Term of Privacy

Privacy Policy

This Privacy Policy identifies and describes the way Domus Global Tax Advisors LLC, LLC. (“Domus Global Tax Advisors LLC”) uses and protects the Information we collect about Customers and Users. All uses of Domus Global Tax Advisors LLC’s products and services and visits to our websites are subject to this Privacy Policy.

This Policy applies to all Customers and Users. The Customer who holds the account with Domus Global Tax Advisors LLC is responsible for ensuring all family members or other Users under the same account understand and agree to this Policy.

This Policy and Domus Global Tax Advisors LLC do not cover Information you provide to non-Domus Global Tax Advisors LLC companies. You shall have no responsibility for protecting any such information divulged by Customer/User to a non- Domus Global Tax Advisors LLC company. As used in this Policy, the terms listed below have the following meanings:

Customer

A “Customer” is anyone who purchases Domus Global Tax Advisors LLC products or services. When a Customer purchases retail products or services for use by others, those individuals also may be considered Customers for purposes of this Policy.

User

A “User” is anyone who visits our websites.

Personal Information

“Personal Information” is Information that directly identifies or reasonably can be used to identify an individual Customer or User. Examples include name, address, telephone number, email address, Social Security number, and financial account number. Personal Information does not include Published Listing Information as discussed in more detail below or Information readily available to the public through no fault of Domus Global Tax Advisors LLC.

Anonymous Information

“Anonymous Information” means Information that does not directly identify and cannot reasonably be used to identify an individual Customer or User.

Aggregate Information

“Aggregate Information” means Information about groups or categories of Customers or Users, which does not identify and cannot reasonably be used to identify an individual Customer or User. Aggregate Information is a kind of Anonymous Information.

Website

“Website” means any page or location on the Internet, no matter what device (cell phone, laptop, PC, etc.) or protocol (HTTPS, WAP, FTP, or other) is used to access the page or location. In this Policy, we use the term website other similar terms such as “Internet site,” “site,” and “web page.”

1. Information

We may collect diff erent types of personal and other Information based on your use of our products and services and our business relationship with you, including contact information; billing Information, equipment, performance, Domus Global Tax Advisors LLC’s website usage, viewing and other technical Information about your use of our network, services, products or websites. Information may be collected when you give it to us with the intent to purchase or interact with us about a product or service we offer or provide; when we collect it automatically when you visit our websites or use our products and services; or when we obtain it from other sources, such as credit agencies. Our goal of collecting your Information is to provide you with the best customer experience possible by communicating with you regarding service updates, off ers and promotions; delivering advertising that may be of interest to you; addressing network and security issues; investigating or taking action regarding illegal activities or violations of our Terms of Service or Acceptable Use Policies.

We collect some information on an anonymous basis and may anonymize the personal Information we collect about you into data groups. When we employ non-Domus Global Tax Advisors LLC companies to anonymize or aggregate data on our behalf, the requirements for sharing Personal Information with non- companies apply. We may share aggregate or anonymous Information in various formats with trusted non-Domus Global Tax Advisors LLC entities, with whom we have contracted with to aggregate such data and may work with those entities to do research and provide products and services. When Domus Global Tax Advisors LLC jointly provides a service with a non-Domus Global Tax Advisors LLC company, your Personal Information may be subject to both this Policy and the privacy policy of the non- Domus Global Tax Advisors LLC company. We encourage you to review the privacy policies of any non- Domus Global Tax Advisors LLC company with which you do business to determine what Information will be collected and how it will be used or disclosed to others.

2. Disclosure

We do not sell your Personal Information to anyone for any purpose, and we maintain Information about you in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes. We have implemented encryption or other appropriate security controls to protect Personal Information when stored or transmitted by Domus Global Tax Advisors LLC.

Subject to applicable legal restrictions, such as those that exist for CPNI (as defined below), the Domus Global Tax Advisors LLC family of companies may share your Personal Information with each other to make sure your experience is as seamless as possible, and you have the full benefit of what Domus Global Tax Advisors LLC and its subsidiaries have to offer.

We share your Personal Information only with non-Domus Global Tax Advisors LLC companies that perform services on our behalf and only as necessary for them to perform those services. We require those non-Domus Global Tax Advisors LLC companies to protect any Personal Information they may receive in a manner consistent with this Policy, and we do not provide Personal Information to non-Domus Global Tax Advisors LLC companies for the marketing of their own products and services without your consent. We may provide Personal Information to non-Domus Global Tax Advisors LLC companies or other third parties for purposes such as emergencies, pursuant to court orders, compliance with the law or a lawful government, judicial, administrative, or law enforcement request (i.e. search warrant, subpoena, court order, discovery request), identity verification to prevent fraud and identity theft, enforcing of property rights, or obtaining payment for products and services that appear on your Domus Global Tax Advisors LLC billing statements.

3. Customer Proprietary Network Information.

Customer Proprietary Network Information (CPNI) is Information that Domus Global Tax Advisors LLC obtains when providing your telecommunications services to you. CPNI includes the types of telecommunications services you purchased, how you use the services, and the billing information related to those services, including items such as the types of telecommunications services that you have purchased and your calling details. Your telephone number, name and address are not considered CPNI.

We use your CPNI to offer you additional services of the type you already purchase from Domus Global Tax Advisors LLC. We also may use your CPNI to offer you products and services, packages, discounts and promotions from Domus Global Tax Advisors LLC and its affiliates, such as fax service, analytic tools and other unified communication tools, which may be different from the types of services you already purchase. Domus Global Tax Advisors LLC has strict policy guidelines to safeguard the privacy of CPNI and protect it from unauthorized access or improper use. Domus Global Tax Advisors LLC does not sell, trade, or otherwise share your CPNI with anyone outside of Domus Global Tax Advisors LLC or its affiliated companies or with anyone who is not authorized to represent us to off er our services or to perform functions on our behalf, except as the law may require, or you may authorize.

In order to opt-out and restrict access to your CPNI for our own marketing purposes, please contact us within 30 days of this notice by clicking the following link or going to the following website http://go.Domus Global Tax Advisors LLC.com/emailPreference/e/64132/100. If you do not notify us within 30 days of this notification that you wish to restrict our use of your CPNI, we will assume that you approve of our use of CPNI for this purpose.

4. Privacy Controls

You can review and correct your Personal Information collected by us. You can limit certain types of solicitation communications from Domus Global Tax Advisors LLC, LLC including marketing contacts made via telephone, email and text messaging by notifying Domus Global Tax Advisors LLC. We will provide you with notice of changes to this Policy. We are happy to correct Information found to be inaccurate. Customers may verify that appropriate corrections have been made.

5. Internet-based Advertising

Domus Global Tax Advisors LLC uses cookies to store Information that can be used to serve ads relevant to your interests, and to help our advertisers measure the eff ectiveness of a particular advertisement. This helps us tailor ads to your interests. These cookies can not only help us ensure that you do not repeatedly see the same ads, but (if you opt-out) they can also help us prevent you from seeing targeted ads at all. The Information collected with these cookies is not personally-identifiable, and we do not associate it with your Personal Information.

You may opt-out of Domus Global Tax Advisors LLC’s use of data for internet-based advertising. Please keep in mind that even after you opt-out, you may still continue to see ads, but they will no longer be tailored to your interests.

Opting-out also does not remove Domus Global Tax Advisors LLC cookies. They will remain on your computer, but we will not use the data connected to your cookie for our services. Please note that if you delete your cookies, you will need to opt-out again to avoid being served targeted ads in the future. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We have relationships with other third-party advertising companies to place advertisements on this website and other websites and perform tracking and reporting functions for this website and other websites. These third-party advertising companies may remember cookies on your computer when you visit our website or other websites so that they can display targeted advertisements to you. These third-party advertising companies do not collect Personal Information in this process, and we do not give any Personal Information to them. However, this Privacy Statement does not cover the collection methods or use of the Information collected by these entities. For more Information about third-party advertising, please visit the Network Advertising Initiative (NAI). Opt-out of being targeted by many third-party advertising companies by visiting NAI’s Consumer Opt-Out orTRUSTe’s Opt-Out.

6. Exclusions

Information that you provide to non-Domus Global Tax Advisors LLC companies is not covered by this Policy. For example: When you download applications or make an online purchase from a non-Domus Global Tax Advisors LLC company while using Domus Global Tax Advisors LLC’s services, the Information collected by the non-Domus Global Tax Advisors LLC company is not subject to this Policy. If you use public forums — such as social networking services, Internet bulletin boards, chat rooms, or blogs on Domus Global Tax Advisors LLC or non-Domus Global Tax Advisors LLC websites — you should be aware that any Personal Information you disclose publicly can be read, collected, or used by others. Once you choose to reveal Personal Information on such a site, the Information is publicly available, and Domus Global Tax Advisors LLC cannot prevent distribution and use of that Information by other parties.

Domus Global Tax Advisors LLC may enter into written product or service agreements with business customers that contain specific provisions related to the confidentiality, security or other handling of Information. When provisions of a written product or service agreement differ from or conflict with the provisions of this Policy, the terms of the written agreement will apply. In all other instances, the terms of this Policy apply.

7. Security

We have established electronic and administrative safeguards designed to secure the Information we collect, to prevent unauthorized access to or disclosure of that Information and to ensure it is used appropriately. Although we strive to keep your Personal Information secure, no security measures are absolute, and we cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Policy). We will make reasonable attempts to notify you if we determine that Domus Global Tax Advisors LLC has experienced a security breach and there is a reasonably likely risk of identity theft, or where otherwise required by law.

8. Policies

We have established policies and practices to meet the expectations of Customers and potential customers who have expressed a desire to limit certain types of solicitation communications from Domus Global Tax Advisors LLC, LLC including marketing contacts made via telephone, email and text messaging. You also can request to be removed from these telemarketing lists when you receive a marketing or promotional call. Where required by state laws and/or regulations, we honor requests from businesses to be removed from our telemarketing lists. The FTC maintains a National Do Not Call Registry at https://www.donotcall.gov/, and your state may maintain its own Do Not Call Registry. Putting your number on these Registries also may limit our telemarketing calls to that number.

Our practices as described above are designed to satisfy state and federal legal requirements limiting marketing contacts. You should know that those laws and regulations — such as the requirements governing the state and federal “Do Not Call” lists — generally permit companies to contact their own current and, in some cases, former customers, even when those customers are listed on the federal and state “Do Not Call” lists. Similarly, restricting our use of your CPNI will not eliminate all types of Domus Global Tax Advisors LLC marketing contacts.

9. Online Advertising

Domus Global Tax Advisors LLC works hard to detect and prevent junk emails (also referred to as “spam” emails) from ever reaching your computer. However, if you are receiving unwanted spam from a Domus Global Tax Advisors LLC email address, please contact us for assistance at support@Domus Global Tax Advisors LLC.com.

10. Account Set-Up

When selecting User names and passwords for Domus Global Tax Advisors LLC accounts, you should choose words or characters that are not obvious. Likewise, you should always keep Personal Information such as account numbers, Usernames, passwords or similar Information in a secure place and not share the Information with others.

11. Policy Changes

Information about our Customers and Users, including Personal Information, may be transferred as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy, or receivership in which Customer and User records would be transferred to another entity as a result of such a proceeding.

We reserve the right to update this Privacy Policy as necessary to reflect any changes we make and to satisfy legal requirements. If we make a material change to this Policy, we will post a prominent notice of the change on our websites, and provide you with other appropriate notice and choice regarding the use of your Information, at least 30 days before the eff ective date.

Please check our websites periodically for changes to this Privacy Policy.

We are happy to address any questions or concerns you may have about our privacy practices and policies. You may email us at support@Domus Global Tax Advisors LLC.com or write to us at 300 S Orange Ave, Suite 1000, Orlando, Florida, 32801. If you believe you have been aggrieved by any act of ours in violation of the law, we encourage you to contact us directly at either of these addresses to resolve your question or issue.

You also have the option of filing a complaint with the FTC Bureau of Consumer Protection, using an online form, or by calling toll-free 1-877-FTC-HELP (1-877-328-4357; TTY: 1-866- 653- 4261. Other rights and remedies also may be available to you under federal or other applicable laws.

12. What Information we collect or process

Domus Global Tax Advisors LLC processes and in certain situations collects personal Information as needed to deliver its Products and Services and manage its business. When collecting personal Information, Domus Global Tax Advisors LLC does so in a reasonable and lawful manner.

The types of Information and the purposes for which Domus Global Tax Advisors LLC collects or processes personal Information may include:

13. Indirect End User Phone Contact Information (Personal Identifiable Information)

Domus Global Tax Advisors LLC acts as a data processor with regard to indirect end user personal identifiable information and our Clients act as the data controller of such data. In the course of Domus Global Tax Advisors LLC’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.

Specifically, only when enabled via system permission on Domus Global Tax Advisors LLC Mobile App Android and Domus Global Tax Advisors LLC Mobile App iOS, Domus Global Tax Advisors LLC shows personal contacts within the respective application. When the user sends an SMS message to one of his/her phone contacts, or when the user initiates a call to one of his/her phone contacts, the phone number is sent securely through Domus Global Tax Advisors LLC’ API. Domus Global Tax Advisors LLC does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; Domus Global Tax Advisors LLC stores only the phone number and pertinent metadata so as to be compliant with all applicable state and federal laws, and Domus Global Tax Advisors LLC does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on his/her mobile device at any time, and his/her app experience is not hindered or interrupted.

 

Domus Global Tax Advisors LLC Mobile App Android and iOS also uses Gravatar, only when enabled via Settings and UIConfigs, which is a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that, only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings or via UIConfig, and his/her app experience is not hindered or interrupted.

14. Clients

Domus Global Tax Advisors LLC uses such Personal Information only for relevant, appropriate, and customary purposes. Domus Global Tax Advisors LLC will not share or disclose personal Information for purposes other than as described herein. Capitalized terms used in this Privacy Policy shall have the meaning as given in Client’s Master Services Agreement (MSA). The following are examples of some of the personal Information Domus Global Tax Advisors LLC may process.

15. Business Contact Information:

Domus Global Tax Advisors LLC may collect and use personal Information about individual contacts of Clients and others who access Domus Global Tax Advisors LLC public websites, knowledge bases, forums, ticket systems, or provide personal Information through other means. Such Information may include but is not limited to account Information, first/last name, company name, title, and responsibilities, work email address, work mailing address, telephone numbers, login information, device identifiers, as well as additional Information provided by such individuals in the course of receiving Products and Services from Domus Global Tax Advisors LLC and/or requesting Information about Domus Global Tax Advisors LLC. We will use such Information for the purposes of providing Products and Services, support, conducting data analytics and product assessments and related activities, and providing Information regarding Domus Global Tax Advisors LLC Products and Services.

16. Customer Proprietary Network Information (CPNI):

Customer Proprietary Network Information (CPNI) may include Information regarding quantity, destination, technical configuration, location, amount of use and related billing information of telecommunications, interconnected and/or non-interconnected Voice over Internet Protocol (VoIP) services. This may include but is not limited to the phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from) through our Products and Services. The date, time and duration of the calls may also be collected. This data is used for billing and service level assurance.

Domus Global Tax Advisors LLC provides Products and Services that are primarily for the benefit of Clients and Subscribers in that Domus Global Tax Advisors LLC transmits, routes, switches or caches information. These Products and Services merely act as a conduit for data transmitted by third parties and Subscribers. Domus Global Tax Advisors LLC does not determine the purposes and means of processing this personal Information. Except for Subscriber data provided by the Client (the Subscribers service provider) for which Domus Global Tax Advisors LLC is merely providing a conduit for transmission, the subscribed services are of such a nature that, in most instances, Domus Global Tax Advisors LLC requires and collects only essential CPNI and billing Information; and opting out or declining to provide the requested data may hinder the provision or delivery of subscribed services. However, for CPNI data that is collected by Domus Global Tax Advisors LLC that is not subject to the control of others, Domus Global Tax Advisors LLC shall obtain consent from the user for the processing of this data.

 

Domus Global Tax Advisors LLC collects end-user CPNI in the course of providing Product support. This data may pertain to Clients of Domus Global Tax Advisors LLC or Subscribers (eg: end users of Domus Global Tax Advisors LLC’ direct Clients). This data may include IP address, telephone number, email address, call detail records, call recordings and other Information sufficient to identify an individual end user.

17. Indirect End User’s CPNI:

Domus Global Tax Advisors LLC acts as a data processor with regard to indirect end user personal information and our Clients act as the data controller of such data. In the course of Domus Global Tax Advisors LLC’ processing and protection of such data, all use will be in conformity with the data controller’s instructions.

18. Direct End User’s CPNI:

Domus Global Tax Advisors LLC typically collects and processes direct end user (eg: Clients, vendors, and partners) personal information for the purposes of providing Products and Services, support, conducting data analytics and managing product performance.

19. Messaging, Voicemail, Video and Media Files:

Domus Global Tax Advisors LLC provides Products and Services that facilitate the recording and storage of audio and video by way of features such as but not limited to voicemail, call and conference recording. Users may elect to store or record personal Information within these resources at their discretion.

20. Anonymized, Non-Identifying Voice and Traffic Data

Domus Global Tax Advisors LLC may use anonymized, non-identifying data collected from use of our Domus Global Tax Advisors LLC Products and Services. This anonymized, non-identifying data may be used to enhance such items, but is not limited to, voice activation, improve traffic analysis algorithms and techniques, and recognition algorithms. This processing is executed under applicable terms and supports Domus Global Tax Advisors LLC’ legitimate interests in tuning, maintaining and enhancing these Products and Services.

2’1. Cookies

Domus Global Tax Advisors LLC websites may use cookies to collect certain kinds of personal Information about Subscribers or users. For more Information on how Domus Global Tax Advisors LLC uses cookies and choices available to Subscribers and users please refer to the following section.