Privacy Policy

The Company is committed to the privacy and security of personal information. The purpose of this Privacy Policy (“Policy”) is to provide you with information about how Company collects, uses, shares, and safeguards personal information it gathers. It also describes options you have concerning your personal information. In general, our processing of personal information is designed to improve the experience of our clients and to provide relevant information about our products, services, and promotions.

About This Policy

This Policy describes the privacy practices of the Company and its subsidiaries, divisions, and affiliates (collectively and/or individually, "Company", "our", or "we"). Except as otherwise provided, it applies to our interactions with our clients and visitors, including, but not limited to:

• Use of our websites, including mobile websites, and/or applications
• Visits to our locations or attendance at one of our events
• Phone and email communications
• Social media interactions on our websites and other third-party websites like Facebook, LinkedIn, Yelp, and YouTube
• Viewing our online advertisements or emails
• Through our authorized service providers

Please read this Policy carefully before using the Website or submitting information to us. By accessing or visiting the Website, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this Policy. If you do not consent to the collection, use, and sharing of your information as described in this Policy, please do not provide us with such information. The nature of our business requires that we gather and maintain information that is of a personal nature that you may wish to keep protected. This Policy does not apply to third-party websites accessible through our Website or other applications.

Personal Information We Collect

As described below, Company may collect or has collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of personal information we collect personal information. In that case, we will inform you.

• Identifiers. Examples include real name, alias, address, Internet Protocol address, email address, social security number, or other similar identifiers.
• Other elements . Examples include name, signature, address, telephone number, employment, or bank account number.
• Characteristics of protected classifications under federal or state law. Examples include date of birth.
• Internet or other electronic network activity . Examples include information regarding a consumer’s interaction with the Company’s internet websites and email newsletters
• Personal Financial Information . Examples include bank account statements, brokerage account statements, earnings records, etc.
• Records of Personal Property
• Professional or Employment-Related Information

Purposes We Collect Your Personal Information

Set forth below are the business purposes we have collected your PI. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.

• To provide you with information, products, or services that you request from us.
• To fulfill or meet the reason for which the information is provided. For example, if you prefer your tax refund to be electronically deposited, we will collect your bank information.
• To contact you and/or provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
• To engage in marketing activities, including to help design products and services appropriate for our clients.
• To communicate with you in social media concerning our products and services.
• To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
• To review, improve, and monitor our website, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.
• To provide client service and engage in quality control activities concerning our products and services.
• To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To process applications for employment, as well as to evaluate and improve our recruiting efforts.
• As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Sources of Personal Information

• You. Examples of when we collect that information include:
  • During a website visit or completed form, or when you visit us at one of our locations or events
  • If you upload or share a photo, submit a request, submit information, or post other digital content through one of our websites, applications, or via social media interactions on third party websites like Facebook, LinkedIn, or Yelp
  • If you participate in a contest, promotion, program, or workshop
  • If you request a quote, proposal, or other information
  • If you apply or inquire about employment, see our Applicant Privacy Policy.
  • In connection with your interactions with us as a registered user of our websites
  • We may use tracking tools, such as browser cookies.
• Your Friends and Family
• Other Professional Advisors
• News Outlets
• Social Media and Related Services

Sharing Personal Information

Of the categories of PI noted above, during the past 12 months, we shared the following:

Categories of Personal Information Disclosed

Categories of Third Parties to Whom Disclosed

Identifiers Other elements C haracteristics of protected classifications under federal or state law Internet or other electronic network activity Personal financial information Records of personal property Professional or employment-related information

Third parties as directed by you. We will share your PI with those third parties to whom you direct. For example, if you authorize us to send your tax information to your bank. Our business partners. For example, we might share your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner's privacy statement before signing on with them. Third parties who perform services on our behalf. For example, we share information with certain service providers, including marketing companies, professional service providers, collection agencies, information technology providers, and data storage companies. We might also authorize our service providers to collect PI on our behalf. Governmental entities, legal service providers. We may share your PI in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.

We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities, such as those summarized in our Website Privacy Policy, as a “sale,” we will comply with applicable law as to such activity.

We do not have actual knowledge that we have sold personal information of minors under age 16.

Using of Your Personal Information on Our Website

See our Website Privacy Policy at https://www.kempercpa.com/privacy/website

IMPORTANT : By using the Website, you consent to the processing of any PI provided or collected for the analytics purposes and functions described within the policy.

Applicable law

This Policy is governed by the laws of the State of Indiana, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within Indiana. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

Contact Us

If you have additional questions you may call us at (866) 900-4236 or use the Consumer Request Concerning Personal Information form located at https://www.kempercpa.com/privacy/consumer-request . You can write to us at:

Partner in Charge of Administration
7200 Eagle Crest Blvd
Evansville, IN 47715.

Changes to this Privacy Policy

Effective Date: July 1, 2020

From time to time we may change our privacy policies. We will notify you of any material changes to our Privacy Policy by posting an updated copy on our website. Please check our Website periodically for updates.

For California Residents

This section of the Privacy Policy (“CA Policy”) supplements and amends the information contained in our Privacy Policy with respect to California residents. This CA Policy applies solely to individuals, visitors, users, and others who are natural persons and residents of the State of California (“consumers” or “you”). THIS ADDENDUM TO THE PRIVACY POLICY DOES NOT APPLY TO USERS WHO ARE NOT NATURAL PERSONS AND NOT CALIFORNIA RESIDENTS.

The CA Policy describes Company’s policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit or we obtain when you access the Site and other sources. This CA Policy is adopted in part to comply with the California Consumer Privacy Act (“CCPA”).

Any terms defined within the CCPA have the same meaning when utilized within this CA Policy. The other provisions of the Policy continue to apply except as modified in this CA Policy. Note, however, that personal information as used in this CA Policy does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Consumer Rights. Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.

• Request to Delete. You have the right to request that we delete your PI from our records and direct any service providers to delete your PI from their records, subject to certain exceptions. Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your personal information from our records.
  
  

  The Company is not required to comply with your request to delete your PI if it is necessary for us (or its service provider) to maintain your PI in order to:

  1. Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Company’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  7. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company.
  8. Comply with a legal obligation.
  9. Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.

  Upon receipt of a confirmed verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.

  If you are under the age of 18, and a registered user of any Site where this CA Policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information in the Privacy Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

• Request to Know. You have the right to request that we disclose the following to you as it relates to the 12-month period preceding its receipt of your verifiable consumer request:
  
  
  1. The categories of PI we have collected about you.
  2. The categories of sources from which the PI was collected.
  3. The business or commercial purpose for collecting PI.
  4. The categories of PI we disclosed for a business purpose.
  5. The categories of third parties with whom we share PI.
  6. The specific pieces of PI we collected about you.

  Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.

  In addition to the CCPA, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of Company to third parties for the third parties’ direct marketing purposes. Consumers who have provided their personal information to us may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such request must be submitted to us by calling(866) 900-4236 or using the Consumer Request Concerning Personal Information form at https://www.kempercpa.com/privacy/consumer-request . Please mention in your call or indicate on the form that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of such personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

• Nondiscrimination. We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.

Submitting Consumer Rights Requests To submit any of the Consumer Rights requests as outlined above, please contact us at (866) 900-4236 or using the Consumer Request Concerning Personal Information form at https://www.kempercpa.com/privacy/consumer-request . We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:

1. the consumer who is the subject of the request,
2. a consumer on behalf of the consumer’s minor child, or
3. by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

Questions. If you have questions about this CA Policy, please contact us as described above in the Privacy Policy.