Effective Date: July 2018
This Privacy Notice describes and governs the information collection, use, and sharing practices of Ivins, Phillips & Barker (“IPB”, “we”, “us”, and “our”), headquartered at 1700 Pennsylvania Ave NW # 600, Washington, DC 20006, with respect to your use of the IPB Tax website at www.ipbtax.com, our processing of your data if you are a client, and our processing of personal data on behalf of clients (collectively, the “Services”). For website visitors or clients in the European Economic Area (“EEA”), and in certain cases for the data subjects whose personal data our clients provide to us, IPB Tax is considered to be the “controller” of the personal data. This Privacy Notice applies to IPB Tax’s processing of personal data as a “controller”. If a client provides us with your personal data, please note that processing of your personal data will also be subject to that client’s privacy practices.
Before you use or submit any information through or in connection with the Services, please carefully review this Privacy Notice. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, PLEASE DO NOT USE THE SERVICES. We will continue to evaluate this Privacy Notice as we update and expand the Services and our offerings, and we may make changes to the Privacy Notice accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Privacy Notice, we will provide you with notice as required by law.
- Information We Collect
We collect information in multiple ways, including when you provide information directly to us, when a client provides us with information, and when we passively collect information from you, such as from your browser or device.
a. Information You Provide Directly to Us
We may collect information from you in a variety of ways, such as when you provide us with your information in order to (a) become a client; (b) maintain your client account with us; (c) receive your client records; and (d) subscribe to our newsletter and event updates. We will collect any information that you provide to us, which may include, but is not limited to: (a) name; (b) email address; (c) mailing address; (d) phone number; and (e) workplace information. You do not have a statutory or contractual obligation to provide us with your information through our website; however, certain information may be required in order to enter into a contract with us.
b. Information that Is Collected About You from Our Clients
We also receive information from or on behalf of our clients. Because of the nature of our services, this could include any type of personal data, but often includes (a) names, (b) contact information, and (c) employment- and tax-related information, including information regarding heirs or others.
c. Information from Other Third Parties
We may also collect information about you or others through non-affiliated third parties. For example, to the extent permitted by law, we may ask for and collect supplemental information from third parties, including public records or information regarding your organization’s history. We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from any other products or services we provide.
d. Information that Is Passively or Automatically Collected
i. Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
ii. Cookies and Other Electronic Technologies
We may also collect data about your use of the Services through the use of Internet server logs, cookies, tracking pixels, and/or other tracking technologies. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c) understand the web pages of the Services you have visited; (d) perform searches and analytics; and (e) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. We also may include web beacons in email messages, newsletters, and other electronic communications to determine whether the message has been opened and for other analytics, personalization, and advertising. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
2. How We Use Your Information
We may use the information we collect from and about you for the following purposes:
- For the purposes for which you provided it;
- To initiate or to provide the features, services, and products available through the Services;
- To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed or event updates you have requested;
- To contact you with information or surveys that we believe may be of interest to you both regarding our products and Services and those of third parties;
- To process and respond to your inquiries or to request your feedback;
- For internal research and reporting;
- To improve the content and features of the Services or develop new Services;
- For recruiting purposes;
- To enforce the legal terms that govern your use of the Services; and
- To administer and troubleshoot the Services.
Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Notice.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.
3. When We Disclose Your Information
We may disclose and/or share your information to or with any non-affiliated third parties under the following circumstances:
- At the Requests of Our Clients. We may disclose your information to third parties at the request of our clients in order to provide our Services, such as to a consulting firm to assist in providing our Services to a client or to a governmental regulator for filing required of a client.
- Consent. We may disclose your information to any third parties based on your consent to do so.
- Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf, including without limitation marketing, market research, customer support, data storage, analysis and processing, and legal services.
- Protection of IPB Tax and Others. You acknowledge, consent, and agree that IPB Tax may access, preserve, and disclose the information you submit or make available for inclusion on the Services, if required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Privacy Notice or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce this Privacy Notice or other contracts with you, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; (d) to respond to your requests for customer service; and/or (e) to protect the rights, property, or personal safety of IPB Tax, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
- Organizational Transfers. As we continue to develop our organization, we may acquire, merge or partner with other organizations. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If any of IPB Tax’s assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
4. Legal Basis for Processing Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground(s) they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing your personal data are as follows:
- To Honor Our Contractual Commitments to You. Much of our processing of personal data is to meet our contractual obligations to our clients or to take steps at clients’ request in anticipation of entering into a contract with them.
- Legitimate Interests
We may also process personal data for the same legitimate interests of our clients and business partners.
- Legal Compliance. We need to use and disclose personal data in certain ways to comply with our legal obligations.
- Consent. Where required by law, and in some other cases, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent.
5. Online Analytics
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
6. Notice Concerning Do-Not-Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. You can learn more about Do Not Track here.
7. Your Choices and Data Subject Rights
All clients and newsletter subscribers can review and update certain user information by emailing us at email@example.com. You can unsubscribe from newsletters and marketing emails by clicking the "unsubscribe" link contained within such communications.
EU Data Subject Rights. Individuals in the European Economic Area and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. Individuals in the European Economic Area may also have rights to object to our handling of their personal data, restrict our processing of their personal data, and to withdraw any consent provided. To exercise these rights, please email us at firstname.lastname@example.org with the nature of your request. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.
Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect), and prior to responding to any requests we may request that you provide us with additional information to confirm your identity. We will consider all requests and provide our response within the time period stated by applicable law.
8. International Transfers
Your personal data will be processed in the United States and potentially other jurisdictions, which may not offer the same level of protection as the privacy laws of your jurisdiction. By using the Services, you acknowledge the processing of your data in the United States or elsewhere outside of your country of residence.
9. Children’s Privacy
The Services are intended for clients over the age of 18 and not for children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, or personal data (as defined by the EU GDPR) from children under the age of 16, we will take reasonable steps to delete it as soon as practicable.
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information because despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
11. Data Retention
We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Notice, as required by our clients, or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.
12. Third-Party Links and Services
The Services may contain links to third-party websites, applications, and other services. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our clients and others to be aware when they leave our Services and to read the privacy statements of each and every site they visit that collects their information.
13. Questions About this Privacy Notice
If you have any questions about our Privacy Notice or privacy practices, you can contact us by emailing us at email@example.com; writing to us at 1700 Pennsylvania Avenue NW #600, Washington, DC 20006; or calling us at +1 202-393-7600.