Privacy Policy

1. Introduction and Our Commitment to Privacy

Torres & Associates CPA ("we," "us," "our," or the "Firm") is committed to protecting the privacy and confidentiality of our clients' personal and financial information. As a Certified Public Accounting firm, we are bound by professional standards of confidentiality established by the American Institute of Certified Public Accountants (AICPA) and applicable state CPA societies, which are often more stringent than those required by law.

This Privacy Policy describes how we collect, use, protect, and disclose nonpublic personal information ("NPI") about our current and former clients in connection with the accounting, tax preparation, financial advisory, and related professional services we provide.

2. Scope of This Policy

This Privacy Policy applies to all individuals who:

• Are current or former clients of Torres & Associates CPA
• Visit our website or online platforms
• Contact us for information about our services
• Provide personal information to us in connection with our professional services

3. Information We Collect

3.1 Nonpublic Personal Information (NPI)

In the course of providing professional accounting and tax services, we collect and maintain nonpublic personal information about our clients. NPI is defined as personally identifiable financial information that is not publicly available. This includes:

• Personal Identifiers: Name, address, telephone number, email address, date of birth, Social Security Number, driver's license number, and other government-issued identification numbers
• Financial Information: Income, assets, liabilities, bank account numbers, investment account information, credit card information, tax return data, and financial statements
• Employment Information: Employer name, W-2 forms, employment income, and benefits information
• Business Information: Business financial records, partnership agreements, corporate documents, and entity information
• Transaction Data: Payment history, service agreements, and billing records

3.2 Sources of Information

We collect nonpublic personal information from the following sources:

• Information you provide directly to us: On engagement letters, tax organizers, questionnaires, and other forms you complete
• Documents you provide: W-2s, 1099s, brokerage statements, bank statements, receipts, and other financial documents
• Third parties with your authorization: Financial institutions, employers, government agencies (such as the IRS), and other professionals acting on your behalf
• Website interactions: Through secure client portals, contact forms, and email communications

3.3 Sensitive Personal Information

In certain circumstances, we may collect sensitive personal information, including Social Security Numbers, financial account credentials, and tax identification numbers. This information is collected only when necessary to provide our professional services and is subject to enhanced security protections as described in this policy.

4. How We Use Your Information

We use your nonpublic personal information solely for the following business purposes:

• To prepare and file tax returns and other required governmental filings
• To provide accounting, bookkeeping, and financial statement services
• To offer tax planning and financial advisory services
• To respond to inquiries from tax authorities on your behalf
• To communicate with you about your account, services, and billing
• To comply with legal and regulatory requirements
• To maintain our internal records and quality control processes

5. Information Sharing and Disclosure

5.1 Our Policy on Sharing

Torres & Associates CPA maintains a strict policy of confidentiality. For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our practice except as required or permitted by law, or with your express written consent.

5.2 Permitted Disclosures

We may disclose your nonpublic personal information in the following limited circumstances:

• With your consent: As authorized by you, such as filing tax returns with the IRS and state tax authorities, or sharing information with your attorney, financial advisor, or other professionals
• To service providers: To companies that perform services on our behalf, such as our IT providers, secure document storage providers, and tax software vendors, who are contractually bound to maintain confidentiality
• For legal compliance: In response to a valid subpoena, court order, regulatory examination, or as otherwise required by law
• To professional oversight bodies: To state boards of accountancy, the AICPA, or state CPA societies in connection with peer reviews, ethics inquiries, or disciplinary proceedings
• To firm employees: To our employees and staff members who need access to provide services to you

5.3 Information We Do Not Share

6. Data Security

Protecting your information is a priority for our firm. In compliance with the FTC Safeguards Rule and industry best practices, we maintain a comprehensive Written Information Security Plan (WISP) that includes administrative, technical, and physical safeguards to protect the confidentiality, integrity, and availability of your information.

6.1 Administrative Safeguards

• Designation of a qualified individual responsible for overseeing our information security program
• Regular employee training on data security and privacy practices
• Periodic risk assessments to identify and address security threats
• Vendor due diligence and contractual requirements for service providers
• Incident response procedures for potential security events

6.2 Technical Safeguards

• Encryption of sensitive data in transit and at rest
• Multi-factor authentication for access to client information
• Secure firewalls and intrusion detection systems
• Regular software updates and security patches
• Secure client portals for document exchange
• Anti-virus and anti-malware protection

6.3 Physical Safeguards

• Secured office premises with restricted access
• Locked storage for physical documents containing sensitive information
• Secure destruction of documents when no longer needed
• Visitor management procedures

7. Data Retention

We retain client records and nonpublic personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory requirements, and support our professional obligations. Our general retention practices include:

• Tax Returns and Supporting Documents: Minimum of seven (7) years from the date of filing, or longer if required by specific circumstances
• Financial Statements and Work Papers: As required by professional standards and applicable law
• Client Communications: As necessary for ongoing client service and professional requirements

When client information is no longer needed, we dispose of it securely using appropriate methods such as shredding for physical documents and secure deletion for electronic records.

8. Your Privacy Rights

Depending on your state of residence, you may have certain rights regarding your personal information under applicable privacy laws, including the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act, Colorado Privacy Act, and other state privacy statutes.

8.1 Rights Under State Privacy Laws

Subject to applicable law and certain exemptions, you may have the right to:

• Right to Know: Request information about the categories and specific pieces of personal information we have collected about you
• Right to Delete: Request deletion of your personal information, subject to certain legal and professional retention requirements
• Right to Correct: Request correction of inaccurate personal information
• Right to Data Portability: Receive your personal information in a portable and readily usable format
• Right to Opt-Out: Opt-out of the sale or sharing of your personal information (Note: We do not sell or share personal information for cross-context behavioral advertising)
• Right to Non-Discrimination: Not be discriminated against for exercising your privacy rights

8.2 Exercising Your Rights

To exercise any of these rights, please contact us using the information provided in Section 11 of this policy. We will verify your identity before responding to your request and will respond within the timeframes required by applicable law. In some cases, we may be unable to fulfill your request due to legal, regulatory, or professional requirements that require us to retain certain information.

8.3 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require the authorized agent to provide written proof of authorization and may verify your identity directly.

9. Tax Return Information (IRS Section 7216)

As a tax return preparer, we are subject to Internal Revenue Code Section 7216 and Treasury Regulations thereunder, which impose specific requirements regarding the disclosure and use of tax return information. These regulations generally prohibit us from disclosing or using your tax return information for any purpose other than preparing your tax return without your prior written consent.

10. Website and Online Privacy

10.1 Information Collection Through Our Website

When you visit our website, we may automatically collect certain technical information such as your IP address, browser type, device information, and pages visited. This information is used to improve our website functionality and user experience.

10.2 Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your browsing experience. You can control cookie settings through your browser preferences. Essential cookies required for website functionality may not be disabled.

10.3 Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

10.4 Client Portal Security

We provide a secure client portal for document exchange and communication. This portal uses encryption and authentication measures to protect your information. You are responsible for maintaining the confidentiality of your login credentials.

11. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about our handling of your information, please contact us:

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or professional standards. When we make material changes, we will notify you by posting the revised policy on our website and updating the effective date. We encourage you to review this policy periodically.

For significant changes that affect how we handle your previously collected information, we will provide you with direct notice and, where required by law, obtain your consent.

13. Acknowledgment

By engaging our services, you acknowledge that you have read and understand this Privacy Policy. Your privacy, our professional ethics, and our ability to provide you with quality accounting services are very important to us. We are committed to maintaining the confidentiality and security of your information.

This Privacy Policy is provided in compliance with the Gramm-Leach-Bliley Act (GLBA), the FTC Safeguards Rule, the California Consumer Privacy Act (CCPA), the Colorado Privacy Act (CPA), the Virginia Consumer Data Protection Act (VCDPA), Internal Revenue Code Section 7216, and the AICPA Code of Professional Conduct.