PRIVACY POLICY
Last updated August 13, 2024
This privacy notice for Gina Tallman CPA LLC (doing business as bravuura advisory) ("we," "us," or "our"), describes
how and why we might collect, store, use, and/or share ("process") your information when you use our services
("Services"), such as when you:
Visit our website at http://www.bravuura.cpa, or any website of ours that links to this privacy notice
Download and use our mobile application (Canopy Client Portal), our Facebook application, or any other
application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you
do not agree with our policies and practices, please do not use our Services. If you still have any questions or
concerns, please contact us at team@bravuura.cpa.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of
these topics by clicking the link following each key point or by using our table of contents below to find the
section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process
personal information depending on how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We may process sensitive personal information when
necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we
process.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information only when we have a valid legal
reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in
specific situations and with specific third parties. Learn more about when and with whom we share your personal
information.
How do we keep your information safe? We have organizational and technical processes and procedures in place
to protect your personal information. However, no electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or
modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access
request, or by contacting us. We will consider and act upon any request in accordance with applicable data
protection laws.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an
interest in obtaining information about us or our products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and the products and features you use. The personal
information we collect may include the following:
names
phone numbers
email addresses
mailing addresses
job titles
usernames
passwords
contact preferences
contact or authentication data
billing addresses
debit/credit card numbers
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process
the following categories of sensitive information:
financial data
social security numbers or other government identifiers
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as
your payment instrument number, and the security code associated with your payment instrument. All payment data
is handled and stored by Canopy Payments. You may find their privacy notice link(s)
here: https://www.getcanopy.com/privacy-policy.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any
changes to such personal information.
Information collected when you use our Facebook application(s). We by default access your Facebook basic
account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as
other information that you choose to make public. We may also request access to other permissions related to your
account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual
permission. For more information regarding Facebook permissions, refer to the Facebook Permissions
Reference page.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also process your information for other purposes with
your consent.
We process your personal information for a variety of reasons, depending on how you interact with our
Services, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may
process your information so you can create and log in to your account, as well as keep your account in
working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you
with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your
inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our
products and services, changes to our terms and policies, and other similar information.
To enable user-to-user communications. We may process your information if you choose to use any of our
offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact
you about your use of our Services.
To save or protect an individual's vital interest. We may process your information when necessary to
save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal
reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you
with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business
interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely
on in order to process your personal information. As such, we may rely on the following legal bases to process your
personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your
personal information for a specific purpose. You can withdraw your consent at any time. Learn more
about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary
to fulfill our contractual obligations to you, including providing our Services or at your request prior to
entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to
achieve our legitimate business interests and those interests do not outweigh your interests and
fundamental rights and freedoms. For example, we may process your personal information for some of
the purposes described in order to:
Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance
with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency,
exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are
involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations involving potential threats to the safety
of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third
parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of,
any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another
company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice
unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy
notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this notice will require us keeping your personal information for longer than the period
of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete
or anonymize such information, or, if this is not possible (for example, because your personal information has been
stored in backup archives), then we will securely store your personal information and isolate it from any further
processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security
measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to
protect the security of any personal information we process. However, despite our safeguards and efforts to secure
your information, no electronic transmission over the Internet or information storage technology can be guaranteed to
be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we
will do our best to protect your personal information, transmission of personal information to and from our Services is
at your own risk. You should only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell
such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at gina@bravuura.cpa.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area
(EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time, depending on your country,
province, or state of residence.
In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability;
and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make such a request by contacting us by using the
contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also
have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be
express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any
time. You can withdraw your consent at any time by contacting us by using the contact details provided in the
section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when
applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and
promotional communications at any time by clicking on the unsubscribe link in the emails that we
send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details
provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed
from the marketing lists. However, we may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to respond to service requests, or for
other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate your account,
you can:
Log in to your account settings and update your user account.
Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our
active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems,
assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at team@bravuura.cpa.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT")
feature or setting you can activate to signal your privacy preference not to have data about your online browsing
activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing
DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy
notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is
not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky,
Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to
request access to and receive details about the personal information we maintain about you and how we have
processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to
withdraw your consent to our processing of your personal information. These rights may be limited in some
circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias,
postal address, telephone or mobile
contact number, unique personal identifier,
online identifier, Internet Protocol address,
email address, and account name
YES
B. Personal information as
defined in the California
Customer Records statute
Name, contact information, education,
employment, employment history, and
financial information
YES
C. Protected classification
characteristics under state
or federal law
Gender, age, date of birth, race and
ethnicity, national origin, marital status,
and other demographic data
YES
D. Commercial information
Transaction information, purchase history,
financial details, and payment information
NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar
network activity
Browsing history, search history,
online behavior, interest data, and
interactions with our and other websites,
applications, systems, and advertisements
NO
G. Geolocation data Device location NO
H. Audio, electronic,
sensory, or similar
information
Images and audio, video or call recordings
created in connection with our business
activities
NO
I. Professional or
employment-related
information
Business contact details in order to
provide you our Services at a business
level or job title, work history, and
YES
professional qualifications if you apply for
a job with us
J. Education Information Student records and directory information NO
K. Inferences drawn from
collected personal
information
Inferences drawn from any of the collected
personal information listed above to create
a profile or summary about, for example,
an individual’s preferences and
characteristics
NO
L. Sensitive personal
Information
Account login information, citizenship or
immigration status, drivers'
licenses, financial information including
account access details, personal data
from a known child, social security
numbers and state id card numbers
YES
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law
or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for
additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal
information. We do not collect or process sensitive personal information for the purpose of inferring characteristics
about you.
We may also collect other personal information outside of these categories through instances where you interact with
us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
Category A - As long as the user has an account with us
Category B - As long as the user has an account with us
Category C - As long as the user has an account with us
Category I - As long as the user has an account with us
Category L - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR
INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and
each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND
WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for
technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial
purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to
website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain
cases, we may decline your request as permitted by law. These rights include:
Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing
as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of
decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as
permitted by applicable law, including California's and Delaware's privacy law)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by
applicable law, including Oregon’s privacy law)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including
California’s privacy law)
Right to opt out of the collection of sensitive data and personal data collected through the operation of
a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject access request, by emailing us
at team@bravuura.cpa, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your
behalf. We may deny a request from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom
we have the information in our system. We will only use personal information provided in your request to verify your
identity or authority to make the request. However, if we cannot verify your identity from the information already
maintained by us, we may request that you provide additional information for the purposes of verifying your identity
and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your
identity before processing your request and the agent will need to provide a written and signed permission from you
to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our
decision by emailing us at team@bravuura.cpa. We will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you
may submit a complaint to your state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California
residents to request and obtain from us, once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all
third parties with which we shared personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your request in writing to us by using the
contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an
updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email
at gina@bravuura.cpa, by phone at 1-970-564-7584, or contact us by post at:
Gina Tallman CPA LLC
Data Protection Officer
135 Park Dr
Grand Junction, CO 81501-2060
United States
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT
FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request
access to the personal information we collect from you, details about how we have processed it, correct
inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our
processing of your personal information. These rights may be limited in some circumstances by applicable law. To
request to review, update, or delete your personal information, please fill out and submit a data subject access
request.