Draft — pending legal review. Bracketed, highlighted items are placeholders for Winthco and its counsel to complete. This draft is not legal advice.
1. Who we are
This Privacy Policy describes how [WINTHCO LEGAL ENTITY NAME, e.g. Winthco LLC] ("Winthco," "we," "us") handles information in connection with the ninitaxbot.com website and the NiniTaxBot service. Contact: kyle@winthco.com · [STREET ADDRESS, CITY, STATE ZIP].
2. Information we collect
Website visitors
- Information you choose to send us, such as your name, firm, email address, returns per season and tax software when you request a pilot spot or contact us. Forms on this site currently open your own email app; we receive what you send by email.
- Technical information our hosting provider processes to deliver the site, such as IP address, browser type and pages requested. [DESCRIBE ANALYTICS, IF ANY]
Service users (CPA firms and their clients)
- Account information for firm users.
- Tax documents uploaded by firms' clients and data extracted from them, which may include names, Social Security numbers, account numbers and income information.
3. How we use information
- To respond to inquiries and administer the pilot program.
- To provide the service: storing documents, classifying them, extracting data, displaying it for review, and producing exports requested by the firm.
- To secure, maintain and improve the service. [COUNSEL: STATE WHETHER/HOW CUSTOMER DATA MAY BE USED FOR MODEL IMPROVEMENT; DEFAULT ASSUMPTION: NOT WITHOUT FIRM CONSENT]
- To comply with law.
4. Role with respect to client data
For tax documents uploaded through a firm's portal, we process data on behalf of that CPA firm under our agreement with the firm. [COUNSEL: CONFIRM SERVICE-PROVIDER / PROCESSOR CHARACTERIZATION AND APPLICABLE LAW, E.G. GLBA/FTC SAFEGUARDS RULE, IRC §7216, STATE LAWS]
5. How we share information
We do not sell personal information. We share information with service providers that help us operate the service (such as hosting, storage and AI processing providers) under contractual obligations, when required by law, or in connection with a business transfer. [LIST SUBPROCESSORS OR LINK TO LIST]
6. Security
We use measures designed to protect information, including encrypted storage and firm-level data isolation at the database level. No method of transmission or storage is completely secure.
7. Retention
[RETENTION PERIODS FOR WEBSITE INQUIRIES, ACCOUNT DATA AND UPLOADED DOCUMENTS; DELETION ON FIRM REQUEST/CONTRACT END]
8. Your choices and rights
You may ask us to access, correct or delete personal information we hold about you by emailing kyle@winthco.com. If your information was uploaded by your CPA firm, we may refer your request to that firm. [COUNSEL: STATE-SPECIFIC RIGHTS, E.G. CALIFORNIA]
9. Children
The service is intended for businesses and is not directed to children under 13. [COUNSEL: ADDRESS DEPENDENTS' DATA IN TAX DOCUMENTS]
10. Changes
We may update this policy and will post the updated version with a new effective date.
11. Contact
[WINTHCO LEGAL ENTITY NAME, e.g. Winthco LLC], [STREET ADDRESS, CITY, STATE ZIP]. Email: kyle@winthco.com.