Expat Tax Professionals Privacy Notice
Effective Date: April 2020
Expat Tax Professionals LLC, owned and operated by Goldtree Tax Services LLC ("Expat Tax Professionals", "we", "our" or "us"), offers expat tax filing and related services to Customers (as defined below) using the Expat Tax Professionals Portal (the "Portal"). The Portal enables Customers to upload information such as via an online tax questionnaire, review their own documents, and make payments.
We also offer the website www.ExpatTaxProfessionals.com (the "Site", and together with the Portal – the "Services"), which provides further information regarding our Services, our company and the ways to get in touch with us.
We are strongly committed to making our privacy practices more transparent and fair. This Privacy Notice (this “Notice”) describes how we collect, store, use and disclose personal data regarding persons who visit our Site ("Visitors") or use our Portal ("Customers", and together with Visitors - "Users" or "you"). It also describes how we process personal data that may be provided to us by our Customers, and our role as "Data Processor" of such data. It applies whenever you visit our Site or use our Portal, interact with us or otherwise access or use any of our Services.
Specifically, it describes our practices regarding –
Please read this notice and make sure that you fully understand and agree to it. If you do not agree to this notice, please discontinue and avoid using our Services.
You are not legally required to provide us with your Personal Data, but without it we will not be able to provide you with some or all of our Services, or certain features of the Services.
We collect the following categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of Users of our Services.
We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our Users typically use and engage with our Services, to better secure our Services and to optimize the overall user experience and performance of our Services.
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, improving our customer service and support operations, and protecting and securing our Users, ourselves, our Services and members of the general public.
Accordingly, we use Personal Data for the following purposes:
Our Site utilizes "cookies", anonymous identifiers and other tracking technologies, which help us to provide and improve our Services, and in order to provide a better experience to our Users. In order for some of these technologies to work properly, a small data file ("cookie") must be downloaded and stored on your device. Some cookies and other technologies serve to recall Personal Data, such as an IP address, and are used for purposes of session and user authentication, security, keeping the user's preferences, connection stability, monitoring performance and generally providing and improving our Services.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or to block cookies with your browser.
Your Personal Data may be maintained, processed, accessed and stored by Expat Tax Professionals and our authorized affiliates, Service Providers (as defined below) and business partners worldwide, as necessary for the proper delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, we have taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We retain your Personal Data for the period necessary in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our User and have not notified us otherwise. We will also retain your Personal Data for legal and accounting purposes (i.e. as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use).
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you. We periodically delete unused Personal Data.
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Notice:
For the removal of doubt, we may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We will provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. If you wish not to receive such promotional communications, you may notify us at any time by e-mailing us at [email protected] or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate, such as when we collect sensitive information including credit card data or personal financial information. Only those employees who need the information to perform a specific function (for example, billing, customer service, or providing the Services) are granted access to Personal Data. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. We are not responsible for the privacy practices of third party sites to which our Site contains links.
If you wish to exercise your rights under applicable law to request access to, and/or rectification or erasure of your Personal Data held by us; to restrict or object to such Personal Data’s processing; or to port such Personal Data – please contact us at [email protected].
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with the applicable provisions of this Notice.
Please note that in some cases, as we may rely on our Service Providers' APIs and systems, your requests may require several weeks to process.
Our Services are not designed to attract children under the age of 16. We do not knowingly or intentionally collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child.
If you believe that we might have any such data, please contact us at [email protected].
Certain data protection laws and regulations typically distinguish between two main roles for parties processing Personal Data: the "Data Controller", who determines the purposes and means of processing, and the "Data Processor", who processes the data on behalf of the Data Controller. To the extent that such laws and regulations apply, Expat Tax Professionals is the "Data Controller" of Visitors' and Customers’ Personal Data collected by Expat Tax Professionals, and assumes the responsibilities of Data Controller (solely to the extent applicable under law), and as set forth under this Notice.
If a Customer is an entity who uploads or submits any Personal Data concerning Users from such Customer's organization, or transmits any materials containing Personal Data to our Services, such Customer is deemed the "Data Controller" of this Personal Data, and we will only process it on the Customer's behalf, as their "Data Processor". This means that in such cases, we will only process such data on behalf of such Customers and in accordance with their reasonable instructions, subject to our contractual agreements. Such Customers will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
If you are a data subject of any of our Customers (either their employee, or an individual whose Personal Data appears in any Materials), please note that Expat Tax Professionals only processes your data solely on such Customer's behalf. If you would like to make any requests or queries regarding your Personal Data, we encourage then to contact such Customer(s) directly. For example, if you wish to access, correct, or delete data processed by Expat Tax Professionals on behalf of its Customers, please direct your request to the relevant Customer (who is the “Controller” of such data). Unless otherwise instructed by our Customer, we will retain the Personal Data processed on their behalf for the period set forth in Section 4 above.
Updates and amendments: We may update and amend this Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you.
Questions, Concerns or Complaints: If you have any comments or questions about this Notice or if you have any concerns regarding your Privacy, please contact us at [email protected].