WE RESPECT YOUR PRIVACY

PRIVACY POLICY
Last updated February 27, 2025

This Privacy Policy for Henton & Associates, Inc. (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

  • Visit our website at https://hentoncpas.com, utilize our Services, or access or any website of ours that links to this Privacy Policy.
  • Engage with us in any way, through our Services.

Questions or concerns?
Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns regarding our practice, processes, and Services, please contact us at info@hentoncpas.com.

We are committed to maintaining robust data and privacy protection for our clients, customers and Service users. This Privacy Policy is designed to help you understand how we process and safeguard the information you provide to us or that we collect as part of the Services. By using our Services or website, you accept the terms and conditions contained in this Privacy Policy and consent to the processing of your personal, non-personal and/or business information, whether such information has been provided by you or collected by us.

SUMMARY OF KEY POINTS

For your convenience, this summary provides key points from our Privacy Policy.

What personal information do we process?
When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information?
Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not intend to process sensitive personal information.

Do we collect any information from third parties?
We do not intend to collect any information from third parties.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other reasonable business purposes. We will process your information when we have reason to do so.

In what situations and with which parties do we share personal information?
We may share information with third parties.

How do we keep your information safe?
We have organizational and technical processes and procedures in place to protect your information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights?
The easiest way to exercise your rights is by visiting https://hentoncpas.com/contact/ or by contacting us at info@hentoncpas.com. We will consider and act upon any request in accordance with applicable data protection laws.

1.  WHAT INFORMATION DO WE COLLECT?

We collect both “non-personal information” and “personal information.” Non-personal information includes information that cannot be used to personally identify you, such as browser type, device information, IP address, operating system, pages visiting on our site, and referring URLs. Personal information includes, but is not limited to, information such as names, email addresses, shipping addresses, billing addresses, payment information, purchase history, telephone numbers, telephonic recordings, chat communications, SMS messages and other information that could be used to personally identify you or a third-party. Through your use of the Services, you hereby agree and consent to our processing of both non-personal Information and personal information.

Personal Information You Disclose to Us

In Short: We collect information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest inobtaining information about us or our products and Services, when you participate in activities on theServices, or otherwise when you contact us.

Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with usand the Services, the choices you make, and the products and features you use. The personal information we collect may include, but is not limited to, the following:

  • names
  • phone numbers
  • email addresses
  • contact preferences

Sensitive Information
We do not intend to process sensitive information, however, we may incidentally process information that might be considered “sensitive”. If you believe us to be processing sensitive information, please contact us directly regarding deletion or removal of sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some non-personal information is collected automatically when you visit our Services.

We automatically collect certain non-personal information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

We also collect non-personal information through cookies and similar technologies.

The non-personal information we collect includes:

  • Log and Usage Data. Log and usage data is service­ related, diagnostic, usage, andperformance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your use of the Services (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).
  • Device Data. We collect device data such as information about your computer, phone,tablet, or other device you use to access the Services. 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, browser type, hardware model,Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tellsus your current location (based on your IP address). You can opt out of allowing us tocollect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out of sharing location data,you may not be able to use certain aspects of the Services.

2.  HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other reasonable business purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To deliver and facilitate delivery of Services to the user. We may process yourinformation to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process yourinformation to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to We may process your information tosend you details about our products and services, changes to our terms and policies, and other similar information.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another.
  • To save or protect an individual’s vital interest. We may process your informationwhen necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We process your information when we believe it is necessary and we have reason  to do so. For example, we will process your information with your consent, when required by law, to provide you with Services, to fulfill our contractual obligations, to protect your rights, to protect our rights, or to fulfill our legitimate business interests.

If you are located in the European Union or United Kingdom, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain thevalid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • We may process your information if you have given us permission (i.e.,consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us directly. Learn more about withdrawing yourconsent.

Performance of a Contract
We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you or a third party, including but not limited to cases in which we provide Services or at your request prior to entering into a formal contract to do so with you.

Legal
We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved, in any capacity.

Vital Interests
We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any

If you are located in Canada, this section applies to you.

We may process your information if you have given us permission (i.e., expressconsent) to use your information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by contacting us at info@hentoncpas.com.

In some exceptional cases, we may be legally permitted under applicable law to process yourinformation without your consent, including, for example:

  • If collection is clearly in the your best interest and your consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle a claim, including but not limited to insurance claims.
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4.  WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in situations with  third parties.

We may need to share your personal information, in specific situations, including but not limited to:

  • Business Transfers.
    We may share or transfer your information in connection with, orduring negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company or vice versa.
  • Third-Party Service Providers.
    We may share or transfer your information in connection with the provision of the Services utilizing third-party service providers that promote and facilitate the provision of the Services.
  • Reasonable Business Purposes.
    We do not intend to sell or profit off of the use or disclosure of your personal information.

5.  DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store yourinformation.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements, or to send reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these information tracking technologies are deemed to be a “sale”/”sharing”(which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use information regarding technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://hentoncpas.com/cookies.

Google Analytics
We may share your information with Google Analytics to track and analyze the use of theServices. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms Rag .

6.  HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by Jaw.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7.  HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizationaland technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, ho electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so wecannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security measures and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8.  DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

As it relates to the Children’s Online Privacy Protection Act of 1998, we do not knowinglycollect, solicit data from, or market to children under 18 years of age, nor do we knowingly sellsuch personal information. We do not intend to knowingly provide Services to persons under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of theServices. If we learn that personal information from users less than 18 years of age has been collected, we will terminate such unauthorized user’s access to the Services, deactivate the account, and/or take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@hentoncpas.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you haverights that allow you greater access to and control over your personal information You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtaina copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict theprocessing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision­ making. In certain circumstances, you may also have the rightto object to the processing of your personal information.

You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State dataProtection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection andInformation Commissioner.

Withdrawing your consent:
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicablelaw, you have the right to withdraw your consent at any time.. You can withdraw your consent at any time by contacting us by using the contact details provided in the section“HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing beforewithdrawal of consent nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of communications:
You can unsubscribe from our communications at any time by clicking on the unsubscribe link in the emails that we send, replying “STOP” or”UNSUBSCRIBE” to the SMS messages that we send, Emailing info@hentoncpas.com, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT USABOUT THIS NOTICE?” below. However, we may still communicate with you – for example, to send you service­ related messages that are necessary for the administration and use of your account and/or the Services, to respond to service requests, or for other non-marketing purposes. SMS messages will not be sent to you for any marketing or promotional purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. Ifyou prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://hentoncpas.com/cookies.

If you have questions or comments about your privacy rights, you may email us at info@hentoncpas.com.

10.  CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include aDo-Not-Track (“ONT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing ONT signals has been finalized. As such, we do not currently respond to ONT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser ONT signals. Because there currently is not an industry or legal standard for recognizing or honoring ONT signals, we do not respond to them at this time.

11.  DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and howwe have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information as defined in the California CustomerRecords
statute
Name, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data YES
D. Commercial informationTransaction information, purchase history, financial details, and payment informationNO
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsNO
G. Geolocation dataDevice locationYES
H. Audio, electronic, sensory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNO
I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us YES
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and
characteristics
NO
L. Sensitive personal InformationNO

We may also collect other personal information outside of these categories through instanceswhere you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests: and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A – As long as the user has an account with us
  • Category B – As long as the user has an account with us
  • Category G -As long as the user has an account with us
  • Category I – As long as the user has an account with us

Sources of Personal Information
Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information
Learn more about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

Will your information be shared with anyone else?
We may disclose your personal information with our service providers and/or third parties pursuant to a written contract between us and each service provider/third party. Learn moreabout how we disclose personal information to in the section, “WHEN AND WITH WHOM DOWE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We do not plan to sell or share (for our own profit) personal information belonging to website visitors, users, and other consumers.

Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, andin certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)
  • Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
  • Right to opt out of the collection of sensitive data and personal data collected throughthe operation of a voice- or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights
To exercise these rights, you can contact us by visiting https://hentoncpas.com/contact/, by emailing us at info@hentoncpas.com, by visiting https://hentoncpas.com/contact/, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, wemay request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need toprovide a written and signed permission from you to submit such request on your behalf.

Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@hentoncpas.com. We will inform you in writing of any action taken or not taken in response to the appeal, including awritten explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACTUS ABOUT THIS NOTICE?”

12. DO WE MAKE UPDATES TO THIS.NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this Privacy Policy, difficulty accessing our website and the information contained therein, or concerns related to our handing of data, you mayemail us at info@hentoncpas.com or contact us by post at:

Henton & Associates, Inc.
2012 W 25th St, Cleveland, OH 44113, USA Suite 509
Cleveland, OH 44113 United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about howwe process it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://hentoncpas.com/contact/.

We reserve the right to change our Privacy Policy at any time, with or without notice to you. Changes, revisions or clarifications will take effect immediately. You should periodically check for any updates or changes to our Privacy Policy on our website at https://hentoncpas.com/privacy

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