1. Overview

Meridian Harbor Advisors (“we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Statement explains how we collect, use, disclose, and safeguard information when you interact with our website, Microsoft Forms intake questionnaires, client portal, and related services.

Because we provide tax and financial advisory services, we are subject to additional federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA), Internal Revenue Code Section 7216, and the Federal Trade Commission Safeguards Rule. This statement reflects those obligations.

By submitting your information through our forms or using our services, you consent to the practices described in this Privacy Statement.

2. Information We Collect

We may collect the following types of information:

A. Personal Information

•             Full name

•             Email address

•             Phone number

•             Mailing address

•             Date of birth

•             Social Security Number (if provided for tax-related purposes)

•             Tax and financial information, including prior-year tax documents, W-2s, 1099s, and supporting records

B. Business Information (if applicable)

•             Business name and structure

•             Employer Identification Number (EIN)

•             Financial statements, ledgers, and supporting records

•             Payroll and contractor information

C. Technical and Usage Information

•             IP address

•             Browser type and device information

•             Form submission timestamps

•             Cookies, web beacons, and similar tracking technologies (see Section 11)

3. How We Collect Information

We collect information through:

•             Microsoft Forms intake questionnaires

•             Secure client portal document uploads

•             Email or direct communications

•             Scheduling or consultation requests

•             Information you authorize third parties (such as financial institutions or prior tax preparers) to share with us

4. How We Use Your Information

We use the information we collect to:

•             Provide a complimentary prior-year tax review

•             Estimate tax preparation and related service costs

•             Prepare, review, and file tax returns and related filings

•             Create and manage your secure client portal access

•             Communicate with you regarding services, scheduling, and updates

•             Comply with legal, tax, and regulatory obligations

•             Maintain business records as required by law

•             Improve our services and client experience

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

5. Gramm-Leach-Bliley Act (GLBA) Privacy Notice

As a provider of financial and tax services, Meridian Harbor Advisors is a financial institution under the Gramm-Leach-Bliley Act and is subject to its privacy and safeguards requirements.

We collect nonpublic personal information (“NPI”) about you from the following sources:

•             Information you provide on applications, forms, and intake questionnaires

•             Information about your transactions with us

•             Information from third parties such as financial institutions, prior tax preparers, or government agencies, when authorized by you

We do not disclose NPI about current or former clients to nonaffiliated third parties except as permitted or required by law. We restrict access to NPI to employees, contractors, and authorized service providers who need it to provide services to you, and we maintain physical, electronic, and procedural safeguards designed to comply with the FTC Safeguards Rule.

6. Tax Return Information (IRC § 7216)

Federal law (Internal Revenue Code § 7216) prohibits us from using or disclosing your tax return information for purposes other than preparing your tax return without your prior written consent.

If we wish to use your tax return information for any other purpose — such as referrals, marketing of additional services, or disclosure to third parties not involved in preparing your return — we will request your specific written consent in advance, in the form required by the IRS.

7. Client Portal and Document Security

We use secure third-party platforms, including Microsoft 365 services, to store and manage client information and documents. Access to your client portal is restricted to authorized personnel only and is protected by access controls and authentication requirements.

Consistent with the FTC Safeguards Rule, we maintain a written information security program that includes administrative, technical, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, or destruction. These safeguards include access controls, encryption of sensitive data in transit and at rest where reasonably feasible, employee training, and periodic risk assessments.

However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Data Breach Notification

In the event of a data security incident affecting your personal information, we will notify you and applicable regulatory authorities in accordance with state and federal breach notification laws, including any applicable timelines, methods of notification, and content requirements. We will also take reasonable steps to investigate the incident, mitigate harm, and prevent recurrence.

9. Sharing of Information

We may share your information only in the following circumstances:

•             Service providers: With trusted service providers who assist in delivering our services (e.g., Microsoft Forms, Microsoft 365, secure cloud storage and portal providers, e-signature platforms). These providers are contractually required to maintain appropriate confidentiality and security standards.

•             Legal requirements: When required by law, regulation, subpoena, court order, or other legal process.

•             Protection of rights: To protect our rights, clients, property, or the safety of others.

•             With your consent: To any other party when you have provided written consent, including consent required under IRC § 7216 for tax return information.

10. Data Retention

We retain client information for the following periods:

•             Tax records and related documents: Retained for a minimum of seven (7) years following the end of the applicable tax year, consistent with IRS recommendations and applicable state requirements.

•             Other client records: Retained for the duration of the client relationship plus seven (7) years, unless a longer period is required by law.

•             Technical and usage data: Typically retained for 12 to 24 months.

After the applicable retention period, data is securely deleted, destroyed, or anonymized in a manner appropriate to its sensitivity.

11. Cookies and Online Tracking

Our website may use cookies, web beacons, and similar tracking technologies to improve site functionality, remember preferences, and analyze usage. We may use analytics services such as Google Analytics or comparable tools to understand how visitors interact with our site.

You can control or disable cookies through your browser settings, though doing so may affect certain site features. Because there is no industry-standard interpretation, we do not currently respond to “Do Not Track” browser signals.

12. Consent to Electronic Communications

By providing your email address and using our client portal, you consent to receive communications, notices, disclosures, tax-related documents, and engagement materials electronically, consistent with the federal E-SIGN Act. You may withdraw this consent at any time by contacting us in writing, though doing so may affect our ability to provide certain services or require alternative delivery methods that may involve additional time or cost.

To receive and retain electronic communications, you should have a current email account, internet access, and software capable of viewing PDF and Microsoft Office documents.

13. Your Rights and Choices

Depending on your jurisdiction, you may have rights regarding your personal information, including:

•             Accessing the data we hold about you

•             Requesting corrections or updates to inaccurate information

•             Requesting deletion of your information (subject to legal and regulatory retention requirements, including IRS recordkeeping obligations)

•             Obtaining a portable copy of certain information

•             Opting out of certain uses of your information

California Residents

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents have the right to know what personal information we collect, request deletion, correct inaccurate information, opt out of the sale or sharing of personal information (we do not sell or share personal information as those terms are defined under California law), limit the use of sensitive personal information, and not be discriminated against for exercising these rights.

Virginia, Colorado, Connecticut, Utah, and Other State Residents

Residents of states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, and others as such laws take effect) may have similar rights, including the right to access, correct, delete, and obtain a portable copy of their personal information, and to opt out of certain processing.

To exercise any of these rights, please contact us using the information in Section 17. We may need to verify your identity before responding to your request.

14. Children’s Privacy

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 13 in compliance with the Children’s Online Privacy Protection Act (COPPA). If we become aware that we have collected such information without appropriate consent, we will delete it promptly. Tax information about dependent children submitted by a parent or guardian for tax preparation purposes is handled under the parent’s or guardian’s client relationship.

15. Third-Party Services

Our website and processes may rely on third-party services such as Microsoft Forms, Microsoft 365, secure client portal tools, e-signature providers, scheduling tools, and analytics providers. These providers have their own privacy policies governing how they handle your information.

We encourage you to review their privacy policies for additional information. We are not responsible for the privacy practices of third parties that we do not control.

16. Changes to This Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices, services, or applicable law. Any changes will be posted on our website with an updated “Last Updated” date. Material changes will be communicated through our website, email, or client portal as appropriate.

17. Contact Information

If you have any questions or concerns about this Privacy Statement, how your information is handled, or to exercise any of your rights, please contact us:

Meridian Harbor Advisors LLC

Phone: +1 (667) 778-1443

Mailing Address: 212 W. Main St, Ste. 202C, Salisbury, MD 21801