Welcome to De Bedout  LLC’s client privacy notice. This privacy notice applies to the processing of personal data by De Bedout CPA(“De Bedout ”, “we” or “us”) in connection with any client services or in preparation for providing such services, whether those services are performed or planned to be performed for individuals or businesses.  Any reference to “client” hereunder refers to personal data of such client’s employees, staff and other contacts of client whose details we process when providing the services.  References to “you” made herein are references to the data subject whose personal data is being processed by De Bedout , and also to the business client entity, as applicable.

If you provide personal information of any individual other than yourself to De Bedout , it is your responsibility to ensure that you provide a copy of this notice to each data subject whose data is processed by us.

De Bedout respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please note that there is a Glossary at the end of this document, to help you understand the meaning of some of the terms used in this privacy notice.

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how De Bedout  collects and processes your personal data, including any data you may provide to us when you engage us to provide our services to you.

Our services are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice, privacy policy, or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, initials, marital status, title, digitized, electronic or scanned signatures, social security number, company name.

Contact Data includes billing address, delivery address, email address, and mobile, fax and telephone numbers.

Financial Data includes bank account and routing number and ACH instructions.

Transaction Data includes details about payments to and from you and other details of services you have engaged us to provide to you.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose.  Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we agree to treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data (as defined in the GDPR) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) to provide our services. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide our services). In this case, we may have to cancel a service you have engaged us to provide but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you engage us to provide services.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Contact, Financial, Transaction, Identity and Financial Data from brokers or financial advisors whom you authorize them to send us information.

Contact Data and Financial Data from our payment processors, if you use one of them to process a payment you may owe us for services rendered.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data.  You have the right to withdraw consent to marketing at any time by contacting us through the “unsubscribe” feature in any marketing communication we send you.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our data privacy manager if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo register you as a new client(a) Identity(b) ContactPerformance of a contract with youTo process and deliver our services:(a) Manage payments, fees and charges(b) Collect and recover money owed to us(c) Provide professional services to you(a) Identity(b) Contact(c) Financial(d) Transaction(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)To manage our relationship with you which will include notifying you about changes to our terms or privacy notice(a) Identity(b) Contact(a) Performance of a contract with you(b) Necessary to comply with a legal obligationTo make suggestions and recommendations to you about goods or services, or to provide you other information that may be of interest to you(a) Identity(b) ContactNecessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

We may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services or information may be relevant for you (we call this marketing).  As part of our marketing efforts, we may send you electronic communications which may include updates on regulatory issues that we think may be of interest to you, invitations to events we think you may wish to attend, and thought leadership pieces in which we discuss and provide an in depth understanding of legal, regulatory or business specific issues we think might interest you.

You may receive marketing communications from us if you have requested information from us or engaged us to provide services to you, and you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time following the “unsubscribe” links on any marketing message sent to you. **

Where you opt out of receiving these marketing messages, this will not apply to personal data provided as a result of a service we provide to you or to a third party and which may involve your personal data.

Change of purpose

We will only use your personal data consistent with the terms of this privacy notice, and for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details provided in this policy.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the rules contained in this privacy notice, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with certain third parties, as required for the operation of our business, which includes processors and sub-processors.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We contract with our third-party service providers to require that they do not use your personal data for their own purposes and to authorize them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Whenever we transfer your personal data out of the European Economic Area we will endeavor to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

Data retention

How long will you use my personal data for?

We have implemented measures designed to ensure that we not retain your personal data longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Note, however, that if we have a legitimate interest in retaining the data, or if we are required to do so by applicable law, we will retain the data in accordance with our data retention plans and policies.   In doing so, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We generally have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being clients to fulfil our legal obligations. Our data retention policy will address how long after that we may retain your personal data, if at all.

In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or ethical reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. However, keep in mind that we may still be under a legal or ethical obligation to retain the personal data, and will do so until the time frame under such legal or ethical obligation lapses, even if we transfer the data to you or a third party.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities contacting us using the details provided in this policy.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

None.

External Third Parties

• Service providers acting as processors (and their sub-processors) based in the United States who provide various services, including information technology and software or software services. A list of such processors and sub-processors will be provided upon reasonable request.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States.

• Regulators and other governmental authorities acting as processors or joint controllers based in the United States, and in the EEA, who require reporting of processing activities in certain circumstances.