Last Updated and Effective Date: May 8, 2024

Privacy Policy

This Privacy Policy is provided on behalf of Tax Guard, LLC (“our,” ”we” or “us”) in connection with our products, website, interfaces, and services.

This Privacy Policy describes how we use, disclose, and process your personal information. Your continued use of our website means that you accept the terms of this Privacy Policy.

Our Privacy Policy is in a format that can be navigated, read and understood. Please take a moment to familiarize yourself with our privacy practices and contact us with any questions (at the contact information at the end of this Privacy Policy), if you have any questions.

1. Information We Collect, the Categories of Source of Collection and the Purpose for Collection.

We collect personal information about you for a variety of business reasons as indicated in the charts below.

The term “personal information” as used in this Privacy Policy means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregate consumer information.

Some personal information is particularly sensitive, and we refer to this information as “sensitive personal information”. Sensitive personal information includes various types of personal information, including personal information that reveals an individual’s social security.

Set forth below are the categories of personal information we collect and have collected in the preceding 12 months, the categories of sources from which the personal information was collected and the business or commercial purpose for such collection.

Please note the specific pieces of personal information we may collect about you, and the uses of that information, can vary depending on the nature of your interactions and level of engagement with us.

Category of Personal Information	What We Collect	Categories of Sources from which Personal Information Collected	Business or Commercial Purposes for Collection****
PERSONAL INFORMATION
Identifiers	First and last name Alias Postal address Internet protocol address Email address Date of birth Social security number Other similar identifiers	Directly from you* Automatically, when you visit our website, including cookies on our websites** From your lender From taxing authorities, e.g., the IRS (at the request of your lender and/or with your authorization)	To evaluate and respond to your inquiries and submissions To provide our services*** To provide customer support To communicate with you or send you notices To evaluate and improve our products, services, and other operations (e.g., developing and analyzing new or revised products and services; and assessing the effectiveness of our website, communications, and marketing programs) To verify your identity and maintain a record of your transactions and interactions with us
California Civil Code Section 1798.80 Identifiers Not Included in Other Rows	Telephone number Bank account number Credit card number Debit card number Expiration date Financial data and information, including income, expenses, deductions, etc.	Directly from you* From your lender From taxing authorities, e.g., the IRS (at the request of your lender and/or with your authorization)	To evaluate and respond to your inquiries and submissions To provide our services*** To provide customer support To process your payments and account adjustments and establish and maintain your account and billing records To verify your identity and maintain a record of your transactions and interactions with us
Protected Characteristics	Marital status	From taxing authorities, e.g., the IRS (at the request of your lender and/or with your authorization)	To fulfill IRS requirements
Commercial Information	Records of personal property, products or services purchased, obtained, or considered Other purchasing or consuming histories or tendencies.	From your use of our services	To maintain records as part of our business operations
Internet Information	Device information, such as IP address, browser type, and other operating system data available Your Internet service provider (ISP) The times and dates that you visit our website and the duration of such use Internet or other similar network activity such as information regarding your browsing history, search history, and information about how you interact with our website or emails Your industry and business	Automatically, when you visit our website, including cookies on our websites**	To evaluate and respond to your inquiries and submissions To provide customer support To evaluate and improve our products, services, and other operations (e.g., developing and analyzing new or revised products and services; and assessing the effectiveness of our website, communications, and marketing programs) To verify your identity and maintain a record of your transactions and interactions with us
Geolocation Data	Internet protocol address	Automatically	To determine where you are located for security and marketing purposes
Audiovisual Information	Recordings of our interactions	Automatically	For quality control, training, security, and analytics purposes
SENSITIVE PERSONAL INFORMATION
Sensitive Identifiers	Social security number Tax status information, data, and transcripts maintained by and obtained from taxing authorities, e.g., the IRS.  This includes, but is not limited to, income, withholdings, expenses, deductions, etc.	Directly from you* From taxing authorities, e.g., the IRS (at the request of your lender and/or with your authorization)	To evaluate and respond to your inquiries and submissions To provide our services To obtain your tax status information To provide customer support To verify your identity and maintain a record of your transactions and interactions with us

* We collect information directly from you through various means, including correspondence (either electronically or in paper format) or by phone when you interact with one of our representatives. You are only required to provide such information if you want to take advantage of products and services provided by us.

** Cookies are small text files that store information on computer or mobile device, and enable websites like ours to capture and remember information about you. Please refer to the “Cookie Notice” section below for further information about how we use cookies.

*** For a description of our services, please click here: https://tax-guard.com/. Please note that if you elect to do business with a commercial lender, your commercial lender may provide us with your personal information as part of providing that commercial lender with our products and services.

**** We may also use your personal information, as necessary: (a) to comply with any legal process; (b) to enforce our terms and conditions; (c) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (d) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use personal information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). Finally, we may use your personal information to person any other business activity, as needed or necessary, and to perform internal tasks such as auditing, data analysis and research.

1. Personal Information We Sell, Share or Disclose and the Purpose for It.

   A. Selling of Personal Information or Sharing of Personal Information for Cross-Context Behavioral Advertising.

During the past 12 months, we have conducted certain activities with some of your personal information, identified in the chart below, that may be considered sharing of personal information for cross-context context behavioral advertising or selling of your personal information under California law. Additional information regarding these practices is set forth in the text after the chart.

Categories of Personal Information that We Disclose	Business Purposes for the Disclosure of Personal Information
PERSONAL INFORMATION
Identifiers	Auditing of Ad Impression Security and Fraud Detection Services on Our Behalf Advertising and Marketing Services
California Civil Code Section 1798.80 Identifiers Not Included in Other Rows	Auditing of Ad Impression Security and Fraud Detection Services on Our Behalf Advertising and Marketing Services
Protected Characteristics	Services on Our Behalf
Commercial Information	Services on Our Behalf
Internet Information	Auditing of Ad Impression Security and Fraud Detection Services on Our Behalf Advertising and Marketing Services
Audiovisual Information	Services on Our Behalf Advertising and Marketing Services
SENSITIVE PERSONAL INFORMATION
Sensitive Identifiers	Services on Our Behalf

* We may disclose your personal information to commercial lenders to whom we provide services pursuant to a contract, and to whom you consented for us to disclose your personal information. Prior to disclosing your personal information to commercial lenders, we enter into a contract with the commercial lender that describes the purpose and requires us and the commercial lender to both keep that personal information confidential and secure. We collect and sell that personal information only to that commercial lender that you, the customer of the commercial lender, chooses to do business with as part of our services.

** Please refer to the “Cookie Notice” section below for further information about how we use cookies.

B. Disclosure of Personal Information to Service Providers and Contractors for a Business Purpose.

In addition, we disclose and have disclosed in the preceding 12 months personal information to our commercial lenders and contractors for the following business purposes.

• Auditing of Ad Impression: We disclose personal information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Security and Fraud Detection: We disclose personal information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
• Services on Our Behalf: We disclose personal information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
• Advertising and Marketing Services: We disclose personal information to provide advertising or marketing services on our own behalf.

The following chart sets forth the categories of personal information we disclose for a business purpose.

Categories of Personal Information	Categories of Third Parties to Whom Information Was Disclosed*,**	Business Purposes for the Disclosure*,**
PERSONAL INFORMATION
Identifiers	To your lender	To provide our services
Identifiers	Customer Relationship Management (CRM) companies and integrated tools, e.g., HubSpot, NetResults, and Salesloft	To communicate with you or send you information
SENSITIVE PERSONAL INFORMATION
Sensitive Identifiers	To your lender	To provide our services

We may also disclose personal information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Finally, we may disclose personal information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

2. Your Rights and How You Can Exercise Them.

   A. Generally

You can request to review your personal information contained in our records at any time. To do this, you may send a letter to us requesting to see your information or use the other methods at the contacts set forth at the end of our Privacy Policy. If you believe our information is incomplete or inaccurate, you can request we correct it. You can also have your personal information deleted, subject to our retention and disposal policies. We are happy to make corrections whenever possible. Please note that information we receive from the IRS pursuant to performance of our services cannot be amended (you will need to contact the IRS directly). We will respond to all such requests within a reasonable timeframe. You may opt out of any future contacts from us at any time.

B. Rights for California Residents.

This section only applies to California residents.

California consumers have certain rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and related regulations (collectively, the “CCPA”), which are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

• Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of third parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you. You also have the right to know the list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third party direct marketing purposes. You may submit a request by emailing us at privacy@tax-guard.com or calling us at 877-232-3011.
• Right to Know Personal Information Disclosed, Sold or Shared and to Whom. Since we sell, share and/or disclose your personal information, as described above, you have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and (3) the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by emailing us at privacy@tax-guard.com or calling us at 877-232-3011.
• Right to Request Deletion of Your Personal Information. You have the right to request that we delete your personal information, subject to a number of exceptions. Following receipt of a request, we will let you know what, if any, personal information we can delete from our records.  If we cannot delete all of your personal information, we will let you know the reason. You may submit a request by emailing us at privacy@tax-guard.com or calling us at 877-232-3011.
• Right to Correct Inaccurate Information. If you believe that any of the personal information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. Please note that information we receive from the IRS pursuant to performance of our services cannot be amended (you will need to contact the IRS directly). You may submit a request by emailing us at privacy@tax-guard.com or calling us at 877-232-3011.
• Right to Opt-Out of the Sale and Sharing of Your Personal Information. You may opt-out of the sale or sharing of your personal information by clicking here: Do Not Sell or Share My Personal Information
• Right to Limit the Use of Your Sensitive Personal Information. California law allows California residents, under certain circumstances, to request that we limit the use or disclosure of their sensitive personal information. Given our use and disclosure of your sensitive personal information by us, this right does not apply to you.
• Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with the requests to know, delete and/ or the correct. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

• Password Protected Accounts.  If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data.  If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.

• Verification for Non-Accountholders.  If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
  • For requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
  • For requests to know specific pieces of personal information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.  We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.  We will maintain all signed declarations as part of our records.
  • For requests to correct or delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion.  We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete personal information, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130.

We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

3. Nevada Privacy Notice.

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your Personal Information are not sales under Nevada law, so no opt-out is required.

4. Cookie Notice

   A. What are Cookies?

Cookies are small text files sent from a website to your browser’s memory that help make your online experience more efficient and relevant to your interests. Cookies have many different jobs. For example, they allow us and our service providers to identify returning visitors and tell us things such as how many people visited our websites, the pages that were accessed, and whether there were any technical problems in loading pages. We also use cookie information for security purposes and to display information more effectively. By collecting this information, we learn what parts of our websites and services are the most interesting or valuable to our visitors, and can monitor overall interest in, and functioning of, our websites and services. Cookies also help to ensure that advertisements you see online are more relevant to you and your interests, and we may use cookies to track responses and views of our advertisements.

There are other technologies that are similar to cookies, such as web beacons, which are also known as internet tags, pixels and clear GIFs. These technologies function like cookies, and we refer to cookies and these similar technologies collectively as “cookies” for purposes of this Cookie Notice.

You can find more information about cookies at: www.allaboutcookies.org.

Some cookies can collect personal information, including information you disclose like your username, or other identifiers that are collected together with your browsing history and activity, to deliver more relevant content and understand your preferences.

B. Use of Cookies on Our Websites

Like virtually all websites and online services, our websites and services use cookies. Some of the cookies we use are temporary, and are discarded as soon as you end your session or close your web browser. Other cookies, called persistent cookies, remain on your computer’s hard drive for longer periods of time, after which they expire, or until you delete them.

Further, some of the cookies on our websites are first-party cookies, meaning that we create and place them on your computer or device when you visit our websites or use our online services. Other cookies, known as third-party cookies, are placed on your computer or device when you visit our websites or use our online services, but are stored by other service providers or third-party domains cookies and used to measure audiences, limit repeat advertisements to use, and customize content or advertising. We restrict the use of third-party cookies to trusted partners. These companies have their own privacy policies and data collection practices. The purpose of the third-party cookies is to provide audience-measurement, limit repeat advertisements shown to you, social-sharing functions, to customize content, or personalize advertising.

C. Use of Analytics Cookies on Our Websites

We or our third-party partners providing web analytics and marketing automation tools, including, but not limited to Google Analytics, HubSpot, Net-Results, and Leadfeeder (hereafter “Analytics Providers”), use cookies (as defined above), analytics, and other similar tracking technologies to help us provide users with a better service and more customized web experience.

We use web analytics and marketing automation tools provided by Analytics Providers on our website and emails to collect information. Your visit(s) to our website may result from one or more sources, including, but not limited to, organic traffic, direct traffic, referral traffic, email marketing, and paid search. Analytics Providers collect information such as how often users visit our site, what pages are visited, and what other sites were visited prior to coming to our site. We use the information we get from Analytics Providers to improve our site, as well as our marketing and email communications. Analytics Providers collect only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. Analytics Providers will also collect contextual information, such as type of web browser, type of operating system, browser resolution, and network location. We combine the information collected using Analytics Providers with personally identifiable information only when you provide us with that information by completing a webform on our website. Although Analytics Providers plant a cookie on your web browser to identify you as a unique user the next time you visit our site, the cookie cannot be used by anyone but the Analytics Providers. We have no access to or control over these cookies.

Analytics tools allow us to measure and assess how users interact with our websites, and digital communications. These services are typically provided by third parties with whom we contract – Analytics Providers. These providers may use many of the same technologies discussed above (such as cookies) to collect various data points associated with your visits to our website. This information may be used to manage and customize our website’s content, layout, and services to improve our site, enhance customer service, and provide tailored messages.

You can opt out of data specifically collected by these Analytics Providers. To learn more about the privacy policies of Analytics Providers and how to opt out of their data collection, please refer to the links below.

Google Analytics: https://policies.google.com/privacy?hl=en-US and https://tools.google.com/dlpage/gaoptout

Leadfeeder: https://www.leadfeeder.com/privacy/

HubSpot: https://legal.hubspot.com/privacy-policy

Net-Results: https://www.net-results.com/privacy-policy/

D. Managing and Disabling Cookies

Users are not required to accept cookies to use our websites. Most browsers automatically accept cookies, but most browsers also allow you to disable or manage the use of cookies to adjust the types of cookies you want to accept. Please note that if you choose to reject all cookies, some portion of our websites or services, as well as most other websites, may not work properly.

5. Our Retention and Disposal Policy.

We will retain each category of your personal information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of personal information pursuant to any applicable contract, law or regulation. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we dispose of personal information, we use reasonable procedures designed to erase or render it unreadable (for example, shredding documents and wiping electronic media).

6. Measures We Use to Secure Your Personal Information.

To help ensure the security of your personal information, we use commercially reasonable administrative, technical, and physical security measures designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite our safeguards, however, no website, app, or information system can ever be completely secure so we cannot guarantee that the use of our systems or websites will be completely safe or secure. Our practices and policies prohibit our employees from using personal information unless they are authorized to do so and have a business need. We require our employees to protect your personal information and maintain its confidentiality.

You should always exercise discretion with respect to the exchange of any personal information over the internet. If you are concerned about the security of your communication, we encourage you to send your correspondence through the postal service or use the telephone to speak directly to us. We are not responsible for the security or confidentiality of communications you send to us through the internet using e-mail messages.

7. Opt-Out Rights.

You can opt-out of commercial emails we may send. In addition, if you request to no longer receive contact from us, we will remove your information from our subsequent emails contact list.

8. Use of Our Website.

Our website is used only by commercial lenders who wish to avail themselves of our commercial services, customers of commercial lenders, or customers engaged in resolution services. For a further description of our services, please click here: https://tax-guard.com/.

Our website and services are not intended for children. We do not structure our website to attract children. Accordingly, we do not intend to collect personal information from anyone whom we know to be under 16 years of age.

9. Changes to our privacy policy.

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy, we will post an updated version on this website. Updates to this Privacy Policy will be referenced by the “Last Updated and Effective Date” shown above. We hope you have found this Privacy Policy helpful. If you are not comfortable with any of the terms or policies described in this Privacy Policy, we ask you to discontinue use of our site.

10. Contact Information.

If you have any questions or concerns, you may contact us at as follows:

Email us at: privacy@tax-guard.com

Call us at: 1-877-232-3011

Write to us at: 10355 Westmoor Drive, Suite 101, Westminster, CO 80021