; and
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Request correction of your Personal Information – this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your Personal Information – this enables you to ask us to delete or remove Personal Information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, we may not be able to fulfill your request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected your Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it; and
- For California residents, comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Object to the processing of your Personal Information – if we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground, you may object as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which overrides your rights and freedoms.
- Request restriction of processing your Personal Information – this enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend a legal claim; or (iv) if you have objected to our use of your Personal Information but we need to verify whether we have an overriding legitimate basis to use it.
- Request transfer of your Personal Information – you may request to have your Personal Information transferred to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent – when we are relying on consent to process your Personal Information, you may withdraw or revoke your consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are a resident of California, you may have certain additional data protection rights regarding the access, rectification, deletion, processing, storage, portability, transfer, and restriction of your Personal Information under the California Consumer Privacy Act of 2018 (the “CCPA”).
In the past twelve (12) months, we have used names and email addresses to create marketing materials that we then email to you using various third-party email distribution applications (for example, Constant Contact).
If you would like to make any of the requests detailed above, only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.
You may only make a request for access twice within a 12-month period. The request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Any disclosures we provide will only cover the 12-month period preceding the request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Children’s Online Privacy Protection Act Compliance
We do not knowingly collect information from minors. We follow the requirements of COPPA and do not collect any information from those under 13. If you are under the age of thirteen, do not provide any personal information to us, and don’t use our Sites. If you believe that a child under the age of 13 has provided us with personal information, please contact us immediately.
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