Untracht Early LLC and its affiliates have always been committed to maintaining client confidentiality. We appreciate this opportunity to clarify our privacy practices for you.

Introduction & Scope

This Privacy Statement sets forth the principles under which Untracht Early collects, uses, processes, retains, and discloses personal and/or sensitive data. This Privacy Statement covers information received in electronic or other formats.

The terms “we”, “us” and “our” refer to Untracht Early, and its officers, directors, owners, employees, authorized third parties and agents. The terms “you” and “your” refer to you, your business, any officers, directors, owners, employees, authorized third parties and agents.

We may update this Privacy Statement from time to time by publishing a new version on our website. We may or may not notify you about changes by mail or email, so you should check back here regularly to review this Privacy Statement for possible changes.

Privacy of Children Who Visit the Website
We recognize the importance of children’s safety and privacy. The website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use this website or our Services.

Note for Individuals in the European Union (“EU”) or the European Economic Area (“EEA”)
There are certain provisions of this Privacy Statement that only apply to individuals from the EU or EEA. Those sections are denoted as “EU/EEA Data Subjects Only”.

What Information and Personal Data We Collect

We may collect various types of information and personal data about you or your business to enable us to provide the services for which we were retained. As used herein and in connection with our business the term personal data and information may include, but is not limited to, the following: Names and contact information, social security number and/or other identification numbers, financial information about you and your interests, and operational information (transactions with Untracht Early such as billing and payment history, correspondence)

Depending on the services we provide and in so far as it relates to those services, personal data and information we collect may also include gender, nationality, dates of birth, marital status, relevant matters which may involve your family, occupation and related history, incidental health information about you and/or your family, insurance information, or any other similar information provided to us by you or your company in connection with our services.

Information and Personal Data We Do Not Collect

We ask that you do not supply the following to us:

● Any information or personal data that is not necessary in rendering our services;
● Any information or personal data that have not been explicitly requested by Untracht Early;
● Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by Untracht Early to provide;
● Any information or personal data where you are under any legal obligation to not provide to or share with Untracht Early; and/or
● Any information or personal data related to race, ethnicity, religion, political opinion, trade unions, genetic or biometric data, health (except to the extent explicitly requested by us) or mortality information, or sexual orientation.

How We Collect Information and Personal Data

We collect information and personal data from you in written form, by phone, online, by mail or email, and in personal interviews and consultations conducted by us, as well as by information we collect from others with your authorization. Below are some examples:

● You upload documents to our client portal;
● You fill out forms, questionnaires, tax organizers;
● You send or respond to an e-mail;
● You provide information via phone or in person;
● You mail us documents;
● You use or access our website;
● You provide us access to online bank, brokerage, vendor or other accounts;
● Your employer, an entity in which you invest or own an equity interest, an entity you are employed by, or a third party service provider that you work with (including a fund, investment vehicle, or third party administrator) provides us with information through any of the above means; and/or
● You provide us with information in connection with seeking employment.

Why We Collect Information and Personal Data

Untracht Early processes your information and personal data to perform our professional services (https://www.untracht.com/services/) and also to manage our business and update our own records (i.e., employment matters, billing and collections, and our own tax, accounting, and business needs). When engaging with Untracht Early, you hereby consent that we may use your information and personal data. The legal basis for processing your information and data is your consent set forth herein, as well as our contractual obligations outlined in an engagement letter.

We may use your information and personal data where necessary or advisable for purposes of managing risks, obtaining professional advice, or for the establishment, exercise and/or defense of legal claims (whether in court proceedings or alternative dispute resolution), compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. The legal basis for this processing is our legitimate interests, namely the protection and assertion our business against risks and of our legal rights, your legal rights and the legal rights of others.

Last, we may use your information and personal data for fraud and crime prevention, any statutory, legal or regulatory compliance that we are subject to, including but not limited to compliance with any CPA professional standards or rules set forth by the American Institute of Certified Public Accountants, the Internal Revenue Service, the PCAOB, Boards of Accountancy where we are registered, internal or external audits, peer review, and any other purpose for which valid consent is obtained.

EU/EEA Data Subjects Only

With respect to our professional services, we primarily act as a “data processor”, which is a person or entity who processes data on behalf of a “data controller”. Our clients are primarily considered the data controllers. A “data controller” is a person or entity who determines the purposes and means (the why and how) by which data is processed. “Processing” means any operation(s) performed on data, including but not limited to collection, organization, recording, saving or storage, altering or usage, deletion or destruction, disclosure, transfer or otherwise making such information or personal data available. The primary exception to this rule is that we may act as a data controller when our professional and ethical obligations require us to do so (i.e., when we have an affirmative obligation to take certain actions even if not directed to do so by another data controller).

Parties To Whom We Disclose Information

As a general rule, we consider all of your information and personal data highly confidential, unless it is considered public information. We are generally prohibited from disclosing information without your specific consent. As tax preparers, we are prohibited by Internal Revenue Code Section 7216 from disclosing your income tax return information without consent, other than for preparing (or assisting in preparing), obtaining and providing services in connection with the preparation of an income tax return on your behalf. We do not sell your information or personal data to third parties.

Our employees and authorized third party independent contractors, if any, may use your information and personal data in conjunction with us solely to provide professional services to you. Their right to further disclose and use the information is limited by our code of professional conduct, our firm policies and procedures, applicable law, and nondisclosure agreements we may have in place with you. We will only disclose information to non-affiliated third parties as authorized by you for a specific purpose or as specifically set forth herein.

We may disclose certain information and personal data to our insurance providers or to comply with CPA professional standards or rules set forth by the American Institute of Certified Public Accountants, the Internal Revenue Service, the PCAOB, Boards of Accountancy where we are registered, internal or external audits, and/or peer review.

Depending on the type of professional services we provide to you, your information or personal data could be stored in the systems or products of one or more third party software or cloud vendors that we utilize to provide professional services. We use reasonable best efforts to consider information security implications and the security postures/environment of these vendors before engaging with them.

For more information how these software and cloud vendors might impact you, specifically which systems, products, and vendors might house your personal data, please contact us. Our contact information is below.

EU/EEA Data Subjects Only

By providing your personal data to us and using our professional services, you are agreeing to the transfer and processing of your personal data to and in the United States in accordance with this Privacy Statement.

California Privacy Rights

In general, we do not share your information with third parties for direct marketing purposes. However under California law, if you are a resident of the state of California (USA), you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost free means to opt out of sharing your information with third parties, if the third party will use such information for its direct marketing purposes.

If you would like to exercise your rights under California law, please send your written request to us. Our contact information is below.

How We Keep Information Safe and Secure

We maintain various physical, electronic, and policy/procedural safeguards to guard your information and personal data. These may include keycard access systems, firewalls, antivirus/antimalware and other end point protection, intrusion detection and data loss prevention systems, web filters, spam/quarantine filters, mobile device management, two factor authentication, disaster recovery / backup systems, encrypted methods of exchanging information, cyber liability insurance, information security policies, training and anything else we deem appropriate.

We perform background checks on all new employees. Cyber and information security training is provided to all new hires and then annually to all employees.

All employees must adhere to Untracht Early’s information security policies and they may be subject to disciplinary action for failure to comply, up to and including termination.

How Long We Keep Information

We will not keep or retain any information and personal data longer than necessary. As an accounting firm, we have obligations to comply with our various professional standards and must retain documentation necessary to support our work and items of continuing significance (workpapers, backup, calculations, copies of original documents, opinions, resolutions of differences, conclusions, research, correspondence with clients, etc.). Tax returns and other finished work we provide may be subject to various statutes of limitations (time periods for bringing action) with various tax and other authorities.

In general, non permanent file records that include your information and personal data will be retained for a period of seven (7) years. Permanent file records will be retained indefinitely and reviewed periodically for relevance, where they would then only be kept for seven (7) years after the last relevant reporting period or date of such permanent file record. In certain circumstances, records containing information and personal data may be retained longer than seven (7) years (e.g., in the event of litigation or legal matters (actual, pending or threatened), a regulatory exam or investigation, an insurance claim, etc.).

After a retention period has expired, as soon as reasonably practical to do so, paper documents and records will be destroyed and electronic documents or records will be deleted from the medium where they are stored.

Use of Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and on your computer and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, which is also stored on your computer, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. Essential website cookies are strictly necessary to provide you with services available through our website and to use some of its features.

Accessing our website at www.untracht.com will prompt you whether or not to allow us to set cookies on your device. You have the choice whether or not to allow them, although by not accepting cookies, the functionality and appearance of our website may be reduced or limited. Changes will take effect once you reload the page on the website. We use cookies to let us know when you visit our website, how you interact with us, to enrich your user experience, and to customize your relationship with our website. Certain third party service providers may collect cookies when you visit our website. We use Google Webfonts, Google Maps, and Vimeo and YouTube video external services which are embedded in our website. We use these solely to analyze the use of our website. Since these providers may collect personal data like your IP address we allow you the choice whether or not to allow them.

Edit your cookie preferences here:

Google Tracking: 

Google Webfonts Settings:

Google Maps Settings:

Vimeo and Youtube video embeds:

Your Rights

EU/EEA Data Subjects Only

If you are natural person residing in the European Union (EU), and depending on whether Untracht Early is acting as a data processor or data controller, you may have certain rights available to you as set forth below. Some of the rights are complex, and not all of the details have been included in our summary below. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

● the right to access
● the right to rectification
● the right to erasure
● the right to restrict processing
● the right to object to processing
● the right to data portability
● the right to complain to a supervisory authority
● the right to withdraw consent under certain circumstances

You have the right to confirmation as to whether or not we process your personal data and where, including access to the personal data together with certain additional information such as the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing where no other legitimate basis for retention exists; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal or professional obligation (including contractual obligations or our professional standards as a public accounting firm); or for the establishment, exercise or defense of legal claims.

In some circumstances you may have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Contact Us

If you have any questions about this privacy policy, your rights as an EU/EEA data subject or wish to exercise any of them, you may contact us in writing at:

Via Email:
privacy@untracht.com

Via Mail:
Untracht Early, LLC
Attention: Privacy Officer
325 Columbia Turnpike, Suite 202
Florham Park, NJ 07932
United States of America