Privacy Statement

Effective Date: November, 2021

We are committed to protecting your privacy when you provide data to us. This Privacy Statement (“Privacy Statement” or “Statement”) sets out the privacy practices for the UHY LLP and its subsidiaries (“UHY”, “us” or “we”) with respect to information, including Personal Data (which means any information relating to an identified or identifiable natural person), we obtain from and about consumers.

Please read the information below to learn about the Personal Data collected about you and how it is used. If we make any changes to this Statement we will notify you prior to the change becoming effective. The most current version of the Statement is always available on our Web site.

1. Personal Data Collected

Sources of Personal Data

Personal Data is collected directly from you when you:

• Complete a contact form on our Web site.
• Email information to us for services.
• Provide us information in hard copy for services.
• Visit our Web site and information is collected automatically.

It is your responsibility to provide us with accurate data, and to provide us with updated Personal Data when it changes.

Categories of Personal Data
The Personal Data collected by UHY includes:

• Identifiers (such as name, email, phone number, and address)
  • We use this information to contact you in response to your requests and/or in connection with services that we provide to you.
• Personal information categories described in the California Customer Records statute (such as Social Security numbers, and driver’s license numbers)
  • We use this information, if provided by you, to provide services to you upon request.
• Commercial information (such as financial and payment information)
  • We use this information, if provided by you, to provide services to you upon request and to facilitate transactions.
• Internet or other electronic network activity information (such as cookies and IP addresses)
  • We use this information to ensure the security of our Web site and improve the performance of our site.

2. With Whom We Share Personal Data

We do not sell your Personal Data to any third parties. 

We share your Personal Data with selected professional and financial services providers to fulfill our obligations to you and to provide you services and products offered by the UHY family of companies.  We also share your information with companies who help us to provide services to you (for example, the brokerage firm that executes securities transactions on your behalf or the company that processes and /or inputs data for your tax return).  Finally, we share your information with companies that support UHY’s accounting, billing and other systems.

3. Retention of Data

We will keep your Personal Data only for as long as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and us, if any; and to comply with legal and statutory obligations, such as in tax, trade and corporate laws. When we no longer need your Personal Data for our purposes, we will destroy, delete or erase that Personal Data or convert it into an anonymous form.

4. Security of Data

We will take reasonable steps to protect your Personal Data in our possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction. For example, we use security measures including safeguarding and monitoring our network and controlling access to our files, equipment, and buildings.

5. Your California Privacy Rights

If you are a resident of the state of California, the following rights are available to you under the California Consumer Privacy Act.

Right to access
You have the right to request that we disclose the categories of Personal Data collected, the categories of sources from which Personal Data is collected, the business or commercial purpose for collection, the categories of third parties with which we share Personal Data, and the specific pieces of Personal Data that we have about you.  You also have the right to request that we provide your Personal Data to you in a readily useable format.

Right to request deletion
You have the right to request that we delete Personal Data that we collected from you.  Note, however, that certain requests to delete Personal Data may be denied if we are required to retain the information as a matter of law, the information is necessary for detecting security incidents, exercising free speech, protecting or defending against legal claims, or for internal uses reasonably aligned with consumer expectations.

Right to non-discrimination
You have the right not to receive discriminatory treatment by us for exercise of these privacy rights.  We do not offer financial incentives related to the provision of data. 

Authorized agent
You have the right to designate an authorized agent to make these requests on your behalf.

To exercise any of these rights, contact us at 1-866-993-6723 or Privacy@uhy-us.com.  You will be required to verify information about your account to confirm your identity in order for your request to be processed.

6. Contact Information

Unless otherwise stated, UHY is a data controller for Personal Data processed subject to this Statement. If you have any questions about this Statement or if you believe that your Personal Data has been processed or disclosed in violation of this Statement, please contact us by sending an email to Privacy@uhy-us.com, or a letter to:

UHY Advisors, Inc.
Attention: Privacy Officer
1185 Avenue of the Americas, 38^th Floor
New York,  NY  10036