Whittlesey, PC Privacy Policy

Revised September 29, 2023

This Privacy Policy (the “Policy”) is designed to assist you in understanding how Whittlesey, P.C. d/b/a Whittlesey ( the “Firm”, “we”, “our”, “us”) collects, uses, shares, and safeguards the information you provide us when you visit our website (https://www.wadvising.com/) (the “Site”), interact with us by phone or in person, or engage us to provide you with tax, accounting, advisory, or other offered services (together our "Services"). This Policy also explains the choices you have regarding this information.

Please note that unless expressly otherwise stated in this Policy, we do not sell or otherwise exchange for value your Personal Information.

This Policy generally states our Personal Information privacy practices. We may agree to provide more specific protections in the context of a particular contract for Services or a contractual addendum, based for example on client-specific regulatory requirements our professional rules of ethics, and so on. In cases where the provisions of such contracts or addenda conflict with or differ from the provisions of this Policy, the provisions of such contracts or addenda shall be controlling.

What do we mean by “Personal Information”?

As used in this Policy, “Personal Information” is any information that either directly or indirectly identifies or, alone or in combination with any other information, could reasonably be used to identify, locate, or contact a natural person, including name, street address, telephone number, email address, identification number issued by a governmental authority, credit card number, bank information, customer or account number, online identifier, device identifier, IP address, browsing history, search history, or other website, application, or online activity or usage data, location data, biometric data, medical or health information, or any other information that is considered "personally identifiable information," "personal information," "personal data", “non-public personal information”, “protected health information”, “federal tax information”, or other similar term under applicable law, and all data associated with any of the foregoing that are or could reasonably be used to develop a profile or record of the activities of a natural person across multiple websites or online services, to predict or infer the preferences, interests, or other characteristics of a natural person, or to target advertisements or other content or products or services to a natural person.

Collection and Use of Personal Information

We collect Personal Information, such as the following, from you when you:

Contract for Services. In order for us to provide you with requested Services, you may be required to provide contact and billing information, as well as financial, health, employment, family, real and personal property information, and so on, depending on the Services requested. We collect this information so that we may create and manage your account, deliver requested Services, and contact you if needed.
Contact Us. When you contact us by phone or email or through our Site, we collect your identifiers, such as your name, phone number, and email address, and any other information you would like to share with us. If available, we also collect your internet activity information, like your IP address. We collect this information so that we can communicate with you concerning your questions and comments, troubleshoot where necessary, diagnose technical and service problems, and address any issues you have with our Site or Services and provide personalized customer service support.
Sign up to receive our newsletters or blog posts. When you sign up to receive our newsletters or blog posts, we collect identifiers such as your name and email address. We collect this information so that we can share our news and blogs with you.
Register for an event. When you register with us for an event or a webinar, we collect your identifiers, such as your name, email, and phone number. We may also collect your professional or employment information like the name of the company you represent, your job title, department, and your business contact information. We collect this information so that we can contact you and keep an internal record of attendees and those interested in our Services.
Access our file-share portal(s). When you access the file share portal(s) on our Site or through links that we provide you in email communications in order to securely upload or download confidential information and digital files, we collect your identifiers, such as your name and email address. We do not, however, collect your password. We use third-party portal providers, which gives you sole control over and responsibility for your portal passwords.
Download or access resources. When you download or access fillable forms, documents, publications, video and audio recordings, and other resources made available on our Site, we may collect identifiers such as your name, email address, phone number, and your professional and employment information like the name of the company you represent, your job title, department, and business contact information. We collect this information so that we can contact you and keep an internal record of those interested in our Services.
When we market to you. When we send you marketing communications, we process your identifiers such as your name and email address so that we may send you relevant information and keep you informed of news and services in which you might be interested.
When you provide a testimonial. When you provide a testimonial, we may post customer testimonials on our Site, which may contain the customer's name. We always get consent from the customer prior to posting any testimonial. If you wish to update or delete your testimonial, you can contact us at marketing@wadvising.com.
Otherwise when you give us your consent. We will notify you and request consent to use your Personal Information for any purpose materially different from the purposes disclosed herein.

Information we collect indirectly through your use of our Site

When you visit our Site, we automatically process your identifiers such as your IP address, your location, and your internet activity information like your usage data and browsing actions. We may also process the type of device, operating system, and technical data about your equipment.
Log data. Our servers automatically record certain information sent by your web browser, such as your web page or resource request, your IP address, your referring/exit URLs, your web browser type and operating system, and the date and time of your request.

We collect this information using cookies and similar tools to enable the functionality of our Site, to assess and improve our Site. For more information on cookies and tracking technology, see the section below titled “What Cookies We Use And Why”.

Social media widgets. Our Site and Services may from time to time include social media features, such as Facebook^TM, LinkedIn^TM and X^TM These features may collect identifiers about you such as your IP address and your internet activity information such as which pages you visit on our Site. Your interactions with those features and their use of the information collected are governed by the privacy policies of the companies that provide them.

For more information on your choices with respect to information collected through cookies and similar technologies, see Your Choice With Respect To Your Personal Information below.

Information Provided by Third Parties

When you post comments or interact on social media, for example, by responding to our blog, we see your comments and identifiers such as your social media handle.

What Cookies We Use and Why

“Cookies” are small pieces of text sent to and stored by your web browser by a website you visit. We place and store cookies for multiple purposes. Cookies enable us to personalize your viewing experience. When you revisit our Site, we can recognize you by the cookie and customize your experience at the Site accordingly. For example, we use cookies to track Site usage and traffic patterns, prevent fraudulent activity or improve Site security, and assess the performance of the Site.

To enable and improve your browsing and user experience and to track your chat activity on our Site (if we choose to offer a chat feature), we use cookies and similar tools for the purposes described below:

Required: These cookies are required for making use of the Site. These cookies include security cookies to authenticate users, prevent fraudulent use, and protect user data from unauthorized parties as well as session cookies that remember your log-in session so you can move easily within the Site.
Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site. All information of these cookies collect is aggregated. These cookies are not essential to use our Site. However, if you do not allow these cookies we will not know when you have visited our Site and will not be able to monitor its performance.
Analytics: Our service providers, including Google, use cookies as part of their tools. These cookies allow our service providers and us to recognize and count the number of users of the Site, to see how users move around the Site, and how they engage with different functions, including usage statistics, when they are using the Site. This helps us improve the way our Site works, for example by making sure our users are finding what they need easily.
Targeting: These cookies may be set through our Site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Other trackers. Our Site contains electronic images known as “web beacons” (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. If you would like to opt out of our sharing of this information, you can contact us at the contact information below.

Google Analytics. We use a tool called “Google Analytics” to collect information on your use of the Site. We use the information we get from Google Analytics to improve the Site. In order to collect this information, Google Analytics may set cookies on your web browser or mobile device or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to the Site or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those policies here for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google.

How To Manage Cookies

You may also use your web browser to enable, disable, or delete Cookies. To do this, follow the instructions provided by your web browser. Each web browser is different and may appear differently depending on the device being used, so we encourage you to review the instructions provided by your specific web browser.

If you enjoy using various browsers, then you will want to address the cookie controls in each of the browsers you use. Below are links to the cookie controls for some common web browsers:

If your browser is not listed above, we suggest that you either look in your browser's help setting or search for “cookies” together with your browser name on the Internet.

Note that using your web browser to disable cookies may reduce our Site’s functionality. For more information about how to manage and delete cookies, visit aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online.

How we Share your Personal Information

Disclosure while providing our Services. We may make your identifiers (name, email, contact, and billing information), account history information, and information that you submit for purposes of receiving Services, to our employees only on a need-to-know basis, as necessary for the employee(s) to fulfil their job duties with respect to the Services.
Service Providers. We share your identifiers (name, email, contact, and billing information), account history information, and Site activity information (such as your log data, location information, online identifier, IP address, and information regarding your interaction with our Site), and information that you submit for purposes of receiving Services with service providers that provide support services to us, such as marketing services, analytics providers, web hosting providers, payment processors, and professional service providers that assist us in carrying out our Services to you, in each case only to the extent necessary to deliver the Services.
Cookies. We collect information about your Internet activity through cookies and similar tools to enable the functionality of our Site and to assess and improve our Site. For more information on cookies, see the section above titled What Cookies We Use And Why.
To prevent harm. To prevent harm, we will share your Personal Information, which may include name, email, address, phone number, and internet activity information (such as your log data, location information, online identifier, IP address, and information regarding your interaction with our Site), if necessary, to law enforcement personnel and agencies, to meet government security requirements, to protect our property, in furtherance of an investigation regarding a breach of the Site rules and policies, unauthorized access to or use of the Site or any other illegal activities.
Legal and regulatory compliance. To comply with applicable laws, regulations, and legal requests, such as subpoenas or court orders, we may need to disclose your Personal Information, which may include name, email, address, phone number, information submitted in connection with obtaining Services, and internet activity identifiers (such as your log data, location information, online identifier, IP address, and information regarding your interaction with our Site).

How We Store And Protect Your Personal Information

We make all reasonable efforts to ensure that your Personal Information is stored securely, both in electronic and physical form, and otherwise protect it from misuse, interference, and loss caused by unauthorized access, modification or disclosure. The security of your information is important to us. When you enter sensitive information through our Site, for example, we encrypt that information using secure socket layer technology (SSL). Our employees, agents, and service providers are obliged to treat confidentially any Personal Information entrusted to us. Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure, therefore, we cannot guarantee absolute security. If you have any security questions, please contact us at the Contact Information below.

Your Choice With Respect To Your Personal Information

Marketing. We enable you to opt out of marketing communication. You may unsubscribe by emailing us or by clicking the Unsubscribe button toward the bottom of each marketing communication.
For all other requests or inquiries concerning Personal Information, please contact us at the Contact Information below.

Jurisdiction-Specific Privacy Rights

Our Services and the information on this Site are directed generally toward businesses entities, nonprofit organizations, and their representatives, who are located within the United States. Depending on your location, you may have certain privacy rights under applicable state, federal, or international privacy laws. If or when such jurisdiction-specific privacy rights become applicable to our Services, we will provide any required notices under such laws either directly in communications with you or in this section.

If you are a resident of a jurisdiction in which a particular privacy law applies and you wish to submit a request to exercise applicable privacy rights, please contact us at the Contact Information given below. Please be advised that we may not be a covered entity under such law, or certain rights in question may be subject to exceptions. In our response to you, should we not be a covered entity or should an exception exist, we will communicate why the law does not apply to us and/or which exception applies, as the case may be.

We will not discriminate against you for exercising any of these rights, nor will we deny you services, charge you a different price, or provide you with a lesser quality of services.

Children’s Privacy

This Site and our Services are not intended for individuals under the age of eighteen (18) years. Accordingly, we do not knowingly collect or share information from minors or children, except as volunteered by their parents or legal guardians.

Changes to this Privacy Policy

This Policy may be updated and changed from time to time. We will post the new Policy on the Site and will indicate the date it goes into effect. If the changes materially affect your rights, our Site will contain a special notice about the changes and, if required by law, will prompt you for your consent for certain changes. Each version of this Privacy Policy will be identified by its effective date, which you can find at the bottom of this Policy.

Contact Us

If you have any questions or comments about our privacy practices, you can contact us at:

Whittlesey, P.C.

ATTN: Privacy

Jeremy Raines

280 Trumbull Street, 24^th Floor

Hartford, CT 06103