1. Overview
This Privacy Policy describes how Goldberg, Gluck & Brusilovsky LLP ("we," "our," or "the Firm") collects, uses, stores, and protects personal information through our secure client portal (the "Portal"). This Portal is a web application that allows clients and staff to securely exchange tax documents, track engagement progress, and communicate regarding tax preparation services.
By using this Portal, you acknowledge the practices described in this policy. If you do not agree with this policy, please do not use the Portal.
2. Information We Collect
We collect only the information necessary to provide our tax preparation and accounting services. The categories of personal information we collect are:
2.1 Account & Authentication Data
- Email address — used for account identification and Portal communications
- Full name — used for account identification and document labeling
- Hashed password — stored using secure hashing (bcrypt); we never store plain-text passwords
- Multi-factor authentication (MFA) secret — only if you enable MFA on your account
- Role — your permission level (client, admin, or staff role) used to control access
2.2 Client Profile Information
- First and last name — of the primary client
- Company name — if applicable
- Phone number — optional, for communication
- Mailing address — optional, for correspondence
- Last 4 digits of SSN — used for identity verification with tax authorities
2.3 Tax Engagement Data
- Tax year information — which tax years are associated with your account
- Tax return status — workflow status (info needed, in progress, reviewed, completed, filed)
- Organizer question answers — your responses to tax organizer questionnaires
- Engagement notes — notes created by you or our staff during the engagement
- Task assignments — tasks assigned to staff members regarding your engagement
2.4 Document Uploads
- Tax documents — W-2s, 1099s, K-1s, receipts, and other tax-related files you upload
- Document metadata — filename, file size, MIME type, upload timestamp, category
- Review status — whether documents have been reviewed by staff
2.5 Messages & Communications
- Message content — subject lines and body text of messages exchanged through the Portal
- Read receipts — timestamp when you read a message
2.6 System & Security Logs
- IP address — recorded for security auditing and abuse prevention
- Authentication events — login, logout, failed login attempts, password changes
- Audit trail — actions performed on the Portal (document uploads, link creation, status changes)
- Session metadata — last login timestamp, account creation date, last activity
2.7 PDF Linker Tool Data (Staff Only)
- Uploaded PDF files — temporarily stored during link creation sessions
- Link configuration data — source/target page numbers, link coordinates, labels
- Session manifests — tracking files for PDF linker sessions
3. How We Use Your Information
We use the information we collect for the following purposes:
- Providing tax preparation and accounting services
- Authenticating your identity and securing your account
- Managing tax engagement workflows (document collection, review, filing)
- Communicating with you about your engagements
- Generating internal routing sheets and task assignments
- Complying with legal and regulatory obligations (IRS, state tax authorities)
- Preventing fraud, abuse, and security incidents
- Improving Portal functionality and performance
4. Data Storage & Security
Infrastructure: All data is stored on PostgreSQL databases and encrypted file storage hosted on cloud infrastructure within the United States.
Encryption: Passwords are hashed using bcrypt with a cost factor of 12. Data in transit is encrypted via TLS 1.2+. File uploads are encrypted at rest.
Access controls: Role-based access control (RBAC) restricts data access. Clients can only see their own data. Staff access is limited by role (preparer, reviewer, admin). Row-level security policies enforce data isolation.
Authentication: We support multi-factor authentication (MFA). Session tokens are HttpOnly, Secure, and SameSite=Lax. Failed login attempts trigger account lockout.
Audit logging: All authentication events, data access, and state-changing actions are logged with IP addresses for security auditing.
Session security: PDF upload sessions are isolated per user with file-backed session tracking and cross-process file locking.
5. Third-Party Services
We use the following third-party services in operating this Portal:
| Service | Purpose | Data Shared |
|---|---|---|
| OpenRouter | AI model routing | API requests (no personal data) |
| OpenAI | AI receptionist model | Chat messages (anonymized) |
| Edge TTS | Text-to-speech (offline) | None (processed locally) |
| DuckDNS | Dynamic DNS | IP address (for DNS updates only) |
We do not use analytics platforms (Google Analytics, Mixpanel, Segment), advertising networks, or social media tracking pixels.
6. Data Retention
Account data: Retained for the duration of your relationship with the Firm, plus 7 years to comply with IRS record-keeping requirements and state regulations.
Tax documents: Retained for 7 years from the filing date, per IRS requirements.
Messages: Retained for the duration of the engagement, plus 3 years.
Audit logs: Retained for 3 years for security and compliance purposes.
PDF Linker temporary files: Automatically cleaned up after 24 hours. Orphaned files from failed operations are cleaned within 30 minutes.
Session data: PDF upload session data expires after 24 hours of inactivity.
7. Your Rights
As a user of this Portal, you have the following rights regarding your personal data:
- Access: You can view all personal data associated with your account through the Portal dashboard.
- Correction: You can update your profile information (name, phone, address) at any time.
- Deletion: You may request complete deletion of your account and associated data by contacting us.
- Data portability: You may request an export of your data.
- Withdraw consent: You may withdraw consent for non-essential data processing.
To exercise any of these rights, contact us at the address provided in Section 9.
8. Data Deletion Request Process
To request deletion of your account and personal data:
- Contact us via email at admin@ggbcpa.net with the subject line "Data Deletion Request"
- Include your full name and email address associated with your account
- We will verify your identity before processing the request
- Your data will be permanently deleted within 30 days of verification
- You will receive confirmation once deletion is complete
Note: Some data may be retained where required by law (e.g., IRS record-keeping requirements). Retained data will be isolated and not used for any purpose other than legal compliance.
9. Contact Information
Goldberg, Gluck & Brusilovsky LLP
950 Tower Lane, Suite 110
Foster City, CA 94404
Phone: (650) 837-9800
Email: admin@ggbcpa.net
For privacy-specific inquiries, include "Privacy Request" in your email subject line.
10. Cookies & Browser Storage
This Portal uses the following browser storage mechanisms:
- HttpOnly authentication cookies — `access_token` and `refresh_token` cookies used solely for session authentication. These are Secure, HttpOnly, and SameSite=Lax.
- localStorage — Used to store your JWT token for API authentication. No personal data is stored in localStorage.
- sessionStorage — Used to persist wizard state (PDF upload progress, link configurations) during a single browser session. This data is cleared when you close the browser tab.
We do not use tracking cookies, analytics cookies, advertising cookies, or any third-party tracking mechanisms.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we make material changes, we will update the "Last updated" date at the top of this page and notify you through the Portal.
12. Regulatory Compliance
As a CPA firm, we are bound by the following regulations regarding your data:
- IRS Circular 230 — governs the practice of tax practitioners and requires confidentiality of taxpayer information
- Gramm-Leach-Bliley Act (GLBA) — requires financial institutions to explain their data-sharing practices and protect sensitive data
- California Consumer Privacy Act (CCPA) — provides California residents with rights regarding their personal information
- AICPA Code of Professional Conduct — requires CPAs to maintain client confidentiality