Calibre CPA Group, PLLC (“CALIBRE,” “us, “our,” or “we”) respect your privacy and are committed to protecting it through the practices described in this policy. This Privacy Policy (“Privacy Policy” or “Policy”) explains our information collection practices and the rights and choices that you may have in relation to how we collect, use, retain, and disclose your Personal Information when you visit our website at calibrecpa.com or use CALIBRE platforms, attend our webinars or other online presentations, request CALIBRE newsletters or other communications, visit our offices or CALIBRE-hosted events, engage us for professional services, or otherwise interact with us through channels where this Privacy Policy is posted (collectively, the “Services”). Terms that are capitalized are defined within this Policy.
Please also note that this Privacy Policy is intended to apply under the circumstances where we control the collection of Personal Information and determine the purposes and means of its processing. We primarily process Personal Information in our role as a professional services provider to our business clients, in which case we will process Personal Information based on the client’s direction. When we process Personal Information based on our business clients’ direction, generally, our clients’ privacy policies will apply. For Calibre Workforce Members, including job applicants, current employees, and independent contractors please contact privacy@calibrecpa.com to request a copy of our Workforce Privacy Policy.
If you are a California resident, please see the Notice to California Residents section of this Privacy Policy for additional information regarding information collection practices.
This Privacy Policy is incorporated into and made part of our Terms of Use. Please read this Privacy Policy carefully to understand our policies and practices for collecting, using, and disclosing your Personal Information. By visiting our website and/or utilizing our Services, you acknowledge and consent to the collection, use, and disclosure of your information as described in this Policy. This Policy may change from time to time (see Changes to This Privacy Policy). Your continued engagement with or utilization of our Services after any such revisions indicates that you accept and consent to them, so please check the Privacy Policy periodically for updates.
Our website may include links to other websites, plug-ins, services and social networks operated and maintained by third parties. Clicking on those links or enabling those connections may allow those third parties to collect or share information about you. Please note that we have no control over the privacy practices of those third parties, and we encourage you to review the privacy practices of every website you visit. Additionally, though this Policy acknowledges that we may obtain information about you from third parties, including information that you may provide to or that is collected through a third party about you, this Policy does not apply to the collection and processing of that information by the third party. Those third parties have their own information collection practices. We encourage you to read the privacy policies of businesses before providing information to or through them, and to contact them directly if you wish to exercise any Personal Information rights related to that data.
TABLE OF CONTENTS
I. Information We Collect
II. How We Use Your Information
III. Disclosures of Your Information
IV. Privacy Rights and Choices
V. Notice to California Residents
VI. Data Transfers
VII. Data Security and Retention
VIII. Services From Other Parties; Interest-Based Advertising
IX. Children’s Privacy
X. Changes to this Policy
XI. Contact Us
We collect Personal Information you provide directly to us, through Device, Internet and Network Activity, and from other sources, as described below. For the purposes of this Privacy Policy, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, including through Device, Internet and Network Activity. Information derived from Device, Internet and Network Activity refers to device, internet, and network activity information that we and our Service Providers and other business partners collect, including information about how you interact with our Services online.
Information You Provide Directly to Us
As a CALIBRE client, you may provide us with the categories of Personal Information below in the course of our business relationship with you. Personal Information obtained from or relating to our prospective, current, or former clients may be subject to separate or additional terms of any notice, engagement letter, or other similar letters or agreements with the client, applicable laws and professional principles.
We may also collect the following categories of Personal Information from you in the course of our business, including through your use of the Services or when you contact us, subscribe to our communications or otherwise request information from us:
We may supplement the information that you provide to us with information that we receive or obtain from other sources, such as from our staff or personnel, clients, professional advisers, partners, and agents of CALIBRE, third parties with whom we interact, and publicly available sources.
Some of the above information may be considered Sensitive Personal Information (as defined by applicable laws in certain jurisdictions), and we may use information that you disclose to us to provide and support our Services, comply with our legal obligations, or defend against a legal claim. We do not collect or use Sensitive Personal Information for any other purposes.
Device, Internet and Network Activity Information
Personal Information derived from Device, Internet and Network Activity we collect may include:
Device Data, such as information about your computer, phone, tablet, or other device you use to access our website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, device and/or browser type, hardware model, internet service provider and/or mobile carrier, operating system, mobile platform, and system configuration information.
Log and Usage Data, including service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our website and which we record in log files. Depending on how you interact with us, this log data may include information about your activity on the website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports, sometimes called “crash dumps” and hardware settings).
Cookies and Other Tracking Technologies, such as first party and third-party products and services to gather traffic statistics using cookies, pixels, or web beacons. A cookie is a small piece of information stored on your device that helps websites and servers recognize you. CALIBRE, our Service Providers, and other third parties may also use other tracking technologies such as pixels, or transparent GIF files, for website management and visitor tracking.
Some of the technologies we use on our website are strictly necessary for functionality of the site. Others improve functionality but are not strictly necessary. Some cookies help improve the performance of our website (such as by gathering analytics data), while others help provide targeted advertising services to you (like ads that you may be interested in). Some cookies may be used to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Examples of cookies and other tracking technologies we use include:
For more information about the specific cookies and other website technologies we use and their purposes, please see our Cookie Declaration. Strictly necessary cookies are enabled on our website by default. The website will only place other types of cookies with your consent, which you provide through our cookies notice when you arrive at our website homepage. If you would like to change your cookies settings, you may do so through the consent preferences icon in the bottom left corner of the browser window. For information about how we respond to web browser signals and other mechanisms that enable consumers to exercise choices about behavioral tracking, see the “Services From Other Parties/Internet-Based Advertising” section below.
Please note that if you block certain cookies from the website, it may not function as intended.
Information Provided By Other Sources
We may receive Personal Information about you from our Service Providers, including technical, billing and accounting firms; data analytics and internet providers; other third-party sources, including your previous or current accounting, financial, legal and/or other professional services firm(s), brokerage funds, and other commercially available sources. At your direction, we may collect information from your vendors, advisors, and employees. We may also collect information about you from family members, family office employees, and other authorized agents with your permission or as necessary to administer the Services you request.
We use your Personal Information for our business purposes, including to provide and improve our website and provide client Services, to respond to your inquiries and requests, to prevent fraud and other criminal activity, for marketing purposes, and for other purposes for which we may notify you. For example, we may use your Personal Information for the following and other purposes as permitted or required by law:
We do not sell, share, or otherwise disclose the Personal Information, including mobile information (SMS / text), that we have collected about you through our Services to third parties unless otherwise stated in this Policy or with your consent. We may disclose your Personal Information to the following categories of recipients:
You may have certain rights with respect to Personal Information, depending on the applicable data protection laws in your jurisdiction. To the extent these rights apply to you, they may include:
Right to Access Information. You may have the right to request access to your Personal Information and, where technically feasible, request a copy of your Personal Information. You may also have the right to obtain information about how we process or disclose your Personal Information.
Right to Review and Correct Information. You may have the right to request that we correct any inaccurate or incomplete Personal Information we have about you.
Right to Delete Information. You may have the right to request that we delete your Personal Information. Please note that we may not be able to delete certain information depending on legal exceptions or obligations. Please see the Data Security and Retention section below for more information about why we may retain your information.
Right to Opt-Out of Marketing Communications. You may request that we not use your Personal Information to send you certain emails or other marketing communications. You may also unsubscribe from receiving marketing emails from us by clicking on the “Unsubscribe” link found in those emails or email us at privacy@calibrecpa.com. Please note you may not be able to opt-out of all communications as we may need to send you information related to our Services.
Right to Opt-Out of Sale or Sharing / Targeted Advertising. You may request to opt out of the “sharing” (as defined by applicable laws) of Personal Information, specifically with regard to certain types of behavioral or targeted advertising based on information collected about you on non-affiliated websites, applications, or services through cookies or website technologies. Please note that CALIBRE does not “sell” Personal Information as that term is defined in certain US state consumer data privacy laws such as the California Consumer Privacy Act (CCPA). CALIBRE may “share” Personal Information as defined in the CCPA if you enable certain cookies on our website. You may revoke your consent to the use of these cookies, including previously-enabled cookies by [mechanism].
Right to Appeal. You may have the right to submit an appeal if you are not satisfied with the outcome of your request. Please send appeals directly to privacy@calibrecpa.com.
Exercising Your Rights
If you would like to exercise the rights that are available to residents of the jurisdiction where you reside, please email us at privacy@calibrecpa.com or call us at 866.464.2839. In order to protect your Personal Information, we may ask you to provide additional information to verify your identity. You may also have the right to submit a request to exercise your rights through an authorized agent, in which case your agent must present signed written permission to act on your behalf. You may be required to independently verify your identity with us and confirm that you have provided authorization to the agent.
We primarily receive Personal Information as a service provider to our clients in the course of providing our professional services to them. However, we provide this notice regarding the categories of Personal Information we may collect or receive for informational purposes that may be of interest to California residents. Please see the Data Security and Retention section of this Policy for information about our data retention practices.
| Categories of Personal Information Collected | Purpose for Collection and Use | Categories of Personal Information Recipients |
| Identifiers, Contact and Verification Information, and Government Identification (name and contact details such as your email address, mailing address, phone number, government identification numbers, account username and password, and social media handles). |
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Financial Information (payment card or bank account, invoicing, and tax information).
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Device, Internet or Network Activity Information (device information, including your browser type and language, IP address, device type, unique device identifiers, mobile network information and operating system, and website interactions, such as the pages visited on the website, time spent on each page, whether you’ve clicked on a hyperlink and search queries).
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Inferences (preferences, such as which areas of our Services you are interested in).
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Demographic Information (your racial or ethnic origin, gender, age, military status or veteran’s status, which may be considered Sensitive Personal Information and include protected characteristics under state and federal law).
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General Geolocation Data (such as your general location based on your ZIP code or IP address).
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Audio, electronic, visual, or similar information (photograph or audio or video recording, email contents, and other written communications that you send to us).
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Sensitive Personal Information (such as your Social Security, driver’s license, state identification card, or passport number; veteran status; racial or ethnic origin, religious or philosophical beliefs, or union membership; or certain information in the content of your written communications with us).
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Disclosures for a Business or Commercial Purpose. In the preceding 12 months, CALIBRE has disclosed the categories of Personal Information in the above chart to our Service Providers for specific, limited business purposes, including the purposes listed in the How We Use Information section of this Policy.
California “Shine the Light” Notice. California law requires us to inform California residents who have provided us with personal information that they may request information from us about our disclosures to third parties for their direct marketing purposes. We do not disclose Personal Information to third parties for their direct marketing purposes.
CALIBRE is a U.S.-based accounting and financial services firm comprised of offices in the United States. Details regarding our offices can be found at https://www.calibrecpa.com/contact-us/. Your Personal Information may be transferred within our offices’ integrated computer networks in the United States, and with third parties in other countries that may not be subject to data protection laws similar to those in the jurisdiction in which information is provided to or received by us.
It may be necessary to transfer Personal Information from the EEA or the UK to an outside country to obtain access to our clients’ Personal Data to enable the provision of our Services, and for related purposes as set out in this Privacy Policy. If we transfer Personal Information, we transfer it in accordance with documented instructions of our clients actings as controllers.
If we transfer Personal Information (i) from within the EEA to countries located outside the EEA that have not received an adequacy decision from the European Commission, or (ii) from the UK to countries that are not recognized as offering an adequate level of protection by the Information Commissioner’s Office, including within CALIBRE offices and with our Service Providers, we implement adequate safeguards to appropriately protect such transfer of Personal Information, including on the terms of a valid data transfer agreement incorporating the European Commission’s standard contractual clauses or as permitted under applicable data protection laws.
We take reasonable steps to protect the Personal Information that we collect; however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. As such, we make no representation as to the efficacy or appropriateness of the technical, administrative, and procedural measures we use to safeguard data. Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. The criteria used to determine the applicable retention period for your information includes the length of time we have an ongoing relationship with you and provide Services to you, and whether there is a legal obligation to which we are subject that requires us to retain your information.
Please note that this Privacy Policy does not apply to the practices of third parties on their own websites, including our Service Providers, marketing Service Providers, or other third parties. When you access a third party’s website through links on our website, information collected from you on those third-party websites is governed by their privacy policies. We are not responsible for and do not control the security or privacy of your information when you visit those websites. We encourage you to read the privacy policy of every website you visit.
For example, we and certain third-party partners may place advertisements for our Services on websites, apps, and platforms operated by others. If you would prefer not to receive certain interest-based advertising, you can opt-out of this activity at the Digital Advertising Alliance (DAA) website at optout.aboutads.info, optout.networkadvertising.org, optout.privacyrights.info, and www.aboutads.info/appchoices.
If you do not want the Services to collect information through the use of cookies, you can also set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please note that this sort of opt-out may be browser and/or device specific. Please also note even if you choose to remove your information or opt-out, you may still see advertisements while browsing online. However, the advertisements may be less relevant to you and your interests.
Our website and Services are not directed to or intended for use by minors. If we learn that we have unknowingly collected or received information from a child under the age of 18 without his or her parent or legal guardian’s verified consent, we will make reasonable efforts to delete such information from our records. If you believe that we might have any information from or about an individual under the age of 18 without appropriate consent, we ask that a parent or guardian contact us at privacy@calibrecpa.com.
The Effective Date of this Privacy Policy is set forth at the top of this webpage. As business needs change, we may amend this Privacy Policy. The amended Privacy Policy supersedes all previous versions. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy.
We welcome your questions and comments about this Privacy Policy or how we process your Personal Information. Please contact us using the information below, and we will respond to you as soon as reasonably possible.
By Mail:
Privacy
c/o Calibre CPA Group
7501 Wisconsin Avenue, Ste 1200 West
Bethesda, MD 20814
By Phone:
866.464.2839
By Email:
privacy@calibrecpa.com
By Fax: 202.331.9890
We try to respond to general privacy inquiries within 30 days or as otherwise required by law. Requests to opt-out from our marketing will be processed within 10 business days.
Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us at the above-listed contact information to inquire how they can obtain a copy of our policy in another, more easily readable format. You may also choose to download a PDF version of this Privacy Policy via the link at the top of this page.