2.

What information We collect

To put it simply, there are three main ways we collect information about you: (1) when you give it to us, (2) with automatic technologies and (3) when we ask others for it. Allow us to explain.

Information You Choose to Give Us

‍When you interact with the Tickmark Platform, we collect the information that you choose to share with us. For example, use of the Taxfyle Platform requires you to set up a basic account, so we need to collect a few important details about you, such as: a unique username you'd like to go by, a password, an email address, a phone number, your date of birth, a credit card number, and, since you are getting help with tax documents for the government, your Social Security or Tax Identification Number. Other services, such as commerce products, may also require you to provide us with a debit or credit card number and its associated account information. This type of information is Personal Information, that is information that identifies you personally.

Some of the information you choose to give us will be Non-Personal Information, that is information about you or your household that doesn't identify you personally, like your gender, income, or what types of financial products you're interested in.

When we combine information that isn't Personal Information (like Non-Personal Information or Usage Information, which we explain below) with Personal Information, we treat it like Personal Information for as long as it is combined.

Of course, you'll also provide us whatever information you send through the Tickmark Platform, but also any information you might provide when using Help Chat (our customer support vehicle), phone calls with us, or Pro Chat (our vehicle for communications between you and your Third-Party Tax Professional and/or workforce). It probably goes without saying, but we'll say it anyway: When you contact our support team or communicate with us in any other way, we'll collect whatever information you volunteer. It should also be obvious if you are providing information related to tax filings, all information on those filings will be provided to the government.

Information We Automatically Collect

In addition to information you provide to us, we automatically collect certain information about how you access and interact with the Tickmark Platform ("Usage Information"). This Usage Information is a key part of how we improve your experience and provide more personalized insights and recommendations. We and our business partners may use various technologies to collect and store Usage Information in connection with our Services. Here are some types of Usage Information we may collect:

Device Information. This is information about how you access the Tickmark Platform, such as advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number), the operating system and version, hardware model, and application or browser type and version. We may also integrate with built-in device features;

Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with the Tickmark Platform. That information includes, among other things: details about how you've used our services, features of those services, Device Information, access times, pages viewed, IP address, identifiers associated with cookies or other technologies that may uniquely identify your device or browser, pages you visited before or after navigating to our website;

Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). With your consent, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses;

Usage Information. We collect information about your activity through the Tickmark Platform. For example, we may collect information about: how you interact with the services, which search queries you submit; how you communicate with Third-Party Tax Professionals; the time and date of your communications; and the number of messages you exchange;

Content Information. We collect information about the content you provide, such as if the Third-Party Tax Professional has received the content and the metadata that is provided with the content;

Camera and Photos. Many of our services require us to collect images and other information from your device's camera and photos. For example, you won't be able to upload photos, say of your W-2 or other tax forms, from your camera roll unless we can access your camera or photos;

Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners, such as commerce features. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services through the Tickmark Platform.

Information Third Parties Provide About You

‍Some of our features may rely on information about you that we collect from third parties, such as the third-party tax documents, and other work-related documents, provided by you and possibly from your linking to one or multiple of your financial accounts through third-party account aggregation services. We may also work with different third-party data partners to supplement the Usage Information and other information we collect directly from you. For example, our business partners may provide us with information about special offers available based on your profile so that we can give you more personalized recommendations. We might also collect information from other users like you through things like a member referral program.

How We Use the Information We Collect

‍We use the information we collect from you and third parties to operate the Tickmark Platform, improve our Services, communicate with you and the providers, conduct research and development to improve or enhance our services and our users' experience, and promote our services. Here are a few examples of how we do this:

Providing features like referrals for tax preparation engagements. When you register for a member account, we use the Personal Information you provide in order to create and maintain your member profile and connect you with a Third-Party Tax Professional, to assist with your tax preparation engagements, to provide upfront price quotes, and an encrypted communication portal. The information we collect as you use the Taxfyle Platform also goes into developing and bringing you our various other features like account aggregations, encrypted communication channels, customer support, and personalized offer recommendations;

Improving our recommendations and insights. The information we collect also helps us tailor our content and improve the way we match you to Third-Party Tax Professionals, workforces, and recommended offers. We're constantly working on ways to better identify and present the information that's most relevant to you;

Personalizing our services. We use the collected information to monitor and analyze trends and usage; personalize the services by, among other things, suggesting professionals or profile information, or customizing the content we show you; contextualize your experience by, among other things, using your precise location data (if, of course, you've consented to us collecting that data) and applying other labels based on the content; improve ad targeting and measurement;

Improving security. We use the collected information to enhance the safety and security of the Tickmark Platform; verify your identity and prevent fraud or other unauthorized or illegal activity.

Communicating with you. We may use information we collect to provide you with customer support or to send you things like service-related announcements, alerts, recommendations, offers from our business partners and other updates or promotions. Most of the time we'll communicate with you by email, but we may also send you push notifications or even snail mail. For information on how to adjust your communications preferences, check out our aptly named "Communications Preferences" section below;

Data Storage. We may also store some information locally on your device. For example, we may store information as local cache so that you can open the app and view content faster. Your Third-Party Tax Professional, or Your Workforce may also store your information, say in case there is an audit or to speed up the process for future engagements. We may store some of your information, including financial information used to complete your engagements, even after you deactivate your account with us (see below for more detail). It's also possible, as with any digital information, that someone might be able to access information forensically or find them in a device's temporary storage. Keep in mind that, while our systems are designed to carry out our deletion practices automatically, we cannot promise that deletion will occur within a specific timeframe. And we may need to suspend those deletion practices if we receive valid legal process asking us to preserve content or if we receive reports of abuse or other Terms of Service violations. Finally, we may also retain certain information in backup for a limited period of time or as required by law;

Legal reasons. We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:

Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;

Enforce our Terms of Use, including investigating any potential violations;

Protect the safety, integrity, rights or security of our members, our services or equipment, the Tickmark Platform, or any third party; or

Detect, prevent or otherwise address fraud, security or technical issues related to our services or our business partners.‍

When We Share the Information We Collect

First, we want to be clear about how we do not share information about you (what we call the "No-Nos"):

• We do not share your tax documents, or related information, with unaffiliated third parties (except agents acting on our behalf; we explain that below); and
• We do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists.

Now that we've covered the No-Nos, let us explain how we could share with third parties. We may share information about you, including Personal Information, with third parties in the following circumstances:

Agents acting on our behalf. We may share information about you with service providers or agents in order to have them perform any of the activities we conduct under this Privacy Policy and our Terms of Use. This includes things like designing or operating features, helping us research and test feature improvements, identifying offers or personalized recommendations, performing analytics and marketing our services. These third parties are acting on our behalf so while they may have access to your information, including things like your credit reports and scores, they're required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them;

When we collaborate with third parties to provide and improve our Services. We may sometimes share information about you with our business partners or other third parties we collaborate with in connection with providing or improving the Tickmark Platform. This can occur, for example, when we're providing an integrated or co-branded feature with a business partner or doing a joint research project with another organization to help improve our services or the Tickmark Platform. We may also share information like the feedback you submit to us if it relates to both our services and a business partner's products. When we share information with third-party collaborators, our collaborators are obligated to follow the No-Nos above, but may also use the information in connection with their own activities to the extent allowed under their own privacy practices (e.g., respond to your feedback, conduct additional research, or improve a feature of theirs);

Our business partners when you ask for their services. We may also give you opportunities to interact with third-party business partners through the Tickmark Platform. In these situations, we will either tell you we'll be sending your information before we do so or we will send you to the business partner's site or platform for you to provide the information directly to them. Remember that any information you provide to the third-party, whether through us or on your own, will be subject to their privacy practices and terms and conditions;

When you publicly post the information. As part of our services, we may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include Personal Information and portions of your member profile designated as public profile information, like your name or user name. Anything you share in a public forum is, obviously, public, so think carefully about what you decide to share. If you would like us to remove Personal Information included in public posts, contact us at [email protected]. In some cases, we may not be able to remove your Personal Information, but we will try to respond to let you know why;

As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets. If such a business transfer results in a material change in the treatment of your Personal Information, you may be notified by e-mail (using the primary email address on your account) or by a prominent notice on our site;

For Legal Reasons. We may share information about you if we reasonably believe that disclosing the information is needed to: comply with any valid legal process, governmental request, or applicable law, rule, or regulation; investigate, remedy, or enforce potential Terms of Service violations; protect the rights, property, and safety of us, our users, or others; detect and resolve any fraud or security concerns; and

With Your Consent. There may also be other limited contexts in which we share specific types of personal information with your express consent.

3.

Users outside the United States

Although we welcome users from all over the world, keep in mind that no matter where you live or where you happen to access the Tickmark Platform, your information may be shared within the Tickmark family of companies. This means that we may collect your personal information from, transfer it to, and store and process it in the United States and other countries outside of where you live.‍

How to Access, Update or Deactivate Your Account

Accessing and Updating Your Account Information

‍You are responsible for maintaining the accuracy of the information you provide to us, such as your profile information and your responses to our onboarding questions. You can access and make changes to certain Personal Information at any time by logging in to your account through our website or app and updating your "Personal Information."

Communications Preferences

‍You can manage your communications preferences by visiting the Tickmark Platform, and communicating with the customer support team, via the Help Chat, or via email, at [email protected]. Technology moves fast, so the types of communications and communication preference options might change from time to time.

Canceling Your Membership and Deactivating Your Account
‍
‍We hope this never happens, but if you decide you no longer want to use our services, you can cancel and deactivate your account by reaching out to us at [email protected].

One more thing to note: Due to our recordkeeping and information retention requirements, we do not delete information about you upon deactivation. We will, however, disable your account and stop sending you further communications. Furthermore, except to the extent necessary for legal or regulatory recordkeeping purposes, we anonymize the data in your profile two years after you deactivate your account. It may take a little more time for our automated backup systems to fully process the anonymized account, though.

Our Interest-Based Advertisement Practices

Advertising Service Providers

Some of our third-party service providers or business partners are advertising networks, marketing partners, publishers and other entities who perform analytics and advertise our products and services on websites not affiliated with us ("Advertising Service Providers"). In connection with these advertising services, we or our Advertising Service Providers, like Google Analytics (more on this below) may use cookies, web beacons, and similar technologies to collect behavioral information about how you use our site or other websites in order to perform tracking and marketing analytics or serve advertisements that are more likely to be of interest to you ("Interest-Based Advertisements"). Our Advertising Service Providers may permit you to opt out of all or some Interest-Based Advertisements on designated websites. For example, many of our Advertising Service Providers participate in the Network Advertising Initiative opt-out program or the Digital Advertising Alliance opt-out program.

Disclosure Regarding Google Analytics Advertising Features

In addition to services from other Advertising Service Providers, we use the following Google Analytics Advertising Features as part of our marketing analytics and advertising: Remarketing with Google Analytics, Google Display Network Impression Reporting, DoubleClick Platform integrations and Google Analytics Demographics and Interest Reporting. We may also use other services provided by Google Analytics from time to time. Google provides users an opportunity to opt-out of the Google Analytics Features through Google's Ads Settings and their web browser opt-out plugin. For additional information on opting out of interest-based ads by Google, visit here.

Do Not Track Signals

‍At this time, we do not respond to automated signals regarding tracking mechanisms, including "do not track" instructions from your browser. Please note that blocking cookies may affect your browsing experience on many sites and may limit your ability to use certain features of our Services, including many of the personalized features we provide for our members.

Our Security Practices and Social Security Number Protection Policy Statement

‍Taxfyle maintains physical, electronic, administrative and procedural safeguards intended to protect the confidentiality of Personal Information that we collect about you, including Social Security Numbers. We limit access to Social Security Numbers to help protect against their loss or misuse and we do not disclose Social Security Numbers to third parties, except for Third-Party Tax Professionals, except where such disclosure is required or permitted by law.

If you have any questions about security on the Taxfyle Platform, you can send an email to us at [email protected].

Changes to Our Privacy Policy

‍We reserve the right to change this Privacy Policy at any time without notice to you. If there are any material changes in the way we provide the services, manage the Taxfyle Platform in a way that affects your privacy, or the way we treat Personal Information, Taxfyle may send a notice to the primary email address on your account, make a change on this page, or place a notice on our platform before the change goes into effect. Taxfyle will also promptly make an updated Privacy Policy publicly available on our platform. Changes will be effective as soon as the revised Privacy Policy is posted unless otherwise stated.

Want More Information?

‍Thanks for taking the time to read through all this. If you have questions regarding this policy or privacy practices at Tickmark, you can email us at [email protected] or write to us at: Tickmark, Inc. Attention: Legal Department, 2901 Florida Avenue, Suite 840, Miami, Florida, 33133.

4.

Additional California Privacy Disclosures

THE FOLLOWING IS RELEVANT ONLY TO RESIDENTS OF CALIFORNIA

‍Effective as of January 1, 2020

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as described in under the CCPA).

This supplement provides additional privacy disclosures and informs you of your additional rights as a California resident, and should be read in conjunction with our Privacy Policy.

Personal Information Collected and Processed

‍Please refer to our Privacy Policy which sets forth the type of information Tickmark, Inc. collects and processes from you, as well as a description of each category of information and where we get that information from.

Requests to Exercise your Rights

RIGHT TO KNOW REQUEST - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

4.2.1 Categories of and specific pieces of personal information we have collected about you.
4.2.2 Categories of sources from which we collect personal information.
4.2.3 Purposes for collecting, using, or selling personal information.
4.2.4 Categories of third parties with which we share personal information.
4.2.5 Categories of personal information disclosed about you for a business purpose.

If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for more information we have collected about you, please contact our Customer Service department and request a copy of your data, or email us at [email protected].

RIGHT TO DELETE REQUEST - You also have a right to request that we delete your personal information, subject to certain exceptions. You may exercise this right by contacting Customer Service or emailing us at [email protected].

HOUSEHOLD REQUESTS - We currently do not collect household data. If all the members of a household makes a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

REQUESTS, GENERALLY - Note, if you have not used Taxfyle, or have not submitted any information to Tickmark, Inc. to process any of your taxes or other information, we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information to relink you to any previous usages or simple visits to our platform. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

REQUESTS MADE THROUGH AGENTS - You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

‍In the preceding 12 months, Tickmark, Inc. has disclosed certain data from the following categories of personal information to the recipients listen in our Privacy Policy for one or more business purposes:

• Personal Information you Share with us as part of your use of our platform
• Usage Information
• Device Information
• Log Information
• Location Information
• Content Information
• Camera and Photos
• Information Collected by Cookies and Other Technologies

For more details on the information we collect from you, please refer to our Privacy Policy.

Sale of Personal Information

‍Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA, and have maintained that we do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists.

Contact Us

‍You may contact us by emailing us at [email protected] or using the “Contact Us” feature on our website.