TMA Accounting & Payroll Privacy Policy California

Effective Date: October 3rd, 2022

This Privacy Policy for California Residents supplements the information contained in TMA Small Business Accounting P.C.'s (the “Company”) and applies solely to all visitors, users, and others who reside in the State of California ("consumers"). The Company adopts this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information the Company Collects

The Company and/or its Website collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

In particular, the Company and/or its Website has collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

The Company or its Website obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on the Company’s Website.

Use of Personal Information

The Company may use or disclose the personal information the Company collects for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about the Company’s products or services, the Company will use that personal information to respond to your inquiry.
To provide, support, personalize, and develop the Company’s Website, products, and services.
To create, maintain, customize, and secure your account with the Company.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve the Company’s responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Company’s Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of the Company’s Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve the Company’s Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To carry out the Company’s obligations and enforce its rights arising from any contracts entered into between you and the Company, including for billing and collection.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred.

The Company will not collect additional categories of personal information or use the personal information the Company collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

The Company may share your personal information by disclosing it to a third party for a business purpose. The Company only makes these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below

The Company does not sell personal information. In the preceding twelve (12) months, Company has not sold personal information[ to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales
A: Identifiers.	Data analytic providers; Operating systems; Service providers; Internet cookie data recipients	None
B: California Customer Records personal information categories.	Data analytic providers; Operating systems; Service providers; Internet cookie data recipients	None
C: Protected classification characteristics under California or federal law.	Data analytic providers; Operating systems; Service providers; Internet cookie data recipients	None
D: Commercial information.	None	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	Data analytic providers; Operating systems; Service providers; Internet cookie data recipients	None
G: Geolocation data.	Data analytic providers; Operating systems; Service providers; Internet cookie data recipients	None
H: Sensory data.	None	None
I: Professional or employment-related information.	None	None
J: Non-public education information.	None	None
K: Inferences drawn from other personal information.	None	None

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability. You have the right to request that the Company disclose certain information to you about the Company’s collection and use of your personal information over the past twelve (12) months (the "right to know"). Once the Company receives your request and confirms your identity, the Company will disclose to you:

The categories of personal information the Company collected about you.
The categories of sources for the personal information the Company collected about you.
The Company’s business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom the Company shares that personal information.

If the Company sold or disclosed your personal information for a business purpose, two separate lists disclosing (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

The specific pieces of personal information the Company collected about you (also called a data portability request).

Right to Delete

You have the right to request that the Company delete any of your personal information that the Company collected from you and retained, subject to certain exceptions (the "right to delete"). Once the Company receives your request and confirm your identity, the Company will review your request to see if an exception allowing the Company to retain the information applies. The Company may deny your deletion request if retaining the information is necessary for the Company or its service provider(s) to:

Complete the transaction for which the Company collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of the Company’s ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform the Company’s contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with the Company.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

The Company will delete or deidentify personal information not subject to one of these exceptions from the Company’s records and will direct the Company’s service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Calling the Company at (317) 571-8080.
Emailing the Company at info@tmasba.com.
Logging into your account profile.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by calling the Company at (317) 571-8080 or emailing the Company at info@tmasba.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows the Company to reasonably verify you are the person about whom the Company collected personal information or an authorized representative, which may include signing and returning a consent form to the Company or production of a government-issued identification to compare against databases of that information.
Describe your request with sufficient detail that allows the Company to properly understand, evaluate, and respond to it.

The Company cannot respond to your request or provide you with personal information if the Company cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with the Company to submit a request to know or delete. However, the Company does consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

The Company will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

The Company will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact the Company by phone at (317) 571-8080.

The Company endeavors to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If the Company requires more time (up to another 45 days), the Company will inform you of the reason and extension period in writing.

If you have an account with the Company, the Company will deliver its written response to that account. If you do not have an account with the Company, the Company will deliver its written response by mail or electronically, at your option.

Any disclosures the Company provides will only cover the 12-month period preceding the Company’s receipt of your request. The response the Company provides will also explain the reasons the Company cannot comply with a request, if applicable. For data portability requests, the Company will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

The Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If the Company determines that the request warrants a fee, the Company will tell you why it made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age sixteen (16) or older, you have the right to direct the Company to not sell your personal information at any time (the "right to opt-out"). The Company does not sell the personal information of consumers the Company actually knows are less than sixteen (16) years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to the Company by visiting the following Internet Web page link:

Do Not Sell My Personal Information

Once you make an opt-out request, the Company will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:

Calling the Company at (317) 571-8080.
Emailing the Company at info@tmasba.com.
Logging into your account profile.

You do not need to create an account with the Company to exercise your opt-out rights. The Company will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

The Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, the Company will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, the Company may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive the Company offers will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Changes to the Company’s Privacy Policy

The Company reserves the right to amend this privacy policy at the Company’s discretion and at any time. When the Company make changes to this privacy policy, the Company will post the updated notice on the Website and update the notice's effective date. Your continued use of the Company’s Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact the Company at:

TMA Small Business Accounting, P.C.
9595 Whitley Drive, Suite 102
Indianapolis, IN 46240
Telephone: (317) 571-8080
Fax: (317) 571-1986
E-mail: info@tmasba.com

If you need to access this Policy in an alternative format due to having a disability, please contact info@tmasba.com and (317) 571-8080.

TMA Small Business Accounting, P.C. Privacy Policy for California Residents

This document was last updated on October 3, 2022.