California Consumer Privacy Act Disclosures

Effective January 1, 2025

This notice and policy supplements information contained in the Privacy Policy provided by WonderTax Labs LLC and its corporate business affiliates ("WonderTax Labs") and applies solely to residents of the State of California ("consumers" or "you") with respect to personal information WonderTax Labs processes as a business. Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations ("CCPA") have the same meaning when used in this notice and policy. This notice and policy does not reflect our collection, use, or disclosure of California residents' personal information, or data subject rights, where an exception or exemption under the CCPA applies.

1. CCPA RIGHTS

As a California resident, you have the following rights under the CCPA:

1.1. The right to know what personal information we have collected about you, including the categories of personal information, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of personal information we have collected about you.
1.2. The right to delete personal information that we have collected from you, subject to certain exceptions.
1.3. The right to correct inaccurate personal information that we maintain about you.
1.4. The right to opt-out of the sale or sharing of your personal information by us.
1.5. The right to limit our use and disclosure of sensitive personal information to purposes specified in subsection 7027(l) of the CCPA regulations. We do not use or disclose sensitive personal information for purposes other than those specified in subsection 7027(m) of the CCPA regulations.
1.6. The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights

To submit a request to exercise a right, please submit an email request to dataprivacy@wonder.tax.

You may opt-out of the sale or sharing of your personal information for targeted advertising through our Cookie Policy or by implementing the Global Privacy Control.

2. NOTICE AT COLLECTION ONLINE

We have set out below categories of personal information about California residents we collect online.

Category of personal information or sensitive personal information under CCPA definitions	Purpose for collection and use of personal information	Sold or shared	Retention time
2.1. Characteristics of protected classifications under California or federal law.	Comply with regulatory obligations.	No	Employment data is retained for the duration of such relationships and to meet our regulatory obligations.
2.2. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers. Specifically, real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, and account name.	Provide and improve services, authenticate for service access, fraud detection and prevention, security, troubleshoot, event planning and hosting, consider individuals for job opportunities and onboarding processes for hired individuals, communicate with you, provide materials you request, including white paper downloads, provide chat functionality on our website, to follow up with you upon your registrations for online seminars or in-person events, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners.	Yes	Online form data is deleted after five years of inactivity; log data is retained for a minimum of one year; employment data is retained for the duration of such relationships and to meet our regulatory obligations.
2.3. Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. (The categories of personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) Specifically, name, address, telephone number, passport number, driver's license or state identification card number, social security number, education, employment, employment history, and bank account number.	Provide and improve services, authenticate for service access, fraud detection and prevention, security, troubleshoot, event planning and hosting, consider individuals for job opportunities and onboarding processes for hired individuals, communicate with you, provide materials you request, including white paper downloads, provide chat functionality on our website, follow up with you upon your registrations for online seminars or in-person events, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners.	No	Online form data is deleted after five years of inactivity; employment data is retained for the duration of such relationships and to meet our regulatory obligations.
2.4. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. Specifically, information regarding a consumer’s interaction with an internet website application or advertisement.	Provide and improve services, authenticate for service access, fraud detection and prevention, security, troubleshoot, event planning and hosting, communicate with you, provide materials you request, including white paper downloads, provide chat functionality on our website, to follow up with you upon your registrations for online seminars or in-person events, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners.	Yes	No more than 140 days
2.5. Geolocation data. Specifically, location using IP addresses	Provide and improve services.	Yes	30 days
2.6. Professional or employment related information. Specifically, employer and job title.	Provide and improve services, event planning and hosting, consider individuals for job opportunities and onboarding processes for hired individuals, communicate with you, white paper downloads, provide chat functionality on our website, follow up with you upon your registrations for online seminars or in-person events, provide material you request, understand your preferences to enhance your experience, and send you relevant information about us, our affiliates.	No	Online form data is deleted after five years of inactivity
2.7. A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Specifically, account log-in and credentials allowing access to an account.	Contact details and password when users create an account with WonderTax Labs's website.	No	Lifetime of customer

3. NOTICE OF COLLECTION OF SENSITIVE PERSONAL INFORMATION

We have set out below categories of sensitive personal information about California residents we collect.

Category of personal information or sensitive personal information under CCPA definitions	Purpose for collection and use of personal information	Sold or shared	Retention time
3.1. A consumer's social security, driver’s license, state identification card, or passport number.	Provide services, authenticate for service access, fraud detection and prevention, security, including anti-money laundering and know-your-customer obligations, and onboarding processes for hired individuals.	No	Customer and employee data is kept for the duration of such relationships and to meet our regulatory obligations; with respect to customer data, such obligations may vary by product.
3.2. A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Specifically, account log-in and credentials allowing access to an account.	Provide services	No	Customer and employee data is kept for the duration of such relationships and to meet our regulatory obligations; with respect to customer data, such obligations may vary by product.
3.3. A consumer's precise geolocation. Specifically, a consumer's precise geolocation within conference spaces.	Event planning and hosting, tracking attendance for CPE reporting, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners.	No	No more than 140 days.
3.4. A consumer's racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership. Specifically, racial or ethnic origin and citizenship or immigration status.	Comply with regulatory obligations.	No	The duration of the employment relationship and to meet our regulatory obligations.
3.5. The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication. Specifically, email messages.	Fraud detection and prevention, and security.	No	To meet our regulatory obligations.
3.6. Personal information collected and analyzed concerning a consumer's health. Specifically, health information related to employee benefits, leave, and accommodations.	Provide services.	No	The duration of the employment relationship and to meet our regulatory obligations.

4. OUR PERSONAL INFORMATION HANDLING PRACTICES IN 2024

We have set out below categories of personal information about California residents we have collected and disclosed for a business purpose in the preceding 12 months. The table is followed by a description of the purposes for which we collected personal information.

Category of personal information or sensitive personal information under CCPA definitions	Categories of third parties to which personal information was disclosed	Business or commercial purpose for disclosure
4.1. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Specifically, real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, social security number, driver’s license number, passport number, and account name.	Our service providers including our CRM service provider, cloud services and data warehousing providers, data analytics providers, logging and log management services, HR and recruiting software providers, benefits providers, security services, communication and productivity software and services, social networks, WonderTax Labs affiliates and subsidiaries, partners, to third parties subject to compelled disclosures, and to payment processors.	To perform services on our behalf, including to organize data, maintain the security of our systems and networks, manage our employee base and provide benefits, better understand our customers, prospective customers, and employees, marketing, and advertising. To our subsidiaries and affiliates (those entities under common control), to provide services, such as customer support, marketing, technical operations, and account management purposes. To our partners, to provide integrations that enable our services to interconnect with third party software and to support our mutual customers. We may also disclose your data to our partners to co-sponsor events that you choose to attend. To our payment processor, to manage credit card processing. To relevant governmental authorities if required by law or to comply with a judicial proceeding, court order, or valid legal process. We may also disclose your data to third parties to protect our rights and property, our agents, employees, partners and customers, including to prevent or stop an attack on our systems or network or to prevent spam or attempts to defraud our users. We may alsodisclose your personal information to third parties to disclose your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.
4.2. Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, but excluding publicly available information that is lawfully made available to the general public from federal, state, or local government records. (The categories of personal information described in the California Customer Records Act (Cal. Civ. Code § 1798.80(e)) Specifically, name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or other financial information, medical information, or health insurance information.
4.3. Characteristics of protected classifications under California or federal law. Specifically, gender marital status, race/ethnicity, national origin, gender identity, disability, requests for family care leave, medical leave, pregnancy disability leave, military and veteran status, and age if 40 years or older.
4.4. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Specifically, records of products or services purchased including those purchased by employees as work-related expenses.
4.5. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. Specifically, browsing history, search history, and information regarding a consumer's interaction with an internet website application or advertisement
4.6. Geolocation data. Specifically, location information based on IP addresses and precise geolocation within conference spaces.
4.7. Audio, electronic, visual, thermal, olfactory, or similar information. Specifically, data relating to WonderTax Labs employees' use of computers, software, networks, communications devices, and other similar systems that we or our affiliates own or make available to you; or you connect to or use for the purposes of providing services to us or our affiliates; and information relating to your activities on our or our affiliates' premises
4.8. Professional or Employment related information. Specifically, job information, compensation, benefits, contact information, work history.
4.9. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). Specifically, education history.
4.10. A consumer's social security, driver's license, state identification card, or passport number.
4.11. A consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Specifically, account log-in, credentials allowing access to an account.
4.12. A consumer's racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership. Specifically, racial or ethnic origin and citizenship or immigration status.
4.13. The contents of a consumer's mail, email, and text messages unless the business is the intended recipient of the communication. Specifically, email messages of WonderTax Labs employees.
4.14. Personal information collected and analyzed concerning a consumer's health. Specifically, health information related to receiving employee benefits, leaves, and accommodations.

5. Business or Commercial Purpose for Collecting Personal Information.

WonderTax Labs uses the personal information that it collects to provide and improve services, authenticate for service access, detect and prevent fraud, security, troubleshoot, plan and host events, communicate with you, provide materials you request, including white paper downloads, provide chat functionality on our website, to follow up with you upon your registrations for online seminars or in-person events, understand your preferences to enhance your experience and send you relevant information about us, our affiliates, and partners.

WonderTax Labs collects such information from the following categories of sources:

5.1. Directly from You. WonderTax Labs may collect personal information when you: inquire about one of our services or purchase our services; send an email to WonderTax Labs or start a live chat with us; interact with our website, products or services; register for an event or seminar; download content like white papers; create an account with us; and use our mobile services.
5.2. Cookies and Other Technologies. WonderTax Labs and its affiliates and trusted third parties may use cookies or other technologies to collect data about your device and activity on our website.
5.3. Third Parties, including Service Providers. WonderTax Labs may also collect personal data from other sources, including third parties from whom we have purchased data, and we may combine this data with data we already have about you. For example, we may collect personal data from:
- 5.3.1. Partners. WonderTax Labs may engage in joint marketing activities or event sponsorships with our third-party partners and we may collect personal data about you from these activities. We also allow partners to provide referrals to WonderTax Labs of individuals who may be interested in learning more about WonderTax Labs's services.
- 5.3.2. Service Providers. WonderTax Labs may also engage with third party service providers who help us understand how our customers are using WonderTax Labs's services.

6. COMMITMENT REGARDING DEIDENTIFIED INFORMATION

If we process deidentified information, we will maintain the information in a deidentified form and not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether the deidentification processes used satisfy legal requirements.

7. AUTHORIZED AGENT

You can designate an authorized agent to make a request under the CCPA on your behalf if:

7.1. The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and
7.2. You directly confirm with WonderTax Labs that you provided the authorized agent with permission to submit the request.

If you use an authorized agent to submit a request to exercise your right to know, correct or your right to request deletion, please provide any information WonderTax Labs requests to verify your identity. The information that WonderTax Labs asks you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

8. CONTACT FOR MORE INFORMATION

If you have any questions or comments about this notice and policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at: Email address: dataprivacy@wonder.tax.

Postal address:

WonderTax Labs LLC
Attention: General Counsel
1 Marshall Street, Suite 205,
Norwalk, CT 06854-2262, USA

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