This Privacy Policy applies to the websites, emails, and other communications, electronic or otherwise of CTI III, LLC dba Corporate Tax Incentives (“CTI”, the “Company”, “we”, “us”, and/or “our” for the limited purpose of this Privacy Policy as the context may require). We respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of data that we may collect from you or that you may provide when you visit our website at www.ctillc.com or use our Tax Incentive Platform available through the website or otherwise directly or through the use of an appointed representative (collectively, “Our Sites”), our practices for collecting, using, maintaining, protecting and disclosing that information, and the choices you can make about the way your information is collected and used by us.

Purpose

This purpose of this Privacy Policy is to give you information on how CTI collects, processes, and maintains your data through your use of applications and services offered by CTI. As the holders of your data, we advise that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

Changes

We may update this Privacy Policy occasionally. We will email you for changes we think are important to you. The current version of this Privacy Policy will always be located on our website and app, and the date the policy was updated will appear at the top of the policy.

Changes

Personal data or personal information means any information about an individual from which that person can be identified or that is linked to information that identifies a specific individual. We may collect, use, store and transfer different kinds of personal data, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, and gender.
• Contact Data includes billing address, email address, telephone, mobile numbers, and other contact information.
• Financial Data includes payroll information, as well as bank account information, credit card information, and other payment instrument information.
• Profile Data includes username and password, your purchases or orders, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our applications and services.

We also collect, use, and share data that we aggregate that is not personally identifiable, such as statistical or demographic data, for any purpose. Aggregated data could be derived from your personal data but is not legally considered personal data as it will not directly or indirectly reveal your identity in this aggregated form. But if we combine or connect such aggregated data with your personal data so that it can directly or indirectly identify you, we 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 (this includes details about 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). Nor do we collect any information about criminal convictions and offenses.

Required Personal Information

Certain services, contract terms, or even the law, may require us to collect personal information. Should you be unwilling to provide such information when requested, we may not be able to provide you with services.

How We Use Your Data

We will never disclose, share or sell your personal information without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this policy. If you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The bases for our use of your personal information are set out below. Please get in touch with us if you need details about the specific legal basis we have to process your personal information where more than one ground is provided.

To accurately categorize your business transactions

• Personal information used
• Accounting data
• Payroll systems
• Prior years’ tax returns
• Basis for processing
• Performance of a contract with you
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
• To match business transactions with their respective context

Personal information used

• Emails
• Email attachments
• Credit card transactions
• Bank transactions
• Calendar events
• Basis for processing
• Performance of a contract with you
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
• To uncover all possible tax incentives for your business

Personal information used

• Emails
• Email attachments
• Credit card transactions
• Bank transactions
• Calendar events
• Payroll information and records
• Accounting workbooks
• Basis for processing
• Performance of a contract with you
• Necessary for our legitimate interests (to keep our records updated, and to study how our customers use our products/services)
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Personal information used

• Actual usage of Our Sites
• Basis for processing
• Performance of a contract with you
• Necessary for our legitimate interests (to keep our records updated and to study how our customers use our products/services)
• To market our products and services to you

Personal information used

• Name
• Email addresses
• Basis for processing
• Necessary for our legitimate interests (to provide you with product and service updates)
• To use to operate Our Sites, products, and services and to prevent fraud or unauthorized access to Our Sites

Personal information used

• Actual usage of Our Sites
• Username and password
• Basis for processing
• Necessary for our legitimate interests (to maintain access control over the information within Our Sites)
• Sharing Of Your Data

For the purposes set out above, we may share your data with:

• Third parties with whom we are collaborating for the purposes for which we collected the data
• Relevant law enforcement officials or third parties (e.g. auditors or investigators) to investigate fraud.
• Relevant regulators or law enforcement officials in response to a valid request for information where we believe disclosure is in accordance with applicable law, regulation or legal process.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where We Store Your Data

Your personal data is stored in the United States of America.

Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. In some circumstances, you can ask us to delete your data: see “your legal rights” below for further information. Moreover, in some circumstances, we will anonymize 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. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your Rights

Applicable law may provide you with certain rights concerning your personal information. Such rights include:

• The right to request access to your personal data and correct such data.
• The right to request restriction of sharing your personal data.
• The right to request the transfer of your personal data.
• The right to request the deletion of your
• The right not to be discriminated against for the exercise of any of the above rights.
• We don’t sell your data. Thus, while you have the right to opt-out of the sale of your data, that right is automatically invoked.

To exercise the rights described above, please submit a verifiable request to us by email or mail at: [email protected]

1720 Prairie City Road, Suite 120, Folsom, CA 95630

+1 (866) 443-2422

Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at [email protected].