1. Who We Are Legacy Tax & Resolution Services, LLC is a tax resolution and tax credit services firm. "Legacy Partner Network" and "LPN" are trade names of the same legal entity, used for our partner and referral network. Throughout this policy, "the Company," "we," "us," and "our" refer to that single entity. Because we both perform tax services ourselves and introduce clients to third-party Program Providers, this policy distinguishes between information we hold as the service provider and information we transfer to another company. 2. Information We Collect 2.1 From website visitors Device and browser type, operating system, and screen settings IP address and approximate location derived from it Pages viewed, referring URL, time on page, and click behavior Cookie and similar tracking identifiers (see the Cookie Policy) 2.2 From prospective and referred businesses Name, business name, title, email address, phone number, and mailing address Business details supplied for eligibility evaluation, which may include entity type, industry, employee count, payroll and tip data, import and customs activity, property and asset data, revenue ranges, and prior filings The identity of the representative who referred you and the tracking link, code, or form used Communications you send us and notes from calls, emails, and messages 2.3 From clients Tax returns, transcripts, payroll records, schedules, and supporting documentation Taxpayer identification numbers, Social Security numbers, and employer identification numbers Financial account information used for billing and fee collection Correspondence with tax authorities and case status records Engagement agreements, authorizations, and powers of attorney 2.4 From independent representatives and partners Identity and contact information, including legal name, business name, address, email, and phone IRS Form W-9 information and taxpayer identification number Payout and banking information, collected and processed through the iDevAffiliate portal and applicable payment providers Sponsor, upline, and downline placement records Referral, commission, adjustment, and payment records Login credentials, portal activity, IP address, device information, and cookie and referral-tracking identifiers Training, certification, and compliance records 2.5 From third parties Program Providers, regarding referral acceptance, case status, and completion Payment and tax processors, regarding payout status Analytics and fraud prevention vendors Public records and business data sources used to verify a business or prevent fraud 3. How We Use Information Evaluate whether a business may qualify for a program Perform tax resolution, tax credit, and related professional services for clients Route referrals to the appropriate third-party Program Provider where the program is delivered by another company Administer portal access and support Track referrals, validate attribution, calculate commissions, and process payouts Verify identity, meet tax reporting obligations, and issue IRS Forms 1099 Communicate about inquiries, engagements, program updates, training, and account matters Monitor compliance with our Marketing and Compliance Policy and investigate suspected violations Detect, prevent, and investigate fraud, abuse, security incidents, and unauthorized access Improve the Site and our operations, including through aggregated analytics Comply with legal, regulatory, tax, audit, professional, and recordkeeping obligations Establish, exercise, or defend legal claims 4. Tax Return Information and IRC Section 7216 Because we prepare and assist with tax filings, information you furnish in connection with those services is tax return information under IRC Section 7216 and Treasury Regulation § 301.7216-1. We may not use or disclose your tax return information for any purpose other than preparing or assisting in preparing your return, except as permitted by law or with your separate, specific, written consent that meets the requirements of Section 7216. In particular: We do not use tax return information for marketing without a separate Section 7216 consent We do not disclose tax return information to your referring representative. A representative receives referral status only — not your returns, financial detail, or documents We do not disclose tax return information to a third-party Program Provider unless doing so is necessary to deliver a service you requested and you have provided any required consent Consents we obtain will state the purpose, the recipients, and the duration, and you may refuse without losing access to services you are otherwise entitled to Unauthorized use or disclosure of tax return information carries criminal and civil penalties. Our personnel are trained accordingly. 5. Legal Bases and Consent Where required, we rely on your consent for marketing communications, non-essential cookies, and any Section 7216 disclosure. Otherwise we process information to perform a contract with you, to comply with legal and professional obligations, and for our legitimate interests in operating, securing, and improving the business. You may withdraw marketing consent at any time. Withdrawal does not affect processing already carried out and does not stop administrative, compensation, compliance, professional, or legal communications while an account or engagement is active. 6. How We Share Information Third-party Program Providers. Where a program is delivered by an independent provider, we share the information necessary for that provider to evaluate and deliver the service. From that point, the provider's own privacy policy governs its use of the information. Referring representatives and their upline. Limited referral status information necessary to administer attribution and compensation. Representatives do not receive client tax data, financial detail, or documents. Service providers acting on our behalf. Affiliate tracking (iDevAffiliate), CRM and communications (GoHighLevel), tax practice management (Canopy), cloud storage and productivity, e-signature, payment and payout processors, tax reporting vendors, analytics, and security providers. These parties may use information only to perform services for us and are bound by contract. Tax authorities and agencies. Where you authorize us to represent you or file on your behalf. Professional advisers. Attorneys, accountants, auditors, and insurers, under confidentiality obligations. Legal and safety. Government agencies, courts, and law enforcement where required by law, subpoena, or legal process, or where necessary to protect rights, safety, or property, or to investigate fraud. Business transfers. A successor or acquirer in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this policy and applicable professional obligations. We do not sell, rent, or share personal information for third-party advertising or cross-context behavioral advertising. 7. Cookies and Tracking We use cookies, pixels, local storage, and similar technologies for essential site function, referral attribution, session management, analytics, and security. Referral tracking cookies are necessary to credit a representative correctly. Details, categories, and choices are in our Cookie Policy. Blocking essential or referral cookies may break site function or referral attribution. We do not respond to browser Do Not Track signals. Where required, we honor recognized opt-out preference signals such as Global Privacy Control. 8. Data Retention We retain information as long as needed for the purposes described here and to meet legal, tax, audit, and professional recordkeeping obligations. Record type Typical retention Website analytics and cookie data Up to 26 months Prospect and unconverted lead records Up to 3 years from last contact Client engagement and tax work product 7 years minimum, per professional and IRS standards Representative account, referral, and commission records Duration of the account plus 7 years Tax records, W-9s, and 1099 data 7 years Section 7216 consents 7 years Terms and policy acceptance records Duration of the relationship plus 7 years When information is no longer needed, we delete or de-identify it. 9. Security We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including role-based access controls, encryption in transit, encryption at rest for taxpayer and financial data, vendor due diligence, and monitoring. Access to client tax information is restricted to personnel with a need to know. No system is completely secure. If we become aware of a breach affecting your personal information, we will notify you and any regulator as required by applicable law and, where taxpayer data is involved, follow IRS incident reporting requirements. 10. Your Privacy Rights Depending on your state of residence, you may have the right to: Know what personal information we collect, use, disclose, and retain Access a copy in a portable format Correct inaccurate personal information Delete personal information, subject to legal, professional, and recordkeeping exceptions Opt out of sale, sharing, or targeted advertising (we do not engage in these) Limit the use of sensitive personal information Not be discriminated or retaliated against for exercising a right Where to send your request: Client or tax matters — support@ltaxrs.com or 855-829-5877 Representative, affiliate, or partner matters — support@legacypartnernetwork.com Use the subject line "Privacy Request." We verify identity before responding, generally by confirming information already in our records, and respond within the timeframe required by law, typically 45 days, with an extension where permitted. An authorized agent may submit a request with proof of authorization. If we deny a request, you may appeal by replying with the subject line "Privacy Appeal." Deletion limits. We cannot delete records we are required to retain under tax law, professional standards, or an active engagement. We will tell you what we are keeping and why. Requests involving a third-party Program Provider. If your information was transferred to another company for service delivery, part of your request may need to go to that provider. We will tell you where to send it. 11. Children The Site and our services are not directed to children under 16, and we do not knowingly collect personal information from them. If you believe a child has provided us information, contact us and we will delete it. 12. Third-Party Links The Site links to third-party sites and portals. We are not responsible for their privacy practices. Review their policies before providing information. 13. Changes to This Policy We may update this policy. The updated version will be posted with a revised "Last Updated" date. Material changes will be communicated by email or portal notice where practical. 14. Contact Legacy Tax & Resolution Services, LLC, d/b/a Legacy Partner Network Attn: Privacy 3961 E. Chandler Boulevard, #111-301 Phoenix, Arizona 85048 Client and tax: support@ltaxrs.com | 855-829-5877 Affiliate and partner: support@legacypartnernetwork.com
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