Privacy Policy

PRIVACY POLICY
Last updated November 11, 2024
This Privacy Notice for Krutilla & Associates ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our websites, web-based and mobile applications, meetings and events (in-person and virtual), and other online services ("Services").
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights
and choices. We are responsible for making decisions about how your personal information is
processed. If you do not agree with our policies and practices, please do not use our Services. If
you still have any questions or concerns, please contact us at
https://www.krutillacpa.com/contact-us.

SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details
about any of these topics by using our table of contents below to find the section you are
looking for.
What personal information do we process? When you visit, use, or engaged our Services, we may
process personal information depending on how you interact with us and the Services, the choices
you make, and the products and features you use. We may collect the following personal
information about you and/or your spouse including name, address, e-mail address, telephone
number, social security number, driver's license number, passport number, state or other
government-issued documents for identification to carry out the Services you requested.
Do we process any sensitive personal information? Some of the information may be considered
"special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual
orientation, and religious beliefs. Sensitive personal information may vary by state law. Please do
not provide any sensitive personal information to us unless you give us permission to use such
information for our business.
Do we collect any information from third parties? We do not collect any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We process
your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share
your information with third-party providers that we engaged with to provide you the Services that
you requested such as software vendors to allow us to perform our engaged services requested by
you. For web-based, mobile applications, and messages via email, our third-party providers use
cookies, web-beacons, wayfinding technology to collect certain personal information such as IP
addresses and geographical location in connection with your activities. You can disable the
sharing of location or tracking of activities on your device.
How do we keep your information safe? We have data security policies and organizational and
technical processes and procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage technology can be guaranteed to
be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security and improperly collect, access,
steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy
law may mean you have certain rights regarding your personal information. To make a Data Privacy
Request, please contact us by:
E-mailing us at Privacy@krutillacpa.com
Submitting a Data Privacy Request through our webform
https://www.krutillacpa.com/contact-us.
Calling us at 925-941-5440

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM MINORS?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT WHEN YOU VISIT OUR WEBSITE?

Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in
obtaining information about us or our Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:

names
phone numbers
email addresses

Sensitive Information. We do not process sensitive information through our website.
All personal information that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with Law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with
our Services, including:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/ offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested services.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We do not sell any of your personal information for monetary purposes. However, we may
be deemed to be selling or sharing your information with our third-party vendors that we have
engaged to provide services to us such as hosting webmaster. By using this website, our third-
parties vendor may be collecting your IP addresses, geographical location, and cookie information
for advertising and analytical purposes. You may be able to disable the tracking on your devices.

4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
Privacy Notice unless otherwise required by law. We will only keep your personal information for as
long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention
period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and
technical security measures. We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the security of any personal information we
process. However, despite our safeguards and eorts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do
we knowingly sell such personal information. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at https://www.krutillacpa.com/contact-
us.

7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time, depending on your
country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information,
which may be expressed and/ or implied consent depending on the applicable law, you have the
right to withdraw your consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?" below.
However, please note that this will not aect the lawfulness of the processing before its withdrawal
nor, when applicable law allows, will it aect the processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
If you have questions or comments about your privacy rights, please contact us at
https://www.krutillacpa.com/contact-us.

8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-
Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At this stage, no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised version of this
Privacy Notice. California law requires us to let you know how we respond to web browser DNT
signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected

A. Identifiers Contact details, such as real Yes
name, alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online identifier,
Internet Protocol address,
email address, and account
name

B. Personal information as Name, contact information, Yes
defined in the California education, employment,
Consumer Records statute employment history, and

financials information

We may also collect other personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
• Category A - As long as the user has an account with us
• Category B - As long as the user has an account with us

Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE
COLLECT?"

How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE PROCESS
YOUR INFORMATION?"

Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose personal
information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
"selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. We will not sell or share personal
information in the future belonging to website visitors, users, and other consumers.

Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute,
and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law), the sale of personal data, or profiling
in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
• Right to obtain a list of the categories of third parties to which we have disclosed personal
data (as permitted by applicable law, including California's privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law,
including California’s privacy law)

How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by calling
toll-free at 925-941-5440, by visiting https://www.krutillacpa.com/contact-us, or by referring to the
contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use the personal
information provided in your request to verify your identity or authority to make the request.
However, if we cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying your identity and for
security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request and the agent will need to provide
written and signed permission from you to submit such request on your behalf.

California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users
who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a California resident
and would like to make such a request, please submit your request in writing to us by using the
contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an
updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you by prominently posting notice of such changes. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us at
https://www.krutillacpa.com/contact-us or via post at:
Krutilla & Associates
350 N. Wiget Lane, Ste150
Walnut Creek, CA 94598
United States

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have
processed it, correct inaccuracies, or delete your personal information. You may also have the right
to withdraw your consent to our processing of your personal information. These rights may be
limited in some circumstances by applicable law. To request review, update, or delete your
personal information, please fill out and submit a data subject access request.