UCPAA Privacy Policy

Last Revised: June 15, 2019

UCPAA, Inc. d/b/a/ The United CPA Association (“UCPAA,” the “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through its compliance with its privacy policies. This Privacy Policy (the “Policy”) describes:

the types of information that UCPAA may collect from you when you access or use its website, located at ucpaa.org, (the “Site”), and related software applications and other online services (collectively, the “Services”); and

its practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies only to the information UCPAA collects, hosts, or controls through its Services, in email, orally, text and/or other electronic communications sent through or in connection with its Services.

This Policy DOES NOT apply to information that you provide to, or that is collected by, any third party, such as an accounting firm or a third party individual utilizing the Services, and social networks that you use in connection with the Services. UCPAA encourages you to consult directly with such third parties about their privacy practices.

Please read this Policy carefully to understand UCPAA’s policies and practices regarding your information and how UCPAA will treat it.

Your use of the Service constitutes your binding acceptance of this Policy, including any modifications that we make. This Policy will constitute a binding and enforceable agreement between you (individually and/or in your individual capacity as an employee, officer, agent, partner, etc. of each organization you represent in connection with any use of the Service) and UCPAA. By using the Site or any Services, you agree to this Policy and you are consenting to UCPAA’s collection, use, disclosure, retention, and protection of your information as described here. If you do not provide the information UCPAA requires, UCPAA may not be able to provide all of its Services to you. If you do not agree with this Policy in its entirety, then you must immediately stop using the Site and all Services. This Policy is binding on you by your use of the Site or Services, regardless of whether or not you choose to (i) register for an Account (as defined in our Terms of Service), and/or (ii) become part of the Membership Program.

Where you use the Service in the course of your employment or business, you enter into this Policy both on your own behalf and in your individual capacity as an employee, officer, agent, partner, etc., of such organization that you represent, and references in this Policy to “user(s)” or “you” shall mean both you (i) as the user of accounting services through the use of the Services via the Site, and/or (ii) in a capacity as representative of an accounting organization or firm listed on the Site.

This Policy may change from time to time, your continued use of UCPAA’s Services after it makes any change is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

1. The Information We Collect

UCPAA collects several types of information from and about users of our Services. Specifically, we may collect the information identified in this Policy because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so as described in this Policy. The information we collect includes:

1. Your Personal Information: Personal information is the information that can be associated with a specific person and could be used to identify that specific person whether from that data, or from the data and other information that we have or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
2. Account Information: If you create an Account, we may store and use the information you provide during that process, such as information about your accounting firm or organization, your full name, email address, zip code, physical address, and other information you may provide with your Account, such as your phone number. We may publicly display this information, including your first name and last name as part of your Account profile. You can modify some of the information associated with your Account through your account settings. You may optionally provide us with information through third party sign-in services such as Facebook and Google Plus. In such cases, we fetch and store whatever information is made available to us by you through these sign-in services.
3. Communications: When you sign up for an Account or use certain features of the Services, you are opting to receive messages from other users, accounting firms, and UCPAA. Please note that you cannot opt out of receiving certain administrative, transactional, or legal messages from UCPAA. For example, if you make or attempt to contact an accounting firm through the Site, or request information from an accounting firm through the Service, the accounting firm or UCPAA may send you messages using the contact information you provide, including through telephone call and/or SMS text messages to your phone number. We may also track your actions in response to the messages you send or receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Service, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests to exchange reviews for compensation. In addition, we make no guarantee that any message that you attempt to transmit through the Service will ever be transmitted, delivered, received, read, or responded to by any other user or accounting firm. In addition, we may log associated phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on the Service, we may contact you, including by phone or email, using the contact information you provide us, that we collect, that is publicly available, or that we have on record for your business. Our calls with you may be monitored and recorded for quality purposes.
4. Transactions: If you initiate a transaction through the Service, we may collect and store information about you, such as your name, your businesses name, phone number, address, and email, as well as any other information you provide to us, in order to process your transaction, send communications about them to you, and populate forms for future transactions. This information may be shared with third parties, and third parties may share such information with us, for the same purposes.
5. Activity: We may store information about your use of the Service, such as your search activity, the pages you view, the date and time of your visit, accounting firms or organizations you contact and purchases you make through the Service.

6. Different Sources: You may access the Service through different devices (e.g., your mobile phone or desktop computer). In addition, we may collect publicly available data and associate it with any Account, including your Account. The information that we collect and store through those different uses may be cross-referenced and combined and made publicly available through the Site.

7. Payment Information: For certain portions of our Services, and in certain cases, payment information will be required. UCPAA does not store or directly access any of your payment information or account information. Instead, UCPAA utilizes third party payments processors and UCPAA does not have direct responsibility or control over such information. UCPAA’s agreements with the third party service providers require them to keep the information secure and confidential. As such, UCPAA cannot and does not guarantee that the transmission of your payment information will always be secured against access from unauthorized third parties. There is always the chance that unauthorized third parties will be able to defeat the security measures taken by UCPAA or the third parties we have contracted with. UCPAA makes no representations or warranties and assumes no liability or responsibility for improper access to or disclosure of your payment information due to unauthorized third party access, errors in transmission, or other causes beyond UCPAA’s control. To help in this process, you should never share your username, password, or other information pertaining to your UCPAA Account with anyone.

2. Information You Provide Us

The information we collect on or through our Services may include:

1. Your preferences: Your preferences and settings such as time zone and language.
2. Your content: Information you provide through our Services, including your reviews, comments, names, and other information you provide on our Services, and other information in your Account profile.
3. Your searches and other activities: The search terms you have looked up and results you selected. This may include preferences pertaining to your geographic location.
4. Your browsing information: How long you used our Services and which features you used, including the ads you clicked on.
5. Your communications: Communications between you and other users or accounting firms or organizations through our Services; communications between you and UCPAA; your participation in a survey, poll, sweepstakes, contest or promotion scheme; your request for certain features (e.g., newsletters, updates or other products).
6. Your Public Posts: You also may provide information (such as ratings, reviews, comments, etc.) to be published or displayed (hereinafter, “posted”) on publicly accessible areas of our Services or transmitted to other users of our Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. We may display this information on the Services, share it with businesses, and further distribute it to a wider audience through third party sites and services. You should be careful about revealing any sensitive details about yourself in such postings.

We use the information you provide to us to enhance the functionality and improve the quality of our Services, and to personalize your experience while using our Services. We also use this information to display relevant advertising, provide support to you, communicate with you, and comply with our legal obligations.

3. Information We Collect Through Automatic Data Collection Technologies

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services, and about your use of the Services, even if you use the Services without registering or logging in.

1. Usage information: Details of your use of our Services, including traffic data, location data, logs and other communication data and the resources that you access and use on or through our Services.
2. Computer and device information: Information about your computer, Internet connection and mobile device, including your IP address, operating systems, platforms, browser type, other browsing information (connection, speed, connection type etc.), device type, device’s unique device identifier, mobile network information and the device’s telephone number.
3. Location information: Our applications collect real-time information about the location of your device, as permitted by you. You may be able to limit or disallow our use of certain location data through your device or browser settings, for example by adjusting the “Location Services” settings for our applications in iOS privacy settings.
4. Last URL visited: The URL of the last web page you visited before visiting our Site.
5. Mobile device IDs: Unique mobile device identifier (e.g. IDFA or other device IDs on Apple devices like the iPhone and iPad), if you are using our Services on a mobile device, we may use mobile device IDs (the unique identifier assigned to a device by the manufacturer), instead of cookies, to recognize you. We may do this to store your preferences and track your use of our applications. Unlike cookies, mobile device IDs cannot be deleted. Advertising companies may use device IDs to track your use of our applications, track the number of advertisements displayed, measure advertising performance and display advertisements that are more relevant to you. Analytics companies may use mobile device IDs to track your usage of our applications.
6. Your preferences: Your preferences and settings such as time zone and language.
7. Your activity on the Services: Information about your activity on the Services, such as your search queries, comments, domain names, search results selected, number of clicks, pages viewed and the order of those pages, how long you visited our Services, the date and time you used the Services, error logs, and other similar information.

4. Why Does UCPAA Collect Information?

UCPAA collects information for the some or all of following reasons:

1. Verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security on and off of the Services.
2. Employ you or consider you for employment;
3. Select and personalize advertisements, offers and other sponsored content that we show you;
4. Help advertisers and other partners measure the effectiveness and distribution of their advertisements, and understand the types of people who use their services and how people interact with their websites, apps, and services.
5. Provide Services to you under contract;
6. We use location information, such as your current location, where you live, the places you like to go, and the businesses and people you are near-to provide, personalize and improve our Services, including the ability to identify local users and accounting firms, for you and others. Location information can be based on things like precise device location (if you have allowed us to collect it), IP addresses, and information from your use of the Services;
7. For legal reasons, for example, if you have entered into a contract with us;
8. Provide information to you about our products and Services if you have consented to receive it;
9. Understand our users (what they do on our Services, what features they like, how they use them, etc.), improve the content and features of our Services (such as by personalizing content to your interests), process and complete your transactions, and make special offers;
10. Administer our Services and diagnose technical problems;
11. Send you communications or provide you information that you have requested or that may be of interest to you by way of emails, or courier, or registered post, or telephone calls, or any other mode of communication;
12. Enable us to show you ads that are relevant to you, which may be presented and displayed through any format or medium, including, but not limited to, ads on the Site, ads on third party websites, ads on social media platforms and/or mobile applications, and via browser plugins, etc.;
13. Generate and review reports and data about, and to conduct research on, our user base and Service usage patterns;
14. Administer contests and sweepstakes;
15. Provide you with customer support;
16. Provide you with policies, services, communications, and information pertaining to your Account;
17. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
18. Notify you about changes to our Services;
19. Allow you to participate in interactive features offered through our Services;
20. In any other way we may describe when you provide the information; and
21. For any other purpose with your consent.

We may also use the information we have collected from you to enable us to display advertisements to our advertisers’/service providers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. Cookies and Other Tools

1. Cookies

This Site or its third party tools use cookies, which are necessary to its functioning and required to achieve the purposes illustrated in this Policy. By accepting and consenting to this Policy, you agree to the use of cookies.

2. What are cookies?

Cookies are small text files that are placed on visitor’s devices or computers – these files are known as cookies. Cookies allow a website to create a better experience for visitors because cookies are uniquely assigned to each visitor and can only be read by a web server in the domain that issued the cookie to the visitor. Cookies cannot be used to run programs or deliver viruses to a visitor’s device.

Cookies do various jobs that make the visitor’s experience to a website much smoother and more interactive. For instance, cookies are used to remember the visitor’s preferences on websites they visit often and to help navigate between pages more efficiently. Much, though not all, of the data collected is anonymous, though some of it is designed to detect browsing patterns and approximate geographical location to improve the visitor experience.

3. How Does UCPAA Use Cookies?

UCPAA places cookies on your device or computer to store and then retrieve small bits of information when you visit or use the Services. This is to ensure that our content is tailored to your specifications, thereby improving the visitor experience. Amongst other things, the cookies allow users to login to the Site and let us calculate (anonymously) how many visitors the Site has. We believe that the visitor experience of the Site would be adversely affected if visitors do not accept our use of cookies.

4. What Type of Cookies Do We Use?

Cookies can be categorized by how long they are stored and their function.

• Cookies categorized by length of storage:

Persistent cookies – Persistent cookies remain on a visitor’s device for a set period of time specified in the cookie. They are activated each time that the visitor visits the website that created that particular cookie.

Session cookies – Session cookies are temporary. They allow website operators to link the actions of a visitor during a browser session. A browser session starts when a visitor opens a browser window and finishes when they close it. Once you close the browser, all session cookies are deleted.

• Cookies categorized according to function:

Strictly necessary cookies – Strictly necessary cookies are essential to navigate around a website and to use its features. Without them, visitors would not be able to use basic services like registration. These cookies do not gather information about visitors that could be used for marketing or remembering where a visitor has been on the internet.

Performance cookies – Performance cookies collect anonymous data for statistical purposes on how visitors use a website, they don’t contain personal information, and are used to improve the visitor experience.

5. How Can You Control Cookies?

Users must be aware that any preferences will be lost if cookies are deleted, and many websites will not work properly, or functionality will be lost. UCPAA therefore does not recommend turning cookies off when using the Site. Most browsers accept cookies automatically, but visitors can alter the settings of their browser to erase cookies or to prevent automatic acceptance. Browsers generally provide the option to see the cookies currently stored and to accept, reject or delete cookies, block third party cookies, block cookies from particular sites, accept all cookies and subscribe to a notification when a cookie is issued. A visit to the ‘options’ or ‘preferences’ menu on their browser will allow visitors to change settings. The browser help section usually provides detailed information on how this is accomplished.

If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.

6. Other Analytic Tools

UCPAA or its service providers may also use analytic services to understand how effective UCPAA’s content is, what interests UCPAA’s users have, and to improve how this Site works. In addition, UCPAA may use web beacons, or tracking pixels to count visitor numbers and performance cookies to track how many individual users access this Site and how often. This information will be used for statistical purposes only and it is not UCPAA’s intention to use such information to personally identify any user. However, if you have created an Account and signed into this Site, UCPAA may combine this information with information from its web analytic services and cookies to analyze how you use this Site in more detail.

6. Anonymous or De-Identified Data

We may anonymize and/or de-identify information collected from you through the Services or via other means, including via the use of third party web analytic tools. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation.

7. How We Share the Information We Collect

UCPAA will never sell, lease, or rent your information to any third party. However, we may disclose information that we collect or you provide, in accordance with this Policy. Specifically:

1. To our subsidiaries and affiliates.
2. To contractors, advertisers/service providers and other third parties whom we use to support our business and who are bound by contractual obligations to keep information confidential and use it only for the purposes for which we disclose it to them.
3. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of UCPAA’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information held by UCPAA about the users of our Services are among the assets transferred.
4. To third parties to market their products or services to you if you have consented to receive the promotional updates.
5. To fulfill the purpose for which you provide it.
6. For any other purpose disclosed by us when you provide the information.
7. Service Providers.
   • We may share your information with outside vendors that we use for a variety of purposes, such as to send you communications via emails, to inform you about products that may be of interest to you, push notifications to your mobile device on our behalf, help us analyze use of our Services, and process and collect payments.
   • Additionally, our Services are hosted by third party hosting services providers; accordingly, we will share all information with them so that they may allow us to operate the Site and Services.
   • We also may use vendors for other projects, such as conducting surveys or organizing sweepstakes for us. We may share information about you with these vendors only to enable them to perform their services.
8. Legal Purposes. We may share your information when we believe in good faith that such sharing is reasonably necessary in order to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process. We may also share your information to investigate and address threats or potential threats to the physical safety of any person, to investigate and address violations of this Policy or the Terms of Service, or to investigate and address violations of the rights of third parties and/or to protect the rights, property and safety of UCPAA, our employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations on account of legal request such as subpoena, court order or government demand to comply with the law.
9. To enforce or apply our Terms of Service and other agreements pertaining to the Site or Services.
10. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of UCPAA, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
11. Consent. We may share your information in any other circumstances where we have your consent.

8. Tailored Advertising

Third parties whose products or services are accessible or advertised via the Services may also use cookies or similar technologies to collect information about your use of the Services. This is done in order to help them Inform, optimize, and serve advertisements based on past visits to our Site and other sites. We also allow other third parties (e.g., Google AdSense and others) to serve tailored ads to you on the Services, and to access their own cookies or similar technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies which may be placed by such third parties. These parties may permit you to opt out of ad targeting.

9. Security: How We Protect Your Information

1. We have implemented appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your information and to maintain data security. These safeguards consider the sensitivity of the information that we collect, process, and store and the current state of technology. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it.

2. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control. You play an important role in keeping your information secure. You should not share your username, password, or other security information for your UCPAA Account with anyone and should utilize usernames and passwords that are unique to the Site and not associated with any other website. If we receive instructions using your username and password, we will consider that you have authorized the instructions.

10. Permissible Age

The Services and the Site are not intended for users under the age of 18, unless permitted under applicable local laws (the “Permissible Age”). We do not knowingly collect any personal information from users or market to or solicit information from anyone under the Permissible Age. If we become aware that a person submitting personal information is under the Permissible Age, we will delete any related information as soon as possible. If you believe we might have any information from or about a user under the Permissible Age, please contact us at [email protected].

11. Third Party Links and Services

The Services may contain links to third party websites. Your use of these features may result in the collection, processing or sharing of information about you, depending on the feature. Please be aware that we are not responsible for the content or privacy practices of other websites or services that may be linked on our services. We do not endorse or make any representations about third party websites or services. This Policy does not cover the information you choose to provide to or that is collected by these third parties. We strongly encourage you to read such third parties’ privacy policies.

12. California Privacy Rights

California law permits users that are California residents to request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request, please contact us at the information provided in CONTACT US section below.

If you are a resident of California, under 18 and a user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to [email protected].

Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

13. Changes to This Privacy Policy

We reserve the right to amend this Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this Policy periodically for changes. Use of information we collect is subject to the privacy policy in effect at the time such information is used. If we make any material changes to this Policy, we will post the changes here. Please review the changes carefully. Your continued use of the Services following the posting of changes to this Policy will constitute your consent and acceptance of those changes.

14. Contact Us

If you have any queries relating to this Policy, you may contact us at:

www.ucpaa.org/contact