Privacy & Data Security

Effective Date: January 1, 2025 | Last Reviewed: June 2026

Your privacy is the bedrock of our CPA and Enrolled Agent practice. As federally‑authorized tax professionals, we are bound by the Gramm‑Leach‑Bliley Act (GLBA), Internal Revenue Code §7216, IRS Publication 4557, the AICPA Code of Professional Conduct, and all applicable state data protection laws. This policy explains in exhaustive detail how we collect, use, protect, share, and retain your non‑public personal information (“NPI”) when you engage our firm for tax preparation, accounting, or advisory services.

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1. Information We Collect

We adhere to the data minimization principle, collecting only the personal information necessary to fulfill our engagement, comply with IRS e‑file requirements, and meet professional standards. Below is a comprehensive breakdown of the categories and specific data elements we may process.

1.1 Identity & Personal Data

1.2 Financial & Tax Data

1.3 Technical & Portal Data

1.4 Data We Do Not Collect

We do not request or knowingly process sensitive categories of data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data for identification, health information beyond what is required on tax forms (and only if voluntarily supplied), or information about sex life or sexual orientation. If such data is inadvertently included in documents you provide, we will not use it for any purpose and will advise you to redact it.

1.5 Sources of Information

We collect information directly from you (via secure portal uploads, intake forms, email, phone, or in‑person meetings), from your authorized representatives (e.g., spouse, power of attorney), and from third parties with your consent (e.g., prior tax preparers, financial advisors, IRS transcripts via Form 8821). We also generate data internally, such as tax calculations, workpapers, and engagement notes.

2. How We Use Your Information

Every use of your NPI is tied directly to the professional services you have engaged. We do not use your data for secondary purposes without explicit consent. The following list details all processing activities:

Prohibition on Secondary Use: Under IRC §7216 and AICPA Ethics Rule 1.700.001, we are prohibited from using your tax return information for any purpose other than the preparation of your return without your explicit, written consent. This includes marketing other services, selling information to third parties, or sharing with affiliates.

Consent for Specific Uses: If we ever wish to use your data for a purpose not covered by this policy (e.g., a client testimonial or case study), we will obtain a separate, signed consent form compliant with IRS regulations (Form 7216 consent).

3. Information Sharing & Subprocessors

We share your NPI only with trusted service providers and only to the extent necessary. All providers are contractually bound to confidentiality and security standards at least as protective as our own. We do not sell your data.

3.1 Categories of Third‑Party Recipients

3.2 Current Subprocessors Table

Provider Purpose Data Accessed Certification / Location
Professional Tax Software (e.g., Intuit ProConnect, Drake, UltraTax)Tax calculation & e‑fileAll tax data, SSNSOC‑2 Type II, USA
Stripe, Inc.Payment processingTokenized card info, amountPCI‑DSS Level 1, USA
Google Workspace / Microsoft 365Email, calendar, secure storageEmail content, attachmentsSOC‑2, USA
DocuSign / similar e‑signatureElectronic signaturesName, email, IPSOC‑2, USA
Encrypted Cloud Storage (e.g., Box, Dropbox Business)Workpaper & document retentionAll client documentsSOC‑2, USA

We do not transfer personal data internationally for core tax processing. In the rare event that data must transit through a non‑US server, it remains encrypted and protected by adequate safeguards. A complete and up‑to‑date subprocessor list is available upon request.

3.3 No Sale or Sharing for Advertising

We do not sell, rent, or trade your personal information to any third party for monetary or other valuable consideration. We do not share data for cross‑context behavioral advertising.

4. Data Security Measures

Our information security program is modelled after NIST SP 800‑171, the IRS Publication 4557 “Safeguarding Taxpayer Data” guide, and the GLBA Safeguards Rule. We implement administrative, technical, and physical safeguards to protect your data.

4.1 Technical Controls

4.2 Administrative Controls

4.3 Physical Controls

4.4 Your Role

You are responsible for maintaining the confidentiality of your portal credentials. Use a strong, unique password and enable MFA where available. Notify us immediately if you suspect unauthorized access to your account.

5. Data Retention & Destruction

5.1 Retention Periods

In accordance with IRS Revenue Procedure 97‑22, AICPA professional standards, and applicable statutes of limitation, we retain the following records:

5.2 Destruction Process

Upon expiration of the retention period, records are securely destroyed in a manner that renders them permanently unreadable:

Early Deletion Requests: Due to legal retention obligations, we cannot delete tax return information before the retention period expires. Non‑tax‑related data (e.g., contact details, general correspondence) can be deleted upon request, subject to our recordkeeping policies.

6. Your Rights & How to Exercise Them

Depending on your jurisdiction, you have the following rights regarding your personal data. We will honor all verifiable requests to the extent permitted by law and professional requirements.

6.1 Right to Access

You may request a copy of the personal information we hold about you. We will provide this in a commonly used electronic format within 45 days. A reasonable fee may be charged for excessive requests.

6.2 Right to Rectification

If you believe any information is inaccurate or incomplete, you have the right to have it corrected. We will update our records promptly upon verification.

6.3 Right to Deletion (Erasure)

You may request deletion of your personal data. However, we cannot delete information that is part of an active or past tax filing until the retention period expires, or that is otherwise required to be maintained by law (e.g., IRS recordkeeping, AML). For data not subject to such requirements, we will comply with deletion within 45 days.

6.4 Right to Restrict Processing

Under certain conditions, you can ask us to limit how we process your data. This may apply if you contest accuracy, the processing is unlawful, or you object to processing.

6.5 Right to Data Portability

You can request a copy of your tax data in a structured, commonly used, machine‑readable format (e.g., PDF, CSV of transaction data).

6.6 Right to Object

You can object to processing of your data for direct marketing (which we do not engage in) or in certain other circumstances.

6.7 Right to Non‑Discrimination

We will not discriminate against you for exercising any of your privacy rights. This includes denying services, charging different prices, or providing a different level of service.

6.8 Right to Opt‑Out of Sale/Sharing

We do not sell personal information, so an opt‑out mechanism is unnecessary. However, we respect all legal opt‑out preference signals where required.

6.9 How to Submit a Request

Email business@yellowbusinessservices.com or call (917) 997‑9255. We may ask for identity verification (e.g., confirm SSN last four, date of birth, or signed request) to protect your data. An authorized agent may submit a request on your behalf with written permission.

We will respond within 45 days, with a possible 45‑day extension if reasonably necessary (you will be notified).

7. Client Responsibilities

Protecting your data is a shared responsibility. As a client, you agree to:

8. GLBA & IRS §7216 Compliance

8.1 Gramm‑Leach‑Bliley Act (GLBA)

Our firm is a “financial institution” under the GLBA. We comply with both the Financial Privacy Rule (15 U.S.C. §§ 6801‑6809) and the Safeguards Rule (16 C.F.R. Part 314). This includes:

8.2 Internal Revenue Code §7216

IRC §7216 and Treasury Regulations §301.7216‑1 et seq. prohibit any tax return preparer from using or disclosing a client’s tax return information for any purpose other than the preparation of the return without the client’s explicit, written consent. Our firm:

8.3 IRS Publication 4557

We follow the security recommendations in IRS Publication 4557, “Safeguarding Taxpayer Data,” including employee background checks, malware protection, secure document disposal, and keeping operating systems patched.

9. AICPA Code of Professional Conduct

As a firm operating under the ethical standards of the American Institute of Certified Public Accountants (AICPA), we adhere to the Code’s confidentiality requirements, especially:

We treat all client information, whether oral, written, or electronic, as confidential. This obligation continues even after the client relationship ends.

9.1 Peer Review & Quality Control

We may be subject to AICPA‑sponsored peer reviews or other quality control inspections. In such cases, reviewers are bound by confidentiality agreements and will not disclose client‑specific information.

10. Breach Notification

We maintain a detailed Incident Response Plan. In the unlikely event of a security breach involving your NPI:

We carry cyber liability insurance to cover the costs associated with notification, credit monitoring, and legal defense.

11. Children’s Privacy & COPPA

Our services are not directed at children under the age of 13, and we do not knowingly collect personal information from children. If we become aware that we have inadvertently received data from a child under 13 without parental consent, we will delete it immediately. We comply with the Children’s Online Privacy Protection Act (COPPA) where applicable.

For dependents under 18 listed on a tax return, we collect only the information required by the IRS and treat it with the same confidentiality as all client data.

12. International Data Transfers

While our services are primarily for U.S. domestic taxpayers, we also serve U.S. citizens living abroad and certain non‑resident aliens with U.S. filing obligations.

12.1 Transfers Outside the U.S.

Core tax processing and data storage occur within the United States. If data must be transferred internationally (e.g., if you reside abroad and we correspond), it remains protected by the same encryption and contractual safeguards.

For clients in the European Economic Area (EEA), the UK, or Switzerland, we ensure adequate safeguards for such transfers, typically through Standard Contractual Clauses (SCCs) or reliance on an adequacy decision where applicable. By engaging our services, you consent to the transfer of your data to the United States for processing.

12.2 Data Subject Rights for Non‑U.S. Residents

If you are located in a jurisdiction with comprehensive data protection laws (e.g., GDPR, UK GDPR, PIPEDA), we extend the same rights described in Section 6, and you may also have the right to lodge a complaint with your local supervisory authority.

13. State‑Specific Privacy Rights

U.S. state privacy laws provide additional rights. Below is a detailed summary. All rights are subject to applicable exemptions (e.g., GLBA, IRS data).

13.1 California (CCPA/CPRA)

13.2 Virginia (VCDPA)

13.3 Colorado (CPA), Connecticut (CTDPA), Utah (UCPA)

Similar rights to Virginia, with minor variations. We honor all applicable rights. For details specific to your state, please contact us.

13.4 Nevada (NRS 603A)

We do not sell covered information. You may still submit a verified opt‑out request, which we will honor.

13.5 Other States

We comply with all state privacy laws in effect, including those in Oregon, Texas, Montana, Iowa, Delaware, Tennessee, Indiana, Florida, and any others as they come into force. Contact us for a jurisdiction‑specific addendum.

Do Not Track Signals: Our website does not respond to browser DNT signals because no consistent industry standard exists. You can manage cookies via browser settings.

14. Cookies & Tracking Technologies

We use minimal cookies and analytics to ensure site functionality, security, and continuous improvement.

Cookie / Technology Purpose Duration Type
PHPSESSIDSession management, CSRF tokenSessionEssential
_ga, _ga_* (Google Analytics 4)Anonymized site usage analytics2 yearsAnalytics
_clck, _clsk (Microsoft Clarity)Anonymized user interaction recording1 yearAnalytics
__stripe_mid, __stripe_sid (Stripe)Fraud prevention for payments1 year / 30 minEssential (fraud)

You can block or delete cookies through browser settings. Note that disabling essential cookies may prevent the scheduling form and payment functions from working. We do not use tracking for advertising or profiling.

15. Data Inventory & Classification

We maintain a detailed data inventory that maps all personal data we collect, process, and store. Data is classified into three tiers:

This classification drives our security controls, retention schedules, and incident response priorities. The inventory is reviewed and updated annually or upon significant change.

16. Privacy Impact Assessments (PIA)

We conduct a Privacy Impact Assessment whenever we introduce a new system, process, or third‑party service that involves the collection or processing of NPI. The PIA evaluates:

Our most recent PIA was completed in January 2025 and covered our online scheduling system and client portal integration. PIAs are retained and available for review by regulatory bodies upon request.

17. Business Continuity & Disaster Recovery

We maintain a Business Continuity Plan (BCP) and Disaster Recovery Plan (DRP) to ensure the availability and integrity of your data during unexpected events.

In the event of a disaster, your tax records remain protected and retrievable, ensuring we can meet filing deadlines and regulatory obligations.

18. Employee Confidentiality & Training

All employees and contractors sign confidentiality agreements as a condition of employment. These agreements prohibit the disclosure or misuse of client information, even after termination of employment.

18.1 Training Program

19. Vendor & Third‑Party Risk Management

We assess all third‑party service providers before engagement and annually thereafter. The assessment covers:

Contracts with subprocessors include data protection addenda, confidentiality clauses, and audit rights. We maintain a registry of all active third‑party relationships.

20. Data Subject Request Procedures

We have established a formal process to handle privacy requests efficiently:

  1. Receipt: Request received via email, phone, or mail. Logged with timestamp.
  2. Identity Verification: We may ask for proof of identity (e.g., government ID, knowledge‑based questions).
  3. Assessment: Determine applicability (e.g., whether data is subject to legal holds or retention obligations).
  4. Fulfillment: Provide access, correction, deletion, or other action within 45 days.
  5. Communication: Respond in writing, documenting the action taken or explaining any denial.
  6. Appeal: If denied, you may request an internal review, which we will complete within 45 days.

21. Record of Processing Activities (ROPA)

We maintain a Record of Processing Activities as required by certain state laws and as a best practice. The ROPA documents:

The ROPA is reviewed quarterly and updated as needed.

22. Consent Management

Where processing is based on consent (e.g., use of testimonials, marketing communications), we obtain explicit, informed consent via a clear affirmative action. You may withdraw consent at any time by contacting us. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

For tax‑related processing, consent is not the primary legal basis; rather, it is the necessity to perform the engagement contract and compliance with legal obligations.

23. Professional Notices & Legal References

23.1 Circular 230

Any U.S. tax advice contained in this communication (including this website) is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending any transaction or matter addressed herein.

23.2 No Legal Advice

This privacy policy does not constitute legal advice. For legal questions regarding your data protection rights, consult an attorney.

23.3 Governing Law

This policy and all privacy‑related matters are governed by the laws of the State of New York (and Mississippi, as applicable), without regard to conflict of law principles, and applicable federal laws of the United States. Any disputes shall be resolved in the courts of New York County, New York.

23.4 Key Legal References

24. Changes to This Policy

We may update this policy periodically. The latest version will be posted here with a revised “Effective Date.” For material changes, we will provide prominent notice on our website homepage and, for active clients, a direct email notification at least 30 days before the change takes effect (where feasible). Your continued use of our services after the effective date constitutes acceptance of the updated policy. We encourage you to review this page annually.

Historical versions of this policy are available upon request.

25. Contact & Complaints

If you have questions about this policy, wish to exercise your rights, or need to report a privacy concern, contact our Privacy Officer:

Privacy Officer: Pradip Dubaria, Enrolled Agent
Email: business@yellowbusinessservices.com
Phone: (917) 997‑9255
Mailing Address: Yellow Business Services Co., 1450 Broadway, New York, NY 10018 (and 3900 Lakeland Drive, Flowood, MS 39232)

If you are dissatisfied with our response, you may file a complaint with the Federal Trade Commission (FTC), the IRS Taxpayer Advocate Service, your state Attorney General, or (for EU/UK residents) your local data protection authority.

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