Privacy Policy
Notice at Collection for Employees and Job Applicants
Notice of Right to Opt-Out of the Selling or Sharing of Your Personal Information
Current Privacy Policy
Last Modified: December 30, 2022
Introduction
Novogradac & Company LLP and its affiliates (collectively, Novogradac, we, us, or our) respects your privacy and is committed to protecting it through compliance with this policy.
This policy applies to information we may collect from you or that you provide when you visit our websites, including but not limited to www.novoco.com, www.novogradacevents.com, training.novoco.com, and when you use our applications made available on the Google PlayStore, the Apple App Store, or the Amazon App Store (together, our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to personal information we collect:
- On this Website.
- By telephone, when placing orders for products available on our Website or completing the conference registration process by phone.
- In email, text and other electronic messages between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- When you use any application we advertise, promote, provide, upload, or otherwise make available to you, including on the Apple App Store, the Google PlayStore, or any other similar platform.
This policy also applies to:
- The personal information we may receive, collect, use, or obtain through or as part of a professional services engagement with our clients, such as the contact information for our clients’ employees.
- The personal information we may receive, collect, use, or obtain through or as part of the services we receive from our vendors, such as the contact information for our vendors’ employees.
- Provided to us offline, such as when a conference attendee registers at the physical conference location.
- The personal information we may receive that is not expressly excluded from this policy.
This policy does not apply to information collected by:
- Us that identifies another business.
- Us through or as part of a professional services engagement with our clients to the extent the information is not the personal information of an individual. Information collected as part of a professional engagement is subject to applicable professional rules, such as those promulgated by the American Institute of Certified Public Accountants or the Uniform Standards of Professional Appraisal Practice.
- Us by any other means, including on any other website operated by Novogradac, its affiliates, or a third party.
- Us through or as part of our relationship with our employees or from job applicants when they send us their resume or complete an application.
- Any third party, including our affiliates, through any application or content that may link to or may be accessible from our Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies, your choice is to not use our Website. By accessing or using our Website, you agree to this privacy policy. This policy may change time to time (see Changes to Our Policy). Your continued use after we make changes constitutes your acceptance of these changes, so please check the policy periodically for updates.
Access by Children under the Age of 16
Our Website is primarily intended for use by businesses and professionals in the affordable housing, community development, historic preservation, renewable energy, historic preservation and opportunity zones fields. It is not intended that the Website be used by minors. No part of our Website is structured to attract children under the age 16. Consistent with the Federal Children's Online Privacy Protection Act and/or applicable state or local law, we will never knowingly request personally identifiable information from anyone under the age of 16, and we will never knowingly sell or share personally identifiable information of anyone under the age of 16. Children under the age of 16 are hereby instructed to exit this Website without providing your own personally identifiable information to us.
Categories of Personal Information Collected from Website Visitors and Other Individuals Who Contact Us
We collect certain types of personal information when you visit our Website or otherwise contact us. In the past 12 months we have collected one or more of the following personal information categories:
- Identifiers, such as your name, username, postal address, unique personal identifier, IP address, email address, or an account name.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as your name, address, phone number and email address.
- Protected classification characteristics under federal, state, or local laws.
- Commercial information, such as records of your purchases made on our Website.
- Internet or other similar network activity, such as browsing history, log in history, website interaction and search history.
- Geolocation data.
- Professional or employment-related information, such as your job title and where you work.
- Non-public education information, such as transcripts, grades and coursework.
- Inferences drawn from other personal information, such as mailing list preferences.
In the preceding 12 months one or all of the personal information categories above may have been provided to Novogradac’s service providers or other third parties, as described below.
Categories of Personal Information Collected from Client Engagements
The specific personal information we collect varies by the scope and type of services we are providing. The broad range of services we provide means we collect and process many categories of personal information. In the past 12 months our clients have provided us with one or more of the following personal information categories regarding themselves (if our client is an individual) and/or individuals associated with them:
- Identifiers, such as name, email address, postal address and similar information.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)).
- Protected characteristics under Federal, California or other state or local laws
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Professional or employment-related information.
- Inferences drawn from other personal information.
- Sensitive personal information, such as social security numbers or similar governmental identification data and demographic data. This data is only collected and used to provide our professional services, such as preparing tax returns.
Novogradac generally collects personal information directly from our clients or from third parties acting on the instructions of a client. In limited circumstances, Novogradac will collect personal information directly from our client, such as the personal information of an individual for whom we are preparing their tax returns.
In the preceding 12 months one or all of the personal information categories above may have been provided to Novogradac’s service providers or other third parties, as described below.
Personal Information Exclusions
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the scope of the California Consumer Privacy Act and/or another privacy law.
Retention of Personal Information
We will retain the personal information disclosed to us for the period of time reasonably necessary to achieve the disclosed collection and use purposes. We are unable to provide retention periods for the categories of personal information we collect. Instead, we will retain information based on the nature of our relationship with you, whether we provide professional services to you or to a company with which you are associated, the applicable statute of limitations, and/or other business considerations.
Selling or Sharing Your Information
In the preceding 12 months, Novogradac has sold personal information disclosed to us by conference attendees to third parties, such as the sponsors of our conferences, as part of their sponsorship of the conference, to allow them to plan their exhibits, their marketing plans, and related business purposes. We provide these third parties with the following categories of information:
- Identifiers.
- Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code Sec. 1798.80(e)).
- Professional or employment-related information.
The California Consumer Privacy Act defines “sharing” to mean the sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communication personal information to a third party for cross-context behavioral advertising purposes (Cal. Civ. Code §1798.140(ah)). In the preceding 12 months, we have shared personal information collected from website users to third parties, such as:
- Identifiers,
- Commercial information, and
- Internet or other similar activity.
Novogradac does not sell or share information disclosed to us through other contexts, such as part of the professional contracted services we provide to our clients or that is disclosed or provided to us by our vendors.
How We Collect Your Information
We collect this information:
- Directly from you when you provide it to us.
- From third parties that may have a relationship with you.
- Automatically as you navigate through the Website.
Information You Provide to Us
The information we collect from you may include:
- Information you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or requesting information about our services. We may also ask you for information when you report a problem with our Website.
- Last date you logged into your account.
- Records and copies of your correspondence (including email addresses, names, phone numbers, and other information), if you contact us, including by phone, by mail, or email.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your search queries on the Website.
- Information you provide in surveys or provide us with feedback on our Website, our products, or our services.
Information Provided to Us by Third Parties
Our clients or vendors may have a relationship with you. They could be an employer, a landlord, or your service provider, and they may need to disclose personal information to us. The information we may collect from third parties may include:
- Information provided to us by your employer if your employer provides us with goods or services.
- Information provided to us by our clients.
You should contact these third parties directly to determine how your personal information may have been collected and how they are using it. Novogradac is not responsible for these third parties’ use of your personal information.
Our Automatic Data Collection Practices
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Website including traffic data, location data, logs and site activity other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See the Choices About How We Use and Disclose Your Information section below for information on how you can exercise choice and opt out of behavioral tracking on this website. Our Website is not currently able to detect and honor a visitor’s “do not track” browser settings.
The information we collect automatically is generally statistical data but may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Analyze and improve digital platform performance.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Deliver “early bird” savings and similar coupons.
- Recognize you when you return to our Website.
- Administer promotions, surveys and user testing activities.
- Run sweepstakes and contests.
- Sync your activity across different service platforms and devices.
- Calculate shipping costs and similar information.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system and services will issue cookies when you direct your browser to our Website.
- Sessions. Session data is information stored by a browser or server. Session data helps the Website perform the actions you request. It can also track behaviors like add-to-cart or similar ecommerce activity.
- Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also called pixels) that permit Novogradac to, for example, count users who have visited those pages and for other related website statistics (for example, recording a purchase or verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To fulfill or meet the reason you provided the information. For example, if you provide your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or registration, we will use that information to process your payment and facilitate delivery. We may also save your information to inform you of future offers, facilitate new product orders or process returns.
- If you use our Website to register for a conference, we will use the information you provide to help plan, organize and prepare for the conference so we and our vendors may provide you with the services and benefits of the conference.
- If you attend one of our webinars, certification, or informational programs, to provide you with the benefits offered by these programs, such as continuing education credits.
- To provide, support, personalize, and develop our Website, apps, products, and services.
- If you work for one or more of our clients, to contact you regarding the services we provide to those clients.
- If you, as an individual, signed an engagement letter with our firm to receive professional services, to provide you with those professional services.
- If you work for one or more of our vendors or service providers, to contact you regarding the goods or services we receive from the vendor or service provider.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments, including for billing and collection, and prevent transactional fraud.
- To personalize your Website and/or app experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and/or apps, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, apps, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in this policy.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Novogradac's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Novogradac about our Website users is among the assets transferred.
Disclosure of Your Information
We may disclose aggregated and/or deidentified information about our users without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business or help us provide the services to you.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Novogradac’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Novogradac about our Website users is among the assets transferred.
- To fulfil the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use or Terms of Sale and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Novogradac, our customers and clients, or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your cookie settings, visit your browser’s help center. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Offers from the Company. If you do not wish to have your email address used by Novogradac to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data, or at any other time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may use the links in the footer of the email to manage your email preferences or unsubscribe. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience, or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (NAI) on the NAI’s website.
Your Privacy Rights
This policy provides you with the rights listed below over the personal information you provide to us. You may have additional rights under applicable federal, state, or local law. To the extent those laws apply to Novogradac and/or our use of your personal information, we will provide you with the ability to exercise those rights. Further information on the data we collect, how we use, and your rights may be found in our Privacy Notice at Collection.
We reserve the right to require you to verify your identity when you exercise a right. We will generally verify your identity by having you confirm information we may have in our systems. Authorized agents acting on behalf of a consumer should contact us via the contact methods in the Exercising Your Rights section below and be prepared to provide authorization from the consumer. We reserve the right to directly contact the consumer to verify any authorized agent request.
We reserve the right to refuse to respond to any request that would require us to expend a disproportionate effort in replying to the request.
Exercising Your Rights
You may exercise your rights by logging into your account and visiting your account profile page. You may also contact us by emailing us at [email protected], or by choosing the Consumer Privacy Request option through the Syntrio Connects Standard reporting system. You may also call 1-877-222-1857 (choose option three to register your request) to exercise your rights.
Right to Know and Access Yor Information
You have the right to know what information we collect about you, including the categories of personal information we collect, the categories of the sources from which personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Right to Correct Your Information
You have the right to correct your personal information. Website users can review and change their personal information by logging into the Website and visiting your account profile page. All individuals may send us an email to [email protected] or choosing the Consumer Privacy Request option to request access to, correct, or delete any personal information that they have provided to us. We may not accommodate a request to change personal information if we believe the change would violate any law or legal requirement or cause the personal information to be incorrect.
Right to Delete
You may request we delete your personal information. We cannot delete website user personal information except by also deleting their user account. We may refuse to delete your personal information if we require it to provide a service or a good to you. We will delete your personal information upon your request, and we will only retain personal information that we are required to by law, regulation, or professional standard, including to show our compliance with your deletion request.
Right to Opt-Out of the Selling or Sharing of Your Personal Information
To the extent we may sell or share your personal information, you may exercise your right to opt-opt of the selling or sharing your personal information through the information in the Notice of Right to Opt-Out, by choosing the Consumer Privacy Request option or by calling 1-877-222-1857 (choose Option 3 to register your request). You may also opt out when you are registering for the conference. Further information may be found in the Privacy Notice at Collection.
Right to Limit Sensitive Personal Information
If you provide us with sensitive personal information, you may have the right to limit the use and/or disclosure of your sensitive personal information to those uses or disclosures that are reasonably necessary to provide the services for which the sensitive personal information was disclosed. Novogradac currently only collects sensitive personal information from individual clients to provide the contracted services.
Right to Non-Discrimination
You will not be discriminated or retaliated against if you exercise any of these privacy rights. Generally, we will only deny the exercise of your rights if it is permitted by applicable law, if we require the information to complete the transaction or provide the service to you, or if the value of the personal information is reasonably related to the value of the personal information you provided.
Residents of the European Union
At this time, our professional services, events and products are not targeted towards residents of the European Economic Area (EEA). Natural persons currently located in the EEA should not submit inquiries, place orders on this Site, or otherwise provide us with their Personally Identifiable Information (as that term is defined in the European Union’s General Data Protection Regulation).
Data Security
We strive to protect the security of your information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is secured on our secure servers behind firewalls. Any information provided to us to fulfill your online orders is secured by using Secure Sockets Layer (SSL) software, which encrypts the information you input. We reveal only the last four digits of your credit card numbers when confirming an order. We utilize security-certified payment processing companies located in North America for credit card authorization and settlement purposes. To further protect against credit card fraud, we only receive a tokenized substitute for your credit card number. If you choose to save your credit card information during a purchase, we save only the tokenized substitute for your credit card number.
It is important for you to protect against unauthorized access to your password and to your computer. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to disclose your password with anyone. You should close all browser windows when finished if using a shared computer.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
Website: Visit https://www.lighthouse-services.com/novoco and select the “Consumer Privacy Request” option.
Email: [email protected]
Phone: 1-877-222-1857 (Choose Option 3 to register your request).
Mail: Novogradac & Company LLP
1160 Battery Street, East Building Suite 225
San Francisco, CA 94111
Attn: Legal & Risk Department – Privacy Policy Inquiries