Privacy Policy for Onward Finance + Accounting

Effective Date / Last updated: March 22, 2024

Onward Finance + Accounting, LLC (“ONWARD”, “we”, “our”, “us”) values and respects individual privacy and is committed to upholding personal data protection. This Privacy Policy (“Privacy Policy”) outlines our data collection practices, detailing the types of information, including Personal Data, that ONWARD processes through our websites, including https://www.onwardcpas.com/, as well as other online tools, such as cloud-based applications for accounting services, secure file transfers, and file storage (collectively, the “Services”). This Privacy Policy explains individual rights concerning ONWARD’s collection, use, and disclosure of Personal Data related to the Services.

Within this Privacy Policy, “Personal Data” refers to information that identifies an individual or household directly or indirectly, through identifiers such as name, identification number, location data, online identifiers, or other factors specific to an individual’s identity.

The terms of this Privacy Notice do not supersede any corporate agreements with your employer or any other organization affiliated with you that have contracted for ONWARD services (“Agreement(s)”). Should there be any conflict between this Privacy Notice and such Agreement(s), the terms of the Agreement(s) will prevail.

If you have questions about our privacy practices or user privacy rights, please refer to the end of this Privacy Policy for information on how to contact us.

I. PERSONAL DATA COLLECTION

a. ONWARD collects certain Personal Data from Users through the Services.

b. Types of Personal Data Collected:

• Personal Data collected through the Services may include Cookies; Usage Data; email addresses; first names; last names; phone numbers; and IP addresses.

• Detailed descriptions of each type of Personal Data are provided in the specific sections of this Privacy Policy or via explanatory messages prior to data collection.

• Personal Data may be voluntarily provided by the User, or, in the case of Usage Data, may be collected automatically when using the Services.

• Unless specified otherwise, all Personal Data requested by the Services is mandatory for User functionality, and failure to provide such data may impede ONWARD from delivering Services. Where some Personal Data is labeled as optional, Users are free to withhold this data without affecting the functionality of the Services.

• Users who are uncertain about what Personal Data is necessary for the Services may contact ONWARD for clarification.

c. Users are responsible for obtaining any third-party Personal Data shared through the Services and must ensure they have the third party’s consent for providing such data to ONWARD.

d. In addition to this Privacy Policy, ONWARD can provide additional contextual information about particular Services regarding the collection and processing of Personal Data when requested.

II. USE OF PERSONAL DATA AND PURPOSE OF PROCESSING

a. ONWARD processes Personal Data, including sharing it with third parties, when necessary for our legitimate business interests and for the performance of the Services as described in this section. ONWARD does not sell Personal Data that we collect.

b. The purposes for collecting Personal Data through the Services include:

• Providing Services to Users

• Conducting analytics on the Services

• Contacting Users

• Displaying content from external platforms

• Managing contacts and sending communication

• Handling registration and authentication

• Operating internal directories, system logs, and routine maintenance

• Enhancing the effectiveness of our Services

• Conducting audits, if necessary

• Providing information to representatives and advisors to meet legal, accounting, or security requirements

• Transferring information in the case of a merger or sale of business

• Resolving disputes between Users, clients, and ONWARD

• Protecting rights, safety, and information pertaining to ONWARD, clients, and third parties

• Complying with legal obligations and responding to enforcement requests, as well as detecting potential fraudulent activity

c. Users' Personal Data may also be used for legal purposes by ONWARD in court or in preceding stages of any legal actions arising from misuse of the Services. Users acknowledge that ONWARD may be required to disclose Personal Data when requested by public authorities.

d. ONWARD may aggregate, anonymize, and/or pseudonymize any collected data, including Personal Data, for purposes such as performing the Services, improving data accuracy, or expanding data sets and research.

III. WHO CAN ACCESS PERSONAL DATA COLLECTED

a. ONWARD will only disclose Personal Data as specified in this Privacy Policy, as permitted by law, or with User consent. Third parties processing Personal Data on our behalf are required to comply with applicable laws and adhere to ONWARD’s instructions.

b. Personal Data may be accessible to personnel involved in the operation of the Services (administration, sales, marketing, legal, IT) or to external parties (e.g., technical service providers, mail carriers, IT companies) assigned as Data Processors by ONWARD.

c. ONWARD may disclose Personal Data to the following entities and for specified purposes:

• Clients and Authorized Business Partners to deliver Services

• Employees with authorized access to Personal Data

• Contractors and Service Providers who perform functions on behalf of ONWARD, requiring Personal Data to execute those roles. Such Contractors will also be obligated to follow applicable legal standards regarding Personal Data.

• For Legal Compliance or to Protect ONWARD’s Rights. Disclosure of Personal Data may occur when necessary to meet legal requirements, enforce agreements, protect rights and property, prevent crime, or coordinate with other organizations for protection against fraud.

• In relation to a Merger or Sale of Business. ONWARD may need to disclose Personal Data during significant corporate transactions, including business sales, mergers, or similar events.

IV. MODE AND PLACE OF PROCESSING DATA

a. ONWARD employs appropriate security measures to safeguard Personal Data against unauthorized access, modification, or destruction. We utilize industry-accepted security practices and have implemented reasonable technical measures to protect User’s Personal Data integrity and confidentiality. However, while ONWARD strives to maintain a secure environment, we cannot guarantee absolute security for Personal Data transmitted over the Internet.

b. Processing of Personal Data is conducted using computers and IT tools with organizational measures related to the purposes outlined in this policy.

c. ONWARD may process Personal Data when one of the following occurs:

• Users have consented to the processing for specified purposes.

• Data is necessary for the performance of an agreement with the User or related pre-contractual obligations.

• Processing is essential for compliance with ONWARD’s legal obligations.

• Processing pertains to a task carried out in the public interest or authorized by ONWARD.

• Processing is required for legitimate interests of ONWARD or third parties.

d. ONWARD is happy to clarify the legal basis that justifies any processing of User Personal Data, including whether such processing is statutory, contractual, or necessary for entering into a contract.

e. Personal Data processing occurs at ONWARD’s operational offices and additional locations where relevant processing parties are based.

f. Depending on User location, transferring Personal Data may involve movement to a different country.

g. Users have the right to understand the legal basis for transferring Personal Data outside of the European Union or to any international organization, and the security measures ONWARD has enacted to ensure data protection.

V. RETENTION OF PERSONAL DATA

a. Personal Data will be processed and stored as long as necessary for the purposes for which it was collected.

• Personal Data collected for contractual purposes between ONWARD and the User (or User’s employer) will be kept until the contract is fulfilled.

• Data collected for ONWARD’s legitimate business interests will be retained as required.

• ONWARD may retain Personal Data longer if the User consents to such processing and does not revoke that consent.

• Legal obligations or authoritative orders may necessitate longer retention periods for Personal Data.

b. Once the applicable retention period ends, Personal Data will be deleted. Therefore, the right to access, erase, correct, and port data cannot be enforced after this period.

VI. RIGHTS OF USERS

a. Users have certain rights regarding their Personal Data processed by ONWARD.

b. Specifically, Users reserve the right to:

• Withdraw consent at any time regarding previously agreed processing of their Personal Data.

• Object to the processing of Personal Data under legal bases excluding consent.

• Access their Personal Data to verify its processing by ONWARD and request copies thereof.

• Verify and seek corrections for the accuracy of their Personal Data.

• Restrict processing of their Personal Data under certain circumstances.

• Request deletion of their Personal Data when justified.

• Receive their Personal Data in a structured, commonly used, machine-readable format and transfer it to another controller where feasible.

• File a complaint with their relevant data protection authority.

c. When Personal Data is processed in the public interest or for ONWARD's legitimate interests, Users may object to such processing with justified reasons.

d. If Personal Data is processed for direct marketing purposes, Users can object at any time without giving reasons. ONWARD does not engage in direct marketing with collected Personal Data.

e. Any requests to exercise User rights should be directed to ONWARD using the contact information provided in this Privacy Policy.

VII. COOKIE POLICY

When Users first access the Services from certain areas, they will receive a notification indicating that cookies are in use. By clicking “accept,” Users consent to ONWARD’s cookie usage as described in this Privacy Policy. Users wishing to decline cookies may withdraw their consent or configure their browser to reject cookies or alert them when cookies are placed. Such actions may impact the functionality of the Services. For detailed information regarding our specific use of cookies, please refer to our “Cookie Policy” incorporated herein. ONWARD may also permit certain third parties to utilize cookies to collect data on Users’ online activities across other sites to aid us in Services analytics.

VIII. HOW “DO NOT TRACK” REQUESTS ARE HANDLED

The Services do not support “Do Not Track” requests. To determine if third-party services used or linked to our Services honor such requests, please review their privacy policies.

IX. THIRD PARTY SERVICES

The Services may contain links to third-party websites, applications, and services not operated by ONWARD. These links are intended for user convenience and do not imply ONWARD’s endorsement or association with those services. ONWARD disclaims responsibility for the privacy practices of any third party, including sites linked to or from our Services.

X. MINORS AND CHILDREN’S PRIVACY

ONWARD does not knowingly collect Personal Data from children under 18. If we discover that we have collected Personal Data from minors, we will take steps to delete this information. Parents or guardians who discover their child has submitted Personal Data to ONWARD without consent may contact us at info@onwardcpas.com so we can take appropriate action to remove it.

XI. DEFINITIONS

a. “Data Processor” means the individual, company, public authority, or other entities processing Personal Data on behalf of the controller as indicated in this Privacy Policy.

b. “Data Subject” refers to the individual to whom Personal Data pertains.

c. “Usage Data” includes information collected automatically through the Services (or third-party services used), including IP addresses, request URIs, response sizes, and other related metrics.

d. “User” denotes the individual utilizing the Services who is usually the Data Subject.

XII. MISCELLANEOUS

a. Users may request additional information regarding the collection or processing of Personal Data from ONWARD at any time. Please refer to our contact information for further inquiries.

b. Changes to this Privacy Policy

• ONWARD reserves the right to modify this Privacy Policy at any time by notifying Users through the Services and/or via available contact methods. Users are encouraged to frequently check the Services for updates, referencing the modification date.

• If changes to this Privacy Policy impact how we process Personal Data based on User consent, ONWARD will seek new consent from Users as required.

XIII. CONTACT INFORMATION FOR DATA CONTROLLER

Onward Finance + Accounting, LLC

3436 Magazine St. Front PMB 341

New Orleans, LA 70115

(504) 688-2272

info@onwardcpas.com