DK CPA Privacy Policy & Data Protection

Welcome. You have arrived at a website provided by Duffy Kruspodin, LLP (“DK,” “we,” “our” or “us”). Founded in Woodland Hills in 1990, DK is a full-service CPA firm providing a full range of accounting and consulting services from our four Southern California locations in Beverly Hills, Woodland Hills, La Jolla and Irvine.

At DK, we take your privacy seriously. We provide this Privacy Policy (“Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information. If you have questions about this Policy after you review it, feel free to contact us at privacy@dk.cpa.

2. Scope

This Policy governs the following websites as well as their subdomains, and all subdomains or portals that link to this Policy (collectively, “Site”):

https://dk.cpa/ (previous URL that redirects to current is dkllpcpa.com)

https://dkllpcpa.sharefile.com/ (“Client Portal”)

https://duffykruspodin.securepayments.cardpointe.com/pay (“Payment Portal”)

https://www.dkwmllc.com

This Notice also governs when you provide Personal Information or interact with us online or in-person. This Notice also applies to Personal Information that we may collect from you in person at our physical locations (“Locations”), via phone calls or other communications with our representatives or in any other instance when you contact us. For the purpose of this Notice, “Personal Information” (also referred to as “personal data”) means any information relating to an identified or identifiable individual that is protected by applicable privacy laws. The definition of Personal Information does not include publicly available information from federal, state, or local government records, such as professional licenses and real estate or property records.

We refer to all the above as our “Services.” Our Services are used by individuals and organizations who are past, current and prospective clients (“Clients”), current or past employees or individuals who apply for employment with us (“Employees and Job Applicants”) and people who visit the Site (“Site Visitors”).

By using our Site or otherwise using our Services, you acknowledge this Notice and agree to our Terms of Service (“Terms”).

3. What Information We Collect

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.

Information That You Provide to Us

As you interact with our Site or Services, we collect the following Personal Information via the online chat function and webforms or inputs/uploads on our Site, and through telephone calls, text messages, letters, emails and other communications with you.

Clients

Contact information such as your first and last name, user name, email address, home or business address, mailing address, telephone numbers, mobile numbers, job title, and company;
Identifiers such as a driver’s license number or passport number;
Financial information such as your personal or business credit card or debit card number, bank account information and your payment, service and purchase history; and
Other information that could reasonably be used to identify you personally.
Note: Personal Information obtained from or relating to Clients or former Clients may be subject to additional limitations and protections under applicable codes of professional conduct, laws, regulations, and the terms of our engagement letter or other agreements in place with our Clients that outline the services being provided and use restrictions in place regarding Personal Information.

Employees and Job Applicants

Contact information such as your first and last name, user name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
Employment history;
Criminal record background checks and drug testing,
Relevant certifications and licenses; and
Identifiers such as a driver’s license number or passport number and copies of your driver’s license, passport, or other form of identification.

Site Visitors

Contact information such as your first and last name, email address, company, job title, home or business address, telephone numbers, mobile numbers.

Information That Is Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”), including via cookies and other tracking technologies (see Use of Cookies and Other Tracking Technologies section below). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information includes:

Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within the Site that you visit and your activities there, including remembering you and your preferences;
Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);
Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
Information about your engagement with our emails; and
Statistical information about how both unregistered and registered users, collectively, use the Site and Services.

We may also collect sensory data such as CCTV recordings from our facilities or premises to protect the health and safety of our customers and associates, and to prevent, investigate, and prosecute fraud and other criminal activities. We may record your voice when you contact our customer service centers.

Information Collected from Third Parties

The Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of DK from third parties. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media. These third parties also use cookies and other tracking technologies to capture information about your interactions with DK.

DK does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

4. Use of Cookies and Other Tracking Technologies

We use various methods and technologies (“Tracking Technologies”) to store or collect Usage Information, to recognize your browser or device, learn more about your interests to personalize your experience, and deliver our Site and Services to you. These tracking technologies allow us and other third parties to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using this Site, you consent to our use of Tracking Technologies.

Types of Tracking Technologies We Use

A few of the Tracking Technologies used on the Site, include, but are not limited to, the following (there may be future-developed tracking technology or methods that are not listed here):

Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Cookies themselves don’t hold Personal Information. They only have a unique alphanumeric identifier that sits on your browser. And in many cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your Personal Information; for example, when you log into our Client Portal. Our Site may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
Pixels: A pixel is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the device which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements.
Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
Recognition Technologies. These technologies, including application of statistical probability to data sets, attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Other data technologies may be used that collect comparable information for security and fraud detection purposes.

We may also engage third parties, such as Google Analytics, to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to place cookies on Devices of users of our Site, where permitted by law, and subject to your right to opt out through the Site. We use the data collected to help us administer and improve the quality of the Site and to analyze the Site’s usage. Such third parties may combine the information that we provide about you with other information that they have collected. These third parties are required to use your information in accordance with this Privacy Notice. We will record all such disclosures and will use reasonable efforts to ensure that such third parties do not use your Personal Information for any purpose that is not expressly provided for herein.

We classify our cookies into the following categories:

Essential/Strictly necessary cookies. These cookies are essential for you to browse the Site and use its features, such as accessing secure areas of the site. You cannot disable this type of cookie on our Site.
Functionality cookies. Also known as “preference cookies,” these cookies allow the Site to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site to not work properly, so we discourage you from disabling these cookies.
Performance cookies. Also known as “analytics cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. This includes cookies from third-party analytics services if the cookies are for the exclusive use of the owner of the website visited. In some jurisdictions, you may be able to turn these cookies off.
Targeting and Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always from third-parties. In some jurisdictions, you may be able to turn these cookies off.

There are many ways to control cookies. For example, you can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. In so doing, we may not be able to recognize your Device, and you may need to log in every time you visit. You can also opt out of non-essential cookies by opting-out of cookies in our Site’s cookie preference center or enabling an opt-out preference signal on your browser (a Global Privacy Control (“GPC”) or an Opt-Out Preference Signal (“OOPS”).

You can block Google Analytics from accessing your online activity with a browser add-on here.

Separately, you can change your Facebook Ad Preferences here.

General Cookie Information

To generally find out more about cookies, visit this site which also has instructions on how to opt out of targeted advertising cookies here. More opt-out resources are also available from the Digital Advertising Alliance or the Network Advertising Initiative. We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs. Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.

5. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our Services, including to:

provide the following services, among others: accounting services; tax services; business consulting; audit & assurance; business valuation; IT services; HR services; and wealth management;
operate, maintain and improve the Site and the Client Portal;
enable you to access and use the Site and the Client Portal;
improve our services to you, including running analytics, assessing the quality of our services, and for other related internal business purposes;
administer and improve our Site, including to measure the effectiveness of the Site, diagnose problems with our server, analyzing where Site traffic comes from, and to identify our Site users;
communicate with you to personalize your experience with us and improve our understanding of your needs, and to respond to inquiries you send to us;
send you messages promoting our products and services. You may opt-out of receiving certain promotional e-mail messages from us as described in the “Your Choices About the Information We Collect” section below;
protect the health and safety of our personnel, clients, guests, and the general public;
comply with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims;
send you notices, updates, security alerts and support and other messages;
provide and deliver the services and features you request, process and complete transactions, and send you related information, including purchase confirmations and invoices;
create and verify user accounts;
facilitate the functionality of our Site, including payment-related functionality;
customize experiences and personalization when you are on our Site; and
for other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information;

To Communicate with You

We process certain information to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

communicate with you about transactions, services, accounts and programs;
respond to your customer service inquiries and requests for information;
send you personalized content;
communicate with you about our Services; and
implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives.

For Improvement of Our Site or Services

We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

test, research, analyze, or develop products;
maintain, improve, and analyze our Site or Services; and
detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment

We use your Personal Information to evaluate your application for employment or administer employment benefits.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

6. When We Disclose Information

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

Service providers. To provide information to our affiliates and nonaffiliated third parties who perform services or functions for us in conjunction with our services to you, but only if we have a contractual agreement with the other party which prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such disclosures include using a payment processor, website host or email marketing provider.
Legal process. To comply with a validly issued and enforceable subpoena or summons; as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.
Compliance. In the course of a review of our practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry or complaint from such a licensing board of organization.
Business transactions. In conjunction with a prospective purchase, sale, or merger of all or part of our practice, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Site or Services such that such information is no longer linked to your Personal Information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Retention of Personal Information

DK will retain your Personal Information only for as long as is necessary for the purposes set out in this Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

How long we have had a relationship with you or provided our Services to you;
The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;
Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments; defend against potential legal claims; detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;
The privacy impact on individuals of ongoing retention; and
The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

8. Your Choices About the Information We Collect

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below or via the Client Portal. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

You can opt out of receiving marketing emails from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Notice.

Controlling Your Cookies

You can opt-out of cookies by enabling an opt-out preference signal on your browser or opting-out of cookies in our Site’s cookie preference centers.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Site. To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

9. Children’s Privacy

Our Site is not intended for use by children under the age of 18. We do not request, or knowingly collect, any Personal Information from children under the age of 18 without the consent of their parents or guardians. If you are the parent or guardian of a child under 18 who you believe has provided Personal Information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

10. Visitors to the Site Outside of the United States

Our Site is not intended for visitors outside of the United States and we do not direct our activities at users outside of the United States. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Notice.

11. Links

For your convenience, the Site and this Notice may contain links to other websites. DK is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that DK endorses or has any affiliation with the links.

12. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site, and you provide us with your information at your own risk.

13. Your California Privacy Rights

This section of the Notice applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;
To know the length of time we intend to retain each category of Personal Information;
To know whether your Personal Information is sold or disclosed and to whom;
To access your Personal Information;
To delete the Personal Information you have provided to us, with certain exceptions;
To correct your Personal Information;
To opt out of the sale of Personal Information;
To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

The categories of Personal Information collected about you;
The categories of sources from which the Personal Information is collected;
The business or commercial purpose for collecting, selling or sharing Personal Information;
The categories of third parties to whom the business discloses Personal Information; and
The specific pieces of Personal Information collected about you.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Personal Information Collected

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category of Personal Information	Examples of this Category	Sources of Personal Information	Business Purpose for Collection
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.	You Automatically Third Parties	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Personal information described in California Civ. Code § 1798.80(e)	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	You Automatically Third Parties	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking.	You	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	You Automatically	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Biometric information	An individual’s genetic, physiological, biological or behavioral characteristics.	N/A	N/A
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement.	Automatically	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Geolocation data	Physical location and/or movements.	N/A	N/A
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	You Automatically	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Professional or employment related information	Current or past job history or performance evaluations	You (for Employees and Job Applicants)	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Non-public education information (per the Family Educational Rights and Privacy Act	Education records directly related to a student maintained by an educational institution or party acting on its behalf.	N/A	N/A
Inferences drawn from other Personal Information	Information used to create a profile about a person reflecting the person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A	N/A
Sensitive Personal Information	Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data	You	To provide, improve and market our Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law

Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.

Personal Information Sold or Shared

We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale” or “sharing” of that information. In the last twelve (12) months, we have shared to third parties the following Categories of Personal Information:

Category of Personal Information	Recipient Categories	Purpose for Sale/Sharing
Identifiers	Advertising, marketing, and analytics providers	Marketing and analytics
Internet or other electronic network activity information	Advertising, marketing, and analytics providers	Marketing and analytics

We do not have actual knowledge that we sell or share the Personal Information of persons under 16 years of age.

Personal Information Disclosed for Business Purposes

We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:

Category of Personal Information	Recipient Categories	Business Purpose for Disclosure
Identifiers	Service Providers	Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services
Personal information described in California Civ. Code § 1798.80(e)	Service Providers	Helping to ensure the security and integrity of Personal Information Performing services on behalf of the business Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services
Commercial information	Service Providers	Helping to ensure the security and integrity of Personal InformationPerforming services on behalf of the businessInternal research for technological development and demonstrationActivities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services
Internet or other electronic network activity information	Service Providers	Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Sensory data	Service Providers	Helping to ensure the security and integrity of Personal Information Performing services on behalf of the businessInternal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services
Professional or employment-related information	Service Providers	Helping to ensure the security and integrity of Personal Information Performing services on behalf of the businessInternal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services
Sensitive Personal Information	Service Providers	Helping to ensure the security and integrity of Personal Information Performing services on behalf of the businessInternal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our Services

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please click on this link.

Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. Currently, we do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third Party Marketing (“Shine The Light Act”)

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us using the information in the Contact Us section below.

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

14. Your Privacy Rights under Other US State Laws

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have rights under applicable privacy laws once those laws have become effective.

Based on the applicable law in the state where you live, you may have the following rights with respect to your personal data:

To confirm whether or not a controller is processing your personal data and to access such personal data;
To know the categories of personal data we collect about you, the purposes for the collection, how long we retain your personal data, and whether that information is sold or shared or disclosed and to whom;
To know the third parties with whom we share your personal data;
To correct inaccuracies in your personal data;
To delete your personal data;
To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below. Please include your state of residence.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the state in which you are a resident.

We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Right to Opt Out

You may have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

15. Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Notice on this page and will indicate at the top of the page the modified Notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes.

By continuing to use the Site or Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be bound by the Privacy Notice as changed.

16. Contact Us

If you have any questions or suggestions regarding this Notice, please contact us as follows:

Duffy Krospodin, LLP
21600 Oxnard Street, Suite 2000
Woodland Hills, CA 91367-4969

Email: privacy@dk.cpa

Contact number: (818) 385-0585

Privacy Policy

Table of contents

1. Introduction