1. Introduction and Scope
Ashe & Klinetop CPAs (the “Firm,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information obtained through our website at https://asheklinetop.com (the “Site”).
The Firm provides certified public accounting, taxation, business valuation, financial reporting, and business consulting services. This policy applies to all visitors and users of the Site, including prospective and existing clients.
This policy does not apply to information collected offline, through other websites, or through any mobile applications. Separate engagement letters and privacy notices govern our client relationships as required by the Gramm-Leach-Bliley Act (GLBA) and applicable professional standards.
2. Information We Collect
2.1 Information You Provide Directly
We collect personal information you voluntarily submit, such as when you:
- Complete a contact or inquiry form (name, email address, telephone number, message);
- Request a complimentary estimate or consultation;
- Subscribe to newsletters or other communications;
- Correspond with us via email or through the Site.
2.2 Information Collected Automatically
When you visit the Site, we and our service providers automatically collect:
- Internet Protocol (IP) address and approximate geographic location;
- Browser type, version, and operating system;
- Pages visited, time spent on pages, and navigation paths;
- Referring website addresses;
- Device identifiers.
2.3 Cookies and Tracking Technologies
We use cookies, web beacons, pixels, and similar technologies to operate the Site and understand how it is used. You can manage your preferences through the cookie consent banner that appears on your first visit.
- Essential Cookies: Necessary for the Site to function properly and cannot be disabled.
- Analytics Cookies: Help us understand Site usage and improve the user experience (e.g., Google Analytics).
- Marketing/Advertising Cookies: Used to deliver relevant content and measure the effectiveness of our communications.
You may accept or reject non-essential cookies at any time via the cookie consent manager. Disabling non-essential cookies will not affect your ability to use the Site’s core features.
3. How We Use Personal Information
We use the information we collect to:
- Respond to your inquiries and provide requested information about our services;
- Schedule consultations or provide estimates;
- Send newsletters, tax updates, and other communications you have requested or to which you have consented;
- Operate, maintain, and improve the Site;
- Analyze usage patterns and enhance the user experience;
- Detect and prevent fraud, abuse, or technical issues;
- Comply with applicable legal, regulatory, and professional obligations (including GLBA, IRS Circular 230, and NY SHIELD Act requirements);
- Fulfill any other purpose with your consent or as otherwise permitted by law.
We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.
4. Disclosure of Personal Information
4.1 Service Providers
We share personal information with trusted third-party vendors who perform services on our behalf, such as website hosting, analytics, and email delivery. These providers are contractually required to protect your information and use it only to perform services for the Firm.
4.2 Professional Referral Partners
We may share information with professional referral partners (such as attorneys, financial advisors, or other service providers) only when necessary to fulfill a service you have requested and only with appropriate confidentiality protections in place.
4.3 Legal and Regulatory Disclosures
We may disclose personal information when required by law, court order, subpoena, government authority, or applicable professional standards, including IRS and state tax authority requirements.
4.4 Business Transfers
In the event of a merger, acquisition, sale of assets, or practice succession, personal information may be transferred to a successor entity subject to appropriate confidentiality protections and in accordance with applicable professional rules of conduct.
4.5 We Do Not Sell Personal Information
We do not sell your personal information to third parties for monetary consideration. We do not share your personal information with third parties for cross-context behavioral advertising unless you have provided consent or we have provided you with the opportunity to opt out as described in Section 5 of this policy.
5. California Residents — CCPA/CPRA Rights
This section applies to residents of the State of California and supplements the rest of this policy, as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”).
5.1 Categories of Personal Information Collected
In the past 12 months, we have collected the following categories of personal information from Site visitors:
- Identifiers: Name, email address, telephone number, IP address.
- Internet or electronic network activity: Browsing history on the Site, interactions with the Site, cookie data.
- Geolocation data: Approximate location derived from IP address.
- Professional or employment-related information: If voluntarily provided in an inquiry or contact form.
5.2 Purposes for Collection
The purposes for which we collect personal information are described in Section 3 of this policy.
5.3 Categories of Third Parties with Whom We Share Personal Information
- Website hosting and technology service providers;
- Analytics providers (e.g., Google Analytics);
- Email service and communications platform providers.
5.4 Your California Privacy Rights
California residents have the following rights, subject to certain exceptions:
- Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected, the sources, our purposes, and the third parties with whom we share it.
- Right to Delete: Request deletion of personal information we have collected about you.
- Right to Correct: Request correction of inaccurate personal information we maintain about you.
- Right to Opt Out of Sharing: Direct us to stop sharing your personal information with third parties for cross-context behavioral advertising.
- Right to Limit Use of Sensitive Personal Information: To the extent we collect sensitive personal information, direct us to limit its use to purposes authorized by law.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
5.5 How to Exercise Your Rights
To submit a verifiable consumer request, please contact us at:
Email: privacy@asheklinetop.com (include “California Privacy Request” in the subject line)
Mail: Ashe & Klinetop CPAs, Attn: Privacy Officer, 108 Buchmans Close Circle, Fayetteville, NY 13066-6680
To opt out of the sharing of your personal information for cross-context behavioral advertising, click the “Do Not Share My Personal Information” link in the footer of the Site, or use the cookie consent manager.
We will respond to verifiable requests within 45 days. If we require additional time, we will notify you in writing within the initial 45-day period. We may respond to up to two requests per 12-month period.
6. Gramm-Leach-Bliley Act (GLBA) Notice
As a provider of tax preparation, financial reporting, and related financial services, the Firm is subject to the privacy requirements of the Gramm-Leach-Bliley Act (GLBA) and the FTC Safeguards Rule. This website privacy policy supplements — but does not replace — the separate annual GLBA privacy notice provided to our clients.
We do not share nonpublic personal information (NPI) with non-affiliated third parties except as permitted by law, including to perform services on your behalf, comply with legal obligations, or with your consent. You may have the right to opt out of certain sharing; details are provided in the separate annual client privacy notice.
7. IRS Circular 230 and Professional Standards
Communications on this Site are provided for general informational purposes only and do not constitute tax, accounting, or legal advice. The Firm’s tax and accounting services are governed by IRS Circular 230 and applicable state CPA professional standards.
IRS Circular 230 Disclosure: To the extent any communication on this Site relates to a federal tax matter, it is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code, or (ii) promoting, marketing, or recommending to another party any tax-related matter addressed herein.
Nothing on this Site is intended to create an accountant-client relationship. A formal client relationship is established only through a signed engagement letter.
8. Data Retention
We retain personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by applicable law and professional standards. Generally:
- Contact and inquiry information: Up to 7 years from last contact, consistent with IRS, state tax authority, and professional recordkeeping requirements;
- Client engagement records: Retained in accordance with AICPA standards and applicable state CPA board requirements;
- Analytics data: Up to 26 months in aggregated or de-identified form.
9. Data Security
We implement reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, use, alteration, or destruction, consistent with our obligations under the FTC Safeguards Rule and the New York SHIELD Act. Our information security practices include written policies, employee training, and technical controls appropriate to the size and nature of our practice.
No security system is completely impenetrable. In the event of a data breach that affects your personal information, we will notify you as required by the New York SHIELD Act and other applicable laws.
10. Third-Party Websites
The Site contains links to third-party websites, including IRS resources, financial tools, and professional partner sites, provided for your convenience. We are not responsible for the content, accuracy, or privacy practices of third-party websites. We encourage you to review the privacy policy of any third-party site you visit.
11. Children’s Privacy
The Site is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has submitted personal information to us, please contact us at privacy@asheklinetop.com and we will promptly delete such information.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy on this page with a revised effective date. We encourage you to review this policy periodically. Your continued use of the Site following any posted changes constitutes your acceptance of the updated policy.
13. Contact Us
For questions about this Privacy Policy, to exercise your privacy rights, or to submit a privacy-related inquiry, please contact us:
Ashe & Klinetop CPAs
Attn: Privacy Officer
108 Buchmans Close Circle, Fayetteville, NY 13066-6680
Phone: 315.637.3195
Email: privacy@asheklinetop.com
For California residents submitting CCPA/CPRA requests, please include “California Privacy Request” in the subject line of your email.