FREEDOM TAX PRIVACY STATEMENT

Last Updated: 02/24/2021

Introduction and overview

Freedom Tax, LLC (“Freedom Tax”) leverages education to empower individuals and businesses around the world and we believe that everyone has a right to privacy. We also believe in providing transparency on how we collect, process and share personal information.

Scope of this Privacy Statement

This Privacy Statement (“Privacy Statement”) describes our privacy practices for individuals in the United States when we process:

a) Personal information for the purposes of providing financial- and investment-related educational products and services.

b) Personal information for the purposes of providing the benefits of live or virtual education services, software services, and other affiliated services which is collectively, all Freedom Tax’s services, sites, experiences and software (the “Freedom Tax Services”); and/or

c) Personal information as necessary to manage, run, and improve our business.

Our role

This Privacy Statement does not apply where Freedom Tax processes personal information as a service provider on behalf of a customer or entity who alone or jointly with others determines the purposes and means of the processing of personal information (“Information Controller”). When we act as a service provider, the privacy statement of the relevant Information Controller and our agreements with such business or entity will govern our processing of personal information.

In certain circumstances, there may be more than one Information Controller processing your information. For example, your employer or your service provider or a financial partner may also act as an Information Controller of personal information processed by Freedom Tax. In these situations, we act as an independent Information Controller over our processing activities – meaning that we, as an Information Controller, make determinations over how your personal information will be processed independently from the other Information Controller. The other Information Controller may have their own obligations under applicable information privacy law, and you may need to speak with the other Information Controller directly for questions on how they process your personal information.

The Freedom Tax Services and your Freedom Tax Account

Freedom Tax Account information

In order to access the benefits we make available as part of the Freedom Tax Services, data entered into one service or feature becomes a part of your Freedom Tax Account.

The personal information contained within your Freedom Tax Account is the combination of information that Freedom Tax has about you. Your Freedom Tax Account may include your credentials; your name and contact details; payment information; information about your activities, your interests and preferences; the content you place in our platform; information we have collected about you from third-party sources and insights that are associated with you.

The information in your Freedom Tax Account will be shared across the Freedom Tax platform to generate our various offerings, services and experiences and otherwise maximize the benefits to you of our platform.

Information you give us

The personal information that we receive about you depends on the context of your interactions with Freedom Tax, how you configure your Freedom Tax Account and the choices that you make, including your privacy settings. Personal information that you provide may also depend upon what services or experiences you use, your location and applicable law.

Creating an account. We collect information when you create an account, interact with our Platform or purchase products or services. Personal information may include your contact information (such as your name, address, phone number and email), profile photo, billing information (your payment information), usernames and credentials.

Customer support, product research, training and feedback. We may collect personal information when you reach out to us for support, give us feedback, participate in optional surveys, product research or training and you choose to share (“Communication Information”).

Social and community content. We receive content you post on our social media pages and our community pages.

Information about others: Please see the section titled, “Information provided by others”, below.

Information we get when you use the products and services.

We may collect certain information about you when you access or use the Freedom Tax Platform or use our Services. This may include:

Device information. We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.

Content. We may receive information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information.

Third-party service content. We receive information about you when you sign into a third-party service with your Freedom Tax Account or when you connect your Freedom Tax Account to a third-party service. For example, you may choose to connect your Freedom Tax Account with your bank accounts. To sync your financial account information, we must access your financial account information.

Usage information. We may collect usage information such as the pages you viewed, the features you use, your browser type and details about any links with which you interact.

Location information. Certain features in our platform may collect your precise location information, device motion information, or both, if you grant permission to do so in your device settings.

Expert advice. Our Services provide many opportunities for you to connect with experts, including, for example, accountants or tax preparers. When you interact with these experts, we may receive information about the questions you ask, the details of your accounts and the guidance provided to you.

Camera and contacts. Certain features may have access to your camera and contacts if you grant permission in your device settings.

Information from cookies and other technologies. Freedom Tax and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experience. The Freedom Tax Platform is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted. You have control over some of the information we collect from Cookies and how we use it.

Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. We may also store personal information locally on your device.

Information provided by others

At Freedom Tax, we believe that you have rights to information that pertains to you, your household and/or your business. If another person has input or processed information in the Freedom Tax platform or otherwise provided information on behalf of you, your family or your business (and we are processing such information as an Information Controller),you may ask to receive a copy of your information, even if you do not have an account with us. To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to receiving a copy of the information. For specific instructions on how to request a copy of your information, please see the section “Your information rights and choices” below.

We also obtain information from outside parties or services to run our business. We protect and process information obtained from those parties as described in this Statement, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the Freedom Tax Services. For a list of the categories of sources from whom we obtain information, please see the section “Other information sources” below).

Other information sources

We may also get information about you from others where permitted by applicable law. For example, we receive information from:

Supplemental information and identity verification providers. Service providers who help us verify your identity, the specifics of your business and/or supplement the information you have provided and ensure the accuracy of your information. For example, we use third party service providers to validate your mailing address, phone number or provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.

Support providers. Service providers who provide us with information about you or your interaction with the Freedom Tax Platform. For example, we may obtain service and support information or technical issues you have raised with these third parties.

Other users. As described in sections “information Provided By Others”, we may get information about you from other users, such as your spouse, your head of household, or your business partner.

Risk management, cybersecurity & anti-fraud providers. We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud, illegal activity and to help protect your personal information.

Content providers. We may receive information from software providers that make user-generated content from their service available to others, such as local business reviews or public social media posts.

Communication providers & social networks. If you give us permission, we may collect information from email providers, communication providers and social networks.

Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.

Publicly-available Sources. We collect information from publicly available sources, such as open government databases.

Government agencies. We receive information from government agencies, including from various tax agencies.

Required information

Some services and experiences part of the Freedom Tax Services and the Freedom Tax Platform require you to provide information for it to function. If you do not wish to provide the required information, you may not be able to use certain features.

How we use personal information

We collect and process personal information from you only where:

We have your consent to do so

We need the personal information to perform a contract with you or provide a service to you

Provide you with the benefits of the Freedom Tax Services and Freedom Tax Platform and operate our business

The processing is in our legitimate business interests

To comply with legal requirements, including applicable laws and regulations

Personal information is used to operate our business, including but not limited to:

Provide you with the Freedom Tax Services and Freedom Tax Platform and create your Freedom Tax Account

Improve our products and services

Run and manage our business, including resolving billing and financial disputes

Evaluate your eligibility for other offers, products and services

Connect you with experts and other users

Communicate with you

Advertise and market our services and experiences

Personalize your experience, including through the development of insights about you and your needs

Provide you with support and resolve disputes

Conduct research, including by partnering with academic institutions

Comply with our legal and regulatory requirements

Protect the rights, property, safety or security of Freedom Tax, our customers, employees, or others and prevent fraudulent or illegal activity

To enforce, remedy or apply our Terms of Service or other agreements

We may also use your personal information for other purposes that are compatible with the disclosed purposes if and where this is permitted by applicable law.

How we share your information

From time to time, we may need to share your information in the following circumstances:

With your consent. We share your information with third-parties when you have requested us to do so.

For research. With appropriate controls, we may share information with third-parties for research purposes or policy-related materials. We only share information in a way that would not allow any individual to be identified.

For joint sales, promotions and events. We may share your information with third-parties who are jointly providing sales initiatives, promotions, or events with us.

With financial services providers. We may share personal Information with collection agencies, credit bureaus and loan service providers, financial product underwriters and payment card association members. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

With service providers. We share personal information with our service providers who provide services on our behalf for the purposes described in this Statement. Service providers are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement.

For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company (collectively, a “Transaction”), we may share your information with that company and its advisors before and after the Transaction date.

Sales of personal information to third parties. We do not and will not sell personal information to third parties. We do share personal information with third-parties for the business purposes described in this Statement.

With our affiliates and subsidiaries. We may share your information with and among our affiliates and subsidiaries for everyday business purposes (as described in this Statement) as well as for marketing purposes.

Your Right to Limit information Sharing: certain laws, including Federal Law for our US customers, provides our customers with the right to limit our information sharing activities in certain circumstances. For example, you may have the right to limit our sharing of information to both affiliates and third-parties for marketing purposes.

Non-Responsive Services, links, and integrations

Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Statement). You should take care only to share information on social media that you are comfortable sharing.

Advertising and analytics

Freedom Tax may use advertising networks and other providers to display advertising on our Freedom Tax Platform or to manage our advertising on other sites. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements. You may be able to opt-out of such interest-based advertising by visiting Digital Advertising Alliance’s Network Advertising Initiative’s, or Your Online Choices.

For legal reasons

We may share your information with third-parties for legal reasons, including:

When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process

To protect the rights, property, or safety of Freedom Tax, the Freedom Tax Platform, our customers or others

To protect or defend against attacks

To enforce, remedy, or apply our Terms of Service or other agreements

To prevent fraud, cybersecurity attacks or illegal activity

For debt collection

Your information rights and choices

Your rights

Regardless of your location, we believe that all persons should have privacy and information protection rights and choices.

Depending on where you live, you may have certain state-specific legal rights with respect to your personal information that we collect and process.

If you are an individual in the United States, you can file a request or take action on one of your rights by contacting us at the contact details provided under the section “How to contact us.”

If you are a California resident, you may have the following rights:

Verification. In order to protect your personal information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a rights request. If you do not have an account with us, or if we suspect that your account has suffered fraudulent or malicious activity, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.

Authorized agents. You may use an authorized agent to submit a rights request. If you do so, the agent must present signed written authorization to act on your behalf, and you may also be required to independently verify your identity or your legal authority or ownership of the personal information with us.

Access. You may have the right to access the categories of personal information we have collected about you, the sources from which that information was collected, the business or commercial purpose for collecting your personal information, the categories of third parties with whom we share your personal information, the specific pieces of personal information we have collected about you, the categories of personal information we sold about you, the categories of third parties to whom we sold personal information about you, and the categories of personal information we disclosed for a business purpose.

Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us.

Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your California privacy rights.

Please note that we may claim legal exemptions for certain types of personal information from all or certain parts of the CCPA pursuant to various CCPA exemptions.

What you can do to manage your privacy

You have choices when it comes to managing the privacy of your personal information.

Update your privacy settings. You may update your privacy settings by contacting us.

Manage marketing communications from us. To update your marketing communication preferences, you can go to the marketing preference tools in your Freedom Tax Account settings. You may also click unsubscribe at the bottom of the marketing emails or respond with STOP to SMS messages.

Download a copy of your personal information. You may request a copy of your personal information by contacting us.

Correct your personal information. You can edit and correct your personal information at any time by contacting us or by changing it directly in our products and services.

Delete your personal information. You may request for us to delete your personal information by contacting us.

Cookies and other tracking technologies. You can find information on changing your browser settings to opt-out of cookies in your browser settings or make changes to your cookies settings by using our cookie preferences tool. If you disable some or all of the cookies the service, or parts of the service may not work.

Even if you opt-out of such cookies or otherwise opt-out of interest-based advertising, you will still receive advertisements, they just won’t be tailored to your interests. If you opt-out and later delete your cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.

Information retention

Unless you specifically ask us to delete your personal information as explained in section “Your information rights and choices,” above, we retain your personal information as long as it is necessary to comply with our data retention policies and obligations. For example, we may maintain your Freedom Tax Account for our legal or regulatory compliance needs (e.g. maintaining records of transactions you have made with us), to exercise, establish or defend legal claims and to protect against fraudulent or abusive activity on our service.

There may be occasions where we are unable to fully delete or de-identify your information due to technical or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete or de-identify it.

Security of your personal information

We use physical, technical and organizational safeguards designed to protect your information. However, despite these controls, we cannot completely ensure or warrant the security of your information.

How to contact us

If you have questions or comments about this Privacy Statement or our practices, please contact us:

Email: privacy@freedomtax.io

Direct Mail: Freedom Tax, Attention: Privacy, 12901 MCGREGOR BLVD Suite 20-221

FORT MYERS, FL 33919.

If you have an unresolved privacy or information use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.

Changes to our Privacy Statements

From time to time we may change or update our Privacy Statement. We reserve the right to make changes or updates at any time. If we make material changes to the way we process your personal information, we will notify you by posting a notice in our platform or on a community post, by sending you a notification or by other means consistent with applicable law.

You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Privacy Statement. Please review this Privacy Statement periodically to stay informed about how Freedom Tax protects your privacy.

Collection and use of children’s personal information

Our services are not intended for or directed to children under the age of 13. We do not knowingly collect personal information from users under the age of 13. If you believe we may have information from a child under the age of 13, please contact us.