Sciba Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how information about you is collected, used, and disclosed by Scriba Tax AI LLC and its affiliates (collectively, “Scriba,” “we,” “us” or “our”) when you access or use our website (https://www.scriba.tax/), mobile application(s), or (the “Platform”), tax, and other services (the “Services”) (the Platform and Services being, collectively, the “Offerings”).

This Privacy Policy applies to your use of our Offerings, and covers only information collected in connection with your access to and use of our Offerings. Please read this Privacy Policy carefully.

In some instances, we may also process personal information on behalf and at the direction of some professional or business partners or customers. Those partners and customers have their own obligations under applicable data privacy laws, and we are not responsible for their information practices. In these circumstances, this Privacy Policy does not apply. Instead, you should refer to the partner’s or customer’s privacy notice if you have any questions about how they handle your personal information.

We may provide you with a different privacy notice or policy in certain specific situations, in which case that privacy notice or policy will apply to the personal information collected or processed in that specific situation, rather than this one.

If you provide us with personal information related to anyone other than yourself, please note that you are responsible for complying with all privacy and data protection laws prior to providing that information to Scriba (including collecting consent, if required).

I. Information We Collect and How We Collect It

When you access or use our Offerings, we collect and store certain information about you, including “personal information.” Personal information is information that, alone or in combination with other information in our possession, could be used to personally identify you. We collect the following categories of personal information and other information as described below.

A. Information collected from third parties

We may collect and receive information about you, including personal information, from third parties, such as your employer, your employer’s accountant or service providers, financial institutions, credit bureaus, insurance carriers and third-party administrators, and our service providers, for the purposes described in this Privacy Policy. In addition, we may receive demographic and business industry information about you from third parties to help us better understand our users and to improve and market the Services. As part of our Offerings, we gather certain tax information. This information may be gathered from governmental and other public and private sources.

B. Information you provide

We may collect or receive the following categories of personal information when you access the Platform, request to receive information about Scriba or its Services, create an account, verify your identity, use any of the Offerings, or otherwise communicate with us, including through customer support channels.

• Financial Information, such as your bank account and routing numbers, bank account balance, and transaction information.
• Identification Information, such as your name, mailing and addresses, phone number, birthdate, Social Security number, Taxpayer Identification number, driver’s license, or passport.
• Taxpayer Information, such as you or your employer’s Federal Employer Identification Number (FEIN), tax withholding selections, including how many dependents you have, jobs you’ve worked in a year, and your tax filing status.
• Life and Health Information, such as identification information for you and your dependents, and life events and conditions that impact benefits eligibility, including marital status, employment information, and illness or disability information.
• Other Information You Provide. We may collect information, including personal information, that you voluntarily provide to us, including survey responses, feedback or comments, and application information if you apply for a job.

C. Information collected automatically

We may automatically collect certain information when you access or use the Offerings.

• Communication Information, such as audio, electronic, or visual information, data in any files uploaded, emailed or otherwise provided by customers, the contents of your communications with us, and inferences we may make from other Personal Information we collect.
• Electronic & Online Identifiers (IDs), such as device type, model, and ID, network information, and browser and operating system type.
• Internet Activity Information, such as your “log-in” and “log-out” information, the pages you visit, links you click, and content you view.
• Tracking Technologies, such as cookies, which are small text files that websites send to your computer or mobile device and pixel tags (also known as web beacons), which are pieces of code embedded in our Services that collect information about engagement on our Platform or emails. This includes session cookies (which are deleted once you close your browser) and persistent cookies (which remain on your computer or device until you delete them or they expire).
• Third-Party Analytics Tools, such as Google Analytics, New Relic, and Bugsnag, to assist us with analyzing our website traffic and help us improve the performance of our Offerings. These services may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
• Social Media Platforms. Our Services may contain social media buttons such as Facebook, LinkedIn, Twitter, and Instagram (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

II. How We Use Your Information

We may use information that we collect about you for the following purposes:

• To develop and provide you with the Offerings, including to determine your eligibility for our Offerings, improve, personalize, and enable your use of the Offerings, and develop new products and features.`
• To protect Scriba, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), monitor and enforce compliance with the applicable Terms of Service, detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable.
• To operate our business, including to process payment transactions, manage and enforce contracts with you or third parties, manage our corporate governance, compliance, and auditing practices, and generate anonymized or aggregated data.
• To communicate with you, including to respond to requests or questions you submit, send surveys about the Offerings, or provide notices.
• To advertise and market to you, including to determine your eligibility for certain programs, events, and offers, inform you of our or our partners’ products, services, features or promotions, provide you with newsletters, articles, reports, and announcements, or develop “interest-based” or “personalized advertising,” including through cross-device tracking.
• For any other purpose for which you, your employer, or your employer’s agent expressly authorize us to use your information.

III. When and with Whom We Share Your Information

We will only share your information with the categories of third parties listed below for the purposes described above in Section II, unless otherwise noted at the point of collection.

• Third-Party Tax Preparers that you have identified or authorized to access your information.
• Service Providers that have signed an agreement that limits how they use your information and promises to keep your information confidential. Examples include banks, financial institutions, and credit bureaus, companies or organizations that provide services such as website hosting (ex: AWS), customer management (ex: Salesforce) and customer service, and tax preparers who partner with Scriba.
• Government agencies, including taxing authorities and their authorized collectors, in the countries in which we operate, only as necessary for us to provide you with the Offerings.
• Advertising Partners that deliver advertisements about us to you, including Advertising Partners that utilize Tracking Technologies in order to deliver advertisements that are personalized to you when you visit their websites (“interest-based advertising” or “personalized advertising”).
• Other third parties:

• for legal reasons, including with companies that verify your identity for us and detect fraud, with legal and financial advisors, auditors, examiners, and certain (including potential) investors, and with companies that may acquire us, if we are involved in a merger, acquisition, or sale of assets.
• to comply with applicable law, regulation, or legal process, including to comply with legal process, such as a court order or subpoena (including in a country other than your home country), protect your, our, or others’ rights, property, or safety, and enforce our policies or contracts and collect amounts owed to us.
• to manage any referral program, including emailing potential customers that you have referred to us, which reference your name as the referral source.
• to further public policy goals, including publishing reports that incorporate aggregated, and or de-identified information about customer attributes, transactions, and behavior, and sharing data containing aggregated and/or de-identified customer information with non-profit or non-partisan organizations.
• for any other purpose and to any other person with whom you, your employer, or your employer’s agent expressly authorize us to share your information.

IV. Your Privacy Choices and Rights

Your Privacy Rights. Depending on where you reside and in accordance with applicable law, you may have various rights with regard to your Personal Information, including:

• Access – The right to request access to and obtain a copy of any Personal Information we may have about you.
• Deletion – The right to delete your Personal Information that we have collected or obtained, subject to certain exceptions.
• Correction – The right to request that we correct any inaccuracies in your Personal Information, subject to certain exceptions.
• Opt-Out of Certain Processing – The right to: (a) opt out of the processing of your Personal Information for purposes of targeted advertising, (b) opt out of the sale of your Personal Information; (c) limit the use of your sensitive Personal Information (if applicable), and (c) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
• Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
• Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
• Automated Decision-Making – The right to know when you are subject to automated decision-making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
• Lodge a Complaint ¬– The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any applicable rights please contact us using the resources in the “Contact Information” Section below. We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity.
Where we collect your sensitive Personal Information, we will only do so where we have obtained your prior express consent, if required by law. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

‍Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email and Text Messages. We may send promotional email and text messages. You can opt out of our promotional emails by using the unsubscribe link located at the bottom of our promotional emails or contacting us as described below. You can opt out of text messages from us by replying “STOP” or contacting us as described below. If you decide to opt-out, we may still send you non-promotional communications related to your use of the Offerings and messages about your account.
• Mobile Notifications. We may send you push notifications through our mobile app. You can opt out from receiving push notifications by changing the settings on your mobile device.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy setting you can set on some web browsers that signals to websites like ours that you don’t want your online activities to be tracked. At this time, we do not respond to DNT signals sent to us by your web browser.
• Cookies and Interest-Based Advertising. You may stop us from sending Tracking Technologies to your browser by changing the settings on your browser. However, if you block all Tracking Technologies, certain Offerings (or function or features) may not work properly. Please note you must separately opt out in each browser and on each device.

V. Important Information

A. Security

We employ administrative, physical, and technical measures designed to protect your information from unauthorized access and to comply with applicable privacy laws in the states and countries in which we operate. Your personal information will be kept on our servers or on those of our service providers and only those employees, contractors, and other third-parties that require it for the purposes of their duties will have access to your personal information. We have also implemented controls which require our third-party service providers and partners to have appropriate safeguards to protect your personal information. However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosures.

B. International Data Transfers

All information processed by us or our service providers may be transferred, processed, or stored anywhere in the world, including in countries that may have data protection laws that are different from the laws where you live. Your information may be accessible to the courts, law enforcement, and national security authorities of the United States. We endeavor to safeguard your information consistent with the requirements of applicable laws. If your personal information is transferred to a country other than your home country, we will take measures to protect your personal information with appropriate contract clauses. To obtain more information about Scriba’s policies and practices with respect to service providers outside your country, please contact us as set forth below.

C. Links to Other Sites

This Privacy Policy only covers the privacy practices of Scriba. It does not apply to the practices of third-party websites, services, or applications, even those who we have partnered or integrated with. Third-party services handle your information in accordance with their own practices and privacy policies. We are not responsible for their policies, practices, or handling of your information.

D. Our Policy Toward Children

The Offerings are not directed to children under 18. However, if a child under the age of 18 is a dependent of a customer or otherwise relevant to a customer’s tax filing, we may collect information about the child (solely as needed to provide the Offerings) from or at the direction of the child’s parent or legal guardian, or from third-parties with information potentially relevant for tax purposes.

E. Changes to this Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time to time. If we make any material changes to this policy, we will notify you of such changes by posting them on the Platform, informing you through the Services or Platform, or sending you an email or other notification, and we will indicate when such changes will become effective.

F. Contact Information

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your privacy rights as detailed in this Privacy Policy, please contact us at:

Scriba Tax AI LLC
clientsuccess@scriba.tax