PRIVACY POLICY

This Privacy Policy describes how CBA Bookkeeping LLC, doing business as The Food Bookkeeper ("The Food Bookkeeper," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when you visit our website, submit information through our forms, communicate with us, schedule an appointment, engage with our marketing, or use our bookkeeping and related services (collectively, the "Services").

Our website is https://thefoodbookkeeper.com. This Privacy Policy should be read together with our Terms & Conditions, which govern your use of our website and Services.

By using our website or Services, you acknowledge the practices described in this Privacy Policy.

If you have questions about this Privacy Policy or our privacy practices, you may contact us at:

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide to Us
We collect personal information that you voluntarily provide when you interact with us, including when you:

• Submit a form on our website;
• Request information about our Services;
• Schedule an appointment;
• Contact us by email, telephone, or text message;
• Become a client;
• Complete an onboarding questionnaire;
• Provide information necessary for bookkeeping or related Services;
• Sign an agreement or other document;
• Opt in to marketing communications, including text messages;
• Respond to our marketing or advertisements; or
• Otherwise communicate with us.

Depending on the nature of your interaction with us, this information may include:

• Name;
• Email address;
• Telephone or mobile phone number;
• Business name;
• Information about how you found us;
• Business revenue information;
• Tax entity type;
• Appointment and scheduling information;
• Communications and correspondence with us;
• Information submitted through website forms;
• Information necessary to provide bookkeeping, accounting, tax-related, CFO, advisory, payroll, accounts payable, sales tax, or other Services;
• Business and financial records;
• Accounting and transaction information;
• Documents and supporting records provided by you;
• Information contained within accounting or business systems to which you authorize us to have access; and
• Other information you voluntarily provide to us.

Client Financial and Accounting Information
If you become a client, we may receive or access information necessary to perform our Services. This may include business financial records, transaction information, payroll-related information, sales tax information, accounting records, supporting documentation, and information contained within your QuickBooks account or other systems you authorize us to access.
We use this information primarily to provide the Services described in our agreement with you.
We do not use confidential client information for unrelated marketing purposes.
Our service agreement also provides that client confidential information remains the client's exclusive property and is used by The Food Bookkeeper as required to complete the Services.

Sensitive Personal Information
In the course of providing bookkeeping, payroll, tax, and related Services, we may collect or access categories of information that certain state laws classify as "sensitive personal information," such as Social Security numbers, financial account or routing numbers, and other government-issued identification numbers. We collect and use this information only as reasonably necessary to provide the Services, comply with our agreements with you, and meet applicable legal and tax obligations. We do not use sensitive personal information to infer characteristics about you, and we do not sell it.

Information Collected Automatically
When you visit or use our website, we may automatically collect certain technical and usage information.
This information may include:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Referring URLs;
• Pages viewed;
• Date and time of visits;
• General information about how you interact with our website;
• Website events and interactions;
• Information about advertisements you interact with; and
• Other technical information made available through your browser or device.

We use this information primarily for website operation, security, analytics, advertising, marketing, and improving our website and Services.

2. HOW DO WE USE YOUR INFORMATION?

We may use personal information for the following purposes:

• To provide our Services: We use information provided by clients and prospective clients to communicate with you, understand your business needs, onboard clients, provide bookkeeping and related Services, and fulfill our contractual obligations.
• To communicate with you: We may use your contact information to respond to inquiries, answer questions, provide requested information, coordinate Services, and communicate about your account or relationship with us.
• Appointment scheduling and reminders: If you schedule an appointment with us, we may use your contact information to confirm appointments and send appointment reminders.
• Transactional and operational text messages: If you are a client or a prospective client who has contacted us or requested information (for example, through our Get Started page), we may send non-marketing text messages related to your inquiry, appointment, or account such as responses to your inquiry, appointment confirmations and reminders, intake and document requests, and billing alerts as necessary to respond to you or administer our business relationship with you.
• Marketing and promotional communications: If you separately opt in, and consistent with your communication preferences, we may send marketing and promotional emails and text messages about our Services, educational content, offers, events, resources, or other information that may be relevant to you. Opting in to marketing text messages is never required to purchase or receive our Services. You may opt out of marketing emails by using the unsubscribe mechanism included in the email. For marketing text messages, you may opt out at any time by replying STOP, and you may request help by replying HELP or contacting us using the information in Section 19. Opting out of marketing communications does not prevent us from sending non-marketing communications that are necessary to provide Services, respond to your requests, or administer an existing business relationship.
• Advertising and marketing measurement: We may use information collected through cookies, pixels, tags, and similar technologies to understand the effectiveness of our advertising and marketing campaigns, measure website activity, and improve our marketing. This may include information collected through services such as Google Ads and Meta/Facebook Pixel.
• Website analytics and improvement: We may use website and usage information to understand how visitors use our website, identify technical problems, improve website performance, and improve the user experience.
• Security and fraud prevention: We may use information to protect our website, systems, business, clients, and users from fraud, unauthorized access, security threats, and other harmful activity.
• Legal and business purposes: We may use information when reasonably necessary to comply with applicable laws, regulations, legal processes, contractual obligations, enforce our agreements, establish or defend legal claims, protect our rights, or protect the safety and security of our business and others.

3. LEGAL BASES FOR PROCESSING

Depending on the law applicable to you, we may process personal information based on one or more of the following:

• Performance of a contract: When processing is necessary to provide Services or fulfill our agreement with you.
• Consent: When you voluntarily provide consent, including where consent is required for marketing communications, such as marketing text messages, or other processing.
• Legitimate business interests: When processing is reasonably necessary for legitimate business purposes, such as operating and improving our business, communicating with prospective clients, protecting our systems, preventing fraud, and measuring marketing performance.
• Legal obligations: When processing is necessary to comply with applicable laws, regulations, legal processes, or governmental requests.
• Protection of rights and interests: When processing is necessary to establish, exercise, or defend legal claims or protect the rights, safety, and security of our business, clients, employees, contractors, or others.

Where applicable law requires consent, we will obtain consent before processing information for the purposes requiring consent. For marketing text messages specifically, we obtain your affirmative, separate opt-in (typically through an unchecked checkbox) before enrolling you in that program.

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

We may disclose personal information to third parties when reasonably necessary to operate our business, provide our Services, communicate with you, process information on our behalf, or comply with legal obligations.
These third parties may include:

• Website hosting providers;
• Website and technology providers;
• Email marketing providers;
• SMS and communications providers;
• Scheduling and appointment providers;
• Customer relationship management platforms;
• Marketing and advertising platforms;
• Automation and integration providers;
• Accounting and financial software providers;
• Electronic signature providers;
• Video conferencing providers;
• Cloud storage and technology providers;
• Professional advisors;
• Contractors, employees, and subcontractors who require access to perform Services; and
• Government authorities, courts, regulators, law enforcement, or other parties when required or permitted by law.

Our current business technology providers may include:

• Google Ads;
• Meta/Facebook Pixel;
• ConvertKit;
• Zapier;
• Calendly;
• HubSpot;
• ManyChat;
• Zoom;
• QuickBooks;
• Beehiiv;
• Eversign; and
• WordPress/GoDaddy.

These providers may change from time to time as our business and technology needs change.
We may also disclose information as part of a business transaction, such as a merger, acquisition, financing, sale of assets, reorganization, or similar transaction.

No Sharing of SMS Opt-In Data for Third-Party Marketing
We do not share mobile phone numbers or SMS consent/opt-in information with third parties for their own independent marketing or promotional purposes. Text messaging originator opt-in data and consent are not shared with any third parties for purposes unrelated to providing the SMS communications you signed up to receive.

Service Providers and Subcontractors
The Food Bookkeeper may use employees, subcontractors, and subprocessors, including providers located in the United States or other countries, to assist in providing our Services.
Access to client information is limited to individuals and providers who reasonably need the information to perform their assigned responsibilities.
Where applicable, we require employees, contractors, and service providers to maintain confidentiality and appropriate data protection practices.

5. CLIENT CONFIDENTIALITY

We understand that bookkeeping and accounting Services may require clients to provide confidential business and financial information.
We treat client information as confidential and use it as reasonably necessary to provide the Services, comply with our agreement with the client, protect our business, and comply with legal obligations.
Our Service Agreement states that client confidential information remains the client's exclusive property and will only be used by The Food Bookkeeper as required to complete the Services.
Our Service Agreement also provides that client data is accessed on a least-privilege basis, transmitted and stored through encrypted systems, and is not copied to personal devices.
Passwords and logins are securely managed through Dashlane, with access limited according to our internal procedures.

6. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies and similar technologies on our website.
These technologies may include:

• Cookies;
• Pixels;
• Tracking tags;
• Web beacons;
• Analytics technologies; and
• Advertising technologies.

We may use these technologies for:

• Website functionality;
• Security;
• Remembering preferences;
• Website analytics;
• Understanding website traffic;
• Measuring advertising performance;
• Retargeting and advertising;
• Marketing attribution; and
• Improving our website and Services.

Third-party services such as Google Ads and Meta/Facebook may use tracking technologies in connection with advertising and measurement.
You can generally control cookies through your browser settings. Disabling cookies may affect certain website functionality.
Where required by applicable law, we will provide additional choices or controls for cookies and targeted advertising.

7. TEXT MESSAGES AND SMS COMMUNICATIONS

This section describes our SMS practices in accordance with A2P 10DLC and CTIA guidelines. It should be read together with the SMS Terms in our Terms & Conditions.

Program/Company Name: CBA Bookkeeping LLC dba The Food Bookkeeper.

If you provide your mobile phone number, we may use it to send:

• Transactional/operational messages — such as appointment reminders, responses to your inquiries, document requests, billing alerts, and other service-related communications tied to your relationship with us as a client or prospective client; and
• Marketing/promotional messages — such as promotional offers, educational content, and announcements about our Services but only if you have separately and affirmatively opted in to marketing text messages (typically via an unchecked checkbox at the point your number is collected).

Message Frequency: Message frequency varies depending on the type of messages you have opted into and your engagement with us; marketing message frequency is typically 2 to 6 messages per month.

Cost: Message and data rates may apply depending on your mobile carrier and plan.

Consent Not Required for Purchase: Consent to receive marketing text messages is not a condition of purchasing our Services, and you may decline SMS marketing opt-in while still becoming or remaining a client.

Opt-Out: You may opt out of marketing SMS messages at any time by replying STOP to any message. Upon doing so, you will receive a one-time confirmation message and no further marketing messages will be sent unless you opt in again. You may also contact us using the information in Section 19 to request removal from marketing text communications. Opting out of marketing text messages does not necessarily stop transactional/operational messages related to Services you have requested or an existing business relationship.

Help: For help, reply HELP to any message, or email us at hello@thefoodbookkeeper.com.

Carrier Disclaimer: Wireless carriers are not liable for delayed or undelivered messages.

We do not sell or rent SMS opt-in information, and we do not share mobile phone numbers or SMS consent information with third parties for their own independent marketing purposes.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide and administer our Services;
• Maintain business and client records;
• Fulfill contractual obligations;
• Comply with tax, accounting, legal, regulatory, and professional obligations;
• Resolve disputes;
• Enforce agreements;
• Protect our legal rights; and
• Maintain appropriate business records.

The specific retention period depends on the type of information, the purpose for which it was collected, our relationship with you, and applicable legal or contractual requirements.
When information is no longer reasonably necessary, we may delete, anonymize, or securely dispose of it, subject to legal, contractual, backup, and legitimate business requirements.

9. HOW DO WE PROTECT YOUR INFORMATION?

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or destruction.
Our practices may include:

• Limiting access to information based on business need;
• Using encrypted systems for transmission and storage where appropriate;
• Using secure systems for managing passwords and credentials;
• Restricting access to client systems;
• Requiring confidentiality and data protection obligations for relevant employees, contractors, and subprocessors; and
• Maintaining procedures for addressing potential security incidents.

However, no method of transmitting or storing information electronically is completely secure. Therefore, while we take reasonable steps to protect personal information, we cannot guarantee absolute security.
If we become aware of a material security incident affecting client data, we will provide notice as required by applicable law and, where applicable, our contractual obligations.

10. INFORMATION ABOUT CHILDREN

Our website and Services are intended for business owners, professionals, and adults.
We do not knowingly collect personal information from children under 13 through our website.
We do not knowingly direct our marketing or Services toward children.
If we learn that we have collected personal information from a child in circumstances where collection is not permitted, we will take reasonable steps to delete the information as required by applicable law.

11. YOUR PRIVACY RIGHTS

Depending on where you live and the laws that apply to you, you may have certain rights regarding your personal information.
These rights may include:

• The right to know whether we process your personal information;
• The right to access personal information we maintain about you;
• The right to request correction of inaccurate information;
• The right to request deletion of personal information, subject to applicable exceptions;
• The right to obtain a copy of certain personal information in a portable format;
• The right to opt out of certain processing activities, such as targeted advertising, where applicable;
• The right to withdraw consent where processing is based on consent, including SMS marketing consent;
• The right to opt out of certain marketing communications; and
• The right not to receive unlawful discrimination for exercising applicable privacy rights.

These rights are subject to applicable legal limitations and exceptions.
For example, we may need to retain certain information to comply with legal obligations, maintain required business records, complete transactions or Services, resolve disputes, prevent fraud, protect security, or establish or defend legal claims.

12. HOW TO EXERCISE YOUR PRIVACY RIGHTS

To request access, correction, deletion, opt-out of targeted advertising, or take other action concerning your personal information, contact us at:

Please provide enough information for us to reasonably identify you and understand your request.
Depending on the nature of the request and applicable law, we may need to verify your identity before completing the request.
We will process valid privacy requests within the time required by applicable law.
You may also designate an authorized agent to submit a privacy request on your behalf, subject to our ability to verify the agent's authority to act on your behalf as required by applicable law.

13. U.S. STATE PRIVACY RIGHTS

Certain U.S. states have enacted comprehensive privacy laws that provide residents with additional rights.
Whether a particular law applies to The Food Bookkeeper depends on factors such as the applicable law's scope, thresholds, exemptions, and the nature and volume of information processed. We do not believe our current data processing activities meet the applicable thresholds under most state privacy laws; however, we extend the rights described in this section as a matter of practice.
Where a state privacy law applies to our processing of your personal information, we will provide the rights and disclosures required by that law.
These may include rights to:

• Access or confirm processing of personal information;
• Correct inaccurate information;
• Delete personal information;
• Obtain portable copies of personal information;
• Opt out of certain targeted advertising or profiling;
• Opt out of the sale of personal information where applicable;
• Limit the use or disclosure of sensitive personal information, where applicable; and
• Exercise other rights provided by applicable state law.

To exercise any of these rights, use the contact information in Section 12. If you are a California, Colorado, or Connecticut resident and our use of advertising cookies or pixels is considered "sharing," "targeted advertising," or "sale" under applicable law, you may opt out by contacting us at hello@thefoodbookkeeper.com or by using a Global Privacy Control signal as described in Section 14.

California Residents
California residents may have additional rights under the California Consumer Privacy Act, as amended, if the law applies to our business.
These rights may include the right to know, delete, correct, opt out of certain sales or sharing, limit certain uses of sensitive personal information, and receive equal treatment for exercising applicable privacy rights.
The Food Bookkeeper does not sell personal information for monetary consideration.
If our use of advertising or tracking technologies is considered "sharing" or otherwise constitutes targeted advertising under a law applicable to you, you may have the right to opt out of that processing.
California residents may submit privacy requests using the contact information provided in this Privacy Policy.

14. GLOBAL PRIVACY CONTROL AND DO-NOT-TRACK SIGNALS

Some browsers and devices provide a "Do Not Track" feature that sends a signal indicating that a user does not want to be tracked.
Because there is not a universally accepted technical standard for responding to Do Not Track signals, our website may not respond to such signals unless required by applicable law.

Where required by applicable state law, we honor the Global Privacy Control ("GPC") signal as a valid request to opt out of the sale or sharing of personal information, and targeted advertising, for the browser or device sending the signal. If we detect a GPC signal from your browser, we will treat it as an opt-out request for that browser to the extent required by applicable law. Because a GPC signal is tied to a specific browser and device, you may need to enable it separately on each browser or device you use.

15. THIRD-PARTY WEBSITES AND SERVICES

Our website, communications, advertisements, or Services may contain links to websites, applications, or services operated by third parties.
We are not responsible for the privacy practices, security, or content of third-party websites or services.
When you interact with a third-party service, that service may collect and process your information under its own privacy policy.
We encourage you to review the privacy policies of third-party services before providing them with personal information.

16. BUSINESS TRANSFERS

If The Food Bookkeeper is involved in a merger, acquisition, financing, reorganization, sale of assets, or other business transaction, personal information may be transferred as part of that transaction.
Any such transfer will be handled in accordance with applicable law and the confidentiality obligations applicable to the information.

17. INTERNATIONAL DATA PROCESSING

Because The Food Bookkeeper may use employees, contractors, subprocessors, and technology providers located in different countries, personal information may be accessed, processed, or stored outside the state or country in which you reside.
Where required by applicable law, we will take appropriate steps concerning international transfers and data protection.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, Services, technology, legal requirements, or privacy practices.
When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy.
We encourage you to review this Privacy Policy periodically to understand our current privacy practices.

19. HOW TO CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

20. ACKNOWLEDGMENT

By using our website or submitting information to The Food Bookkeeper, you acknowledge that you have had an opportunity to review this Privacy Policy and our Terms & Conditions.
Nothing in this Privacy Policy limits any rights you may have under applicable privacy or data protection laws.