ITIN Connect Privacy Notice
> This notice currently applies to users in the State of New York. ITIN Connect is expanding to additional states. A version of this notice covering each new state will be published before ITIN Connect begins accepting users from that state.
Who This Notice Is For
This Privacy Notice explains how Financial Connect CPA PLLC, doing business as ITIN Connect ("we," "us," or "our"), collects, uses, shares, and protects your personal information when you use the ITIN Connect platform. It also explains your rights as a user located in New York.
Please read this notice carefully. If you have questions, you can contact us using the information in Section 10.
1. About ITIN Connect
ITIN Connect is a technology marketplace. We provide a secure online platform that connects individuals who need an Individual Taxpayer Identification Number (ITIN) with independent, IRS-authorized Acceptance Agents and Certified Acceptance Agents. We are not a tax preparation firm, and we do not prepare or file tax returns on your behalf.
Controller (the organization responsible for your data):
Financial Connect CPA PLLC d/b/a ITIN Connect
150 W 51st Street
New York, NY
United States
2. Information We Collect
We collect the following categories of personal information:
2.1 Identity and Application Data
Information you provide when creating an account or submitting an ITIN application, including your full legal name, date of birth, country of birth, mailing address, email address, and phone number.
2.2 Tax Information
Information required to support an ITIN application, including your reason for applying, U.S. tax return information (where applicable), and any tax-related details submitted through the platform.
2.3 Government-Issued Identity Documents and Immigration Documents
[[Sensitive data category]] Copies of identity documents you upload to verify your identity, such as a passport, national identity card, foreign driver's license, or immigration documents (for example, a visa or border crossing card). We also collect foreign tax identification numbers where applicable.
These are sensitive categories of personal information. We handle them with heightened care, as described in Section 7.
2.4 Payment Data
ITIN Connect does not collect payment information from taxpayers. Taxpayers pay nothing to use the ITIN Connect platform. Payment data — including cardholder name, billing address, and transaction records associated with the provider lead-access fee — is collected from Providers (credentialed tax professionals) only. Full payment card numbers are not stored by ITIN Connect. Payment processing for Provider fees is handled by Stripe (see Section 5.2).
2.5 Communications
Messages, notes, and other communications you send through the platform, including communications between you and your selected provider or with our support team.
2.6 Device and Log Data
Technical information collected automatically when you use the platform, including browser type, operating system, pages visited, timestamps, and internet protocol (IP) address. IP addresses are stored in hashed and encrypted form. We do not store your raw IP address.
2.7 Consent Records
Records of any consents you provide through the platform, including consents under Internal Revenue Code §7216 authorizing the disclosure or use of your tax return information.
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Providing the Platform
To create and manage your account, match you with an available provider, facilitate the submission and review of your ITIN application, and communicate with you about your application status.
3.2 Processing Payments
To process the flat lead-access fee charged to Providers (credentialed tax professionals) through our payment processor, Stripe. ITIN Connect does not charge any fee to taxpayers. Taxpayers are not subject to any payment processing through Stripe.
3.3 Identity Verification
To verify your identity in connection with your application and to comply with applicable legal requirements.
3.4 Communications and Notifications
To send you service-related messages, including application updates, account notifications, and responses to your inquiries.
3.5 Platform Security and Fraud Prevention
To monitor and protect the security of the platform, detect and prevent fraud or unauthorized activity, and maintain logs for security and audit purposes.
3.6 Legal and Regulatory Compliance
To comply with our obligations under applicable law, including the New York SHIELD Act, New York General Business Law §349, the FTC Safeguards Rule, and Internal Revenue Code §7216.
3.7 Platform Improvement
To analyze aggregated, de-identified usage data to understand how the platform performs and to improve user experience. We do not use your identifiable personal information for this purpose.
4. Legal Bases for Processing
We process your personal information on the following grounds:
Contract performance: Processing your application and providing the services you have requested.
Legal obligation: Complying with applicable federal and state laws, including tax regulations and financial data security requirements.
Legitimate interests: Maintaining platform security, preventing fraud, and improving our services, where these interests are not overridden by your privacy rights.
Consent: Where we ask for your consent — for example, for §7216 disclosures — we process your information on that basis. You may withdraw consent at any time, though withdrawal does not affect processing that has already occurred.
5. How We Share Your Information
We do not sell your personal information. We share your information only in the limited circumstances described below.
5.1 Your Selected Provider
When you select an IRS-authorized Acceptance Agent or Certified Acceptance Agent through the platform, we share the information necessary for that provider to review and support your ITIN application. Sharing of tax return information for this purpose is subject to your §7216 consent.
5.2 Technology and Infrastructure Partners
We use the following third-party technology providers to operate the platform. Each acts as a service provider (or, where applicable, a data processor) and is permitted to use your information only to provide services to us.
Google LLC (Google Cloud Platform) — Encrypted cloud storage, database operations, and platform runtime infrastructure. ITIN Connect uses Google Cloud Storage for document storage, Cloud SQL for database operations, and Cloud Run for platform runtime. All production infrastructure operates within the United States.
Reducto AI — Automated document processing to extract information from identity and application documents. Reducto AI operates under a data processing agreement with ITIN Connect and maintains a subprocessor list available at trust.reducto.ai. Note: AWS appears on Reducto's subprocessor list. AWS does not receive taxpayer data directly from ITIN Connect.
Stripe, Inc. — Payment processing. Stripe processes payment card data directly and is independently subject to PCI DSS compliance requirements. ITIN Connect does not store full card numbers.
Twilio Inc. — SMS and voice communication services used to send platform notifications and verification messages.
Postmark (ActiveCampaign, LLC) — Transactional email delivery for account notifications and application updates.
5.3 Support Personnel
Authorized ITIN Connect support staff may access your information when necessary to respond to your inquiries or to resolve technical issues. Access is limited to what is necessary and is governed by confidentiality obligations.
5.4 Legal Requirements and Protection of Rights
We may disclose your information if we believe in good faith that doing so is required to comply with a legal obligation (such as a court order or government request), to protect the rights, property, or safety of ITIN Connect, our users, or others, or to enforce our terms of service.
5.5 Business Transfers
If ITIN Connect or Financial Connect CPA PLLC is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.
6. How Long We Keep Your Information
We retain your information for as long as necessary to provide our services and comply with our legal obligations. The table below summarizes our standard retention periods.
Category
Retention Period
W-7 application data and supporting documents
3 years from submission
§7216 consent records
Duration of engagement plus 3 years
Government-issued identity and immigration documents
30 days after the end of your engagement
Payment records
7 years (to satisfy tax and financial recordkeeping requirements)
Communications (messages and support records)
3 years
Device and log data
3 years
After the applicable retention period, we securely delete or de-identify your information. Some information may be retained for longer periods where required by law or where necessary to resolve a dispute or enforce an agreement.
7. Sensitive Information
Certain categories of information we collect — including government-issued identity documents, immigration documents, and foreign tax identification numbers — are considered sensitive personal information. We apply the following additional protections to this data:
Access is restricted to personnel and service providers who require it to perform specific, authorized tasks.
Identity documents are deleted 30 days after the end of your engagement (see Section 6).
Automated document processing (performed by Reducto AI) is conducted under a data processing agreement that prohibits use of your information for any purpose other than providing the contracted service.
We do not use sensitive information for advertising, profiling, or any secondary purpose.
8. How We Protect Your Information
We maintain a Written Information Security Program (WISP) in compliance with the FTC Safeguards Rule and the New York SHIELD Act. Our technical security measures include:
Encryption at rest: All data stored on the platform is encrypted using AES-256 encryption.
Encryption in transit: All data transmitted between your device and our platform is protected using TLS 1.2 or higher.
IP address protection: IP addresses are stored in hashed and encrypted form. Raw IP addresses are not retained.
Access controls: Access to personal information is limited to authorized personnel on a need-to-know basis.
Vendor oversight: We require all technology partners to maintain appropriate security standards through contractual obligations.
No system can guarantee absolute security. If you believe your account has been compromised, please contact us immediately using the information in Section 10.
9. Your Rights as a New York User
New York law provides you with rights regarding your personal information. This section explains those rights and how to exercise them.
9.1 Right to Be Notified of a Breach
Under the New York SHIELD Act, if a security breach occurs that exposes your private information, we are required to notify you in the most expedient time possible and without unreasonable delay.
9.2 Right to Access
You have the right to request confirmation of whether we hold personal information about you and to receive a copy of that information.
9.3 Right to Correction
You have the right to request that we correct inaccurate or incomplete personal information we hold about you.
9.4 Right to Deletion
You have the right to request that we delete personal information we hold about you.
Important limitation: We may be unable to delete certain information if we are required to retain it by law or regulation. For example, §7216 consent records and payment records are subject to mandatory retention periods described in Section 6. Where we cannot fully honor a deletion request, we will explain the reason.
9.5 How to Exercise Your Rights
To submit a request, please contact us using the information in Section 10. We will respond within a reasonable time and may need to verify your identity before processing your request. We will not discriminate against you for exercising your rights.
10. How to Contact Us
If you have questions about this Privacy Notice, wish to exercise your rights, or want to report a concern, please contact us:
ITIN Connect — Privacy Inquiries
Financial Connect CPA PLLC d/b/a ITIN Connect
150 W 51st Street
New York, NY
United States
privacy@itin-connect.com
11. Governing Law
This Privacy Notice is governed by and interpreted in accordance with the following applicable laws and regulations:
New York SHIELD Act (Stop Hacks and Improve Electronic Data Security Act) — governing data security and breach notification requirements for New York residents.
New York General Business Law §349 — prohibiting deceptive acts and practices in the conduct of business.
FTC Safeguards Rule (16 C.F.R. Part 314) — establishing standards for safeguarding customer financial information.
Internal Revenue Code §7216 — governing the use and disclosure of tax return information by tax return preparers and related service providers.
12. Changes to This Notice
We may update this Privacy Notice from time to time. When we make changes, we will update the version number and effective date at the top of this document and notify you through the platform or by email where required by law. We encourage you to review this notice periodically.
The current version of this notice and its history are identified in the document footer below.
Document ID: DOC-PRIV-20260815 | Version: v1.3.0 | Effective: August 15, 2026 | Financial Connect CPA PLLC d/b/a ITIN Connect | New York — Pilot Version
ITIN Connect Consumer Marketplace Terms
Document ID: DOC-CMKT-20260815
Version: v1.1.0
Effective Date: August 15, 2026
Issued by: Financial Connect CPA PLLC d/b/a ITIN Connect
Address: 150 W 51st Street, New York, NY
These terms govern your use of the ITIN Connect platform as a taxpayer ("you" or "Taxpayer"). Please read them carefully. By accessing or using the platform, you agree to these terms.
1. What ITIN Connect Is — and Is Not
1.1 Technology Marketplace
ITIN Connect is a technology marketplace operated by Financial Connect CPA PLLC. It provides three core services: document management, provider-matching, and case coordination.
1.2 Not a Tax Preparer
ITIN Connect does not prepare, file, or opine on any federal tax return or ITIN application. ITIN Connect does not provide tax advice. All substantive tax preparation judgment is made exclusively by the credentialed tax professional ("Provider") you select through the platform.
1.3 Your Relationship With Your Provider
When you are matched with a Provider, you enter into a separate engagement directly with that Provider. The terms of that engagement are governed by the Provider-Taxpayer Engagement Letter, not by these terms.
2. Platform Access — Free for Taxpayers
2.1 No Platform Fee for Taxpayers
Use of the ITIN Connect platform is free for taxpayers. You owe no fee to ITIN Connect for access to the platform's document management, provider-matching, and case coordination services.
2.2 Your Provider's Professional Fee
The services provided by your selected Provider — including ITIN application preparation and submission — are subject to the Provider's professional fee. That fee is agreed between you and your Provider and is governed by the Provider-Taxpayer Engagement Letter, not by these terms.
2.3 How ITIN Connect Is Compensated
ITIN Connect charges credentialed Providers a flat lead-access fee for access to the platform. This fee is paid by the Provider, not by you. It is not tied to your personal information.
3. No Guarantee of ITIN Approval
3.1 IRS Makes All Decisions
ITIN Connect makes no representation, warranty, or guarantee that your ITIN application will be approved. The Internal Revenue Service ("IRS") independently determines all eligibility and approval decisions. Neither ITIN Connect nor your Provider controls those decisions.
3.2 No Implied Warranty
Nothing in these terms or in any platform communication should be read as a promise or prediction of approval.
4. Your Provider's Independence
4.1 Independent Professional
Your Provider is an independent credentialed tax professional. The Provider is not an employee, agent, or contractor of ITIN Connect. ITIN Connect does not supervise or direct your Provider's professional judgment, tax analysis, or work product.
4.2 Credential Verification
ITIN Connect verifies Provider credentials before allowing a Provider to be activated on the platform. This verification does not make ITIN Connect responsible for the Provider's professional acts or omissions after activation.
4.3 No Liability for Provider Conduct
ITIN Connect is not liable for any act, omission, error, or professional judgment made by your Provider. If you have a concern about your Provider's professional services, please refer to Section 7 (Dispute Resolution) and the Provider-Taxpayer Engagement Letter.
5. Limitation of ITIN Connect's Liability
5.1 Cap on Liability
To the fullest extent permitted by applicable law, ITIN Connect's total liability to you for any claim arising out of or related to the platform or these terms is limited to one hundred dollars ($100.00). Because ITIN Connect provides platform access to taxpayers at no charge, this cap reflects the maximum liability ITIN Connect accepts for its technology services.
5.2 Excluded Damages
ITIN Connect is not liable for any consequential, indirect, incidental, special, or punitive damages, even if ITIN Connect has been advised of the possibility of such damages.
5.3 IRS Decisions and Processing
ITIN Connect is not liable for any IRS decision, IRS processing delay, rejection of an ITIN application, or any outcome or consequence arising from the ITIN application process.
6. Cancellation
6.1 Cancellation Before Engagement
You may cancel your use of the platform at any time before a Provider has been matched to your case and before any work has commenced. Because ITIN Connect does not charge taxpayers a platform fee, there is no charge associated with cancellation.
6.2 Cancellation After Engagement Commences
If a Provider has been matched and work has commenced, you may still cancel at any time. No fee is owed to ITIN Connect. Any amount owed to your Provider for services already rendered is governed solely by the Provider-Taxpayer Engagement Letter.
6.3 Provider Fee Refund Policy
The refund policy for your Provider's professional fee is governed solely by the Provider-Taxpayer Engagement Letter. ITIN Connect has no authority over the Provider's fee.
7. Dispute Resolution
7.1 Disputes With Your Provider
Disputes about professional services, work quality, or the Provider's fee are between you and your Provider. You should refer to your Provider-Taxpayer Engagement Letter for the process to address those disputes. ITIN Connect may, at its sole discretion, facilitate communication between you and your Provider, but ITIN Connect is not responsible for resolving professional disputes.
7.2 Disputes With ITIN Connect
Any dispute between you and ITIN Connect arising out of or relating to platform services shall be governed by the laws of the State of New York and submitted to binding arbitration in New York, New York, under commercially reasonable arbitration rules.
7.3 Injunctive Relief
Notwithstanding Section 7.2, either party may seek emergency injunctive or equitable relief from a court of competent jurisdiction without waiving the right to arbitrate the underlying dispute.
8. Prohibited Uses
8.1 Prohibited Conduct
You may not use the ITIN Connect platform to:
submit fraudulent or materially misleading applications;
impersonate another person or submit documents in another person's name without lawful authority; or
submit documents you know to be false, forged, or altered.
8.2 Consequences of Violation
Violation of this Section may result in immediate suspension or termination of your platform access. ITIN Connect reserves the right to refer violations to the IRS, law enforcement, or other appropriate authorities. No compensation will be owed to you by ITIN Connect if your access is terminated due to a violation of this Section.
9. Amendments to These Terms
9.1 Right to Update
ITIN Connect may update or modify these terms from time to time. When it does, the document version number and effective date will be updated accordingly.
9.2 Notice of Material Changes
ITIN Connect will provide notice of any material change before it takes effect. Notice may be provided by email, in-platform notification, or other reasonable means.
9.3 Acceptance by Continued Use
If you continue to use the platform after receiving notice of a material change, you accept the updated terms. If you do not accept the updated terms, you should stop using the platform and contact ITIN Connect to discuss your options.
10. Governing Law
These terms are governed by and construed in accordance with the laws of the State of New York, without regard to its conflict-of-laws principles. The parties consent to the exclusive jurisdiction of the courts located in New York, New York, for any matter not subject to arbitration under Section 7.
11. Entire Agreement
These terms, together with the following documents, constitute the entire agreement between you and ITIN Connect regarding your use of the platform:
Privacy Notice
§7216 Consent
AI-Processing Consent
Lead-Sharing Disclosure
Provider-Taxpayer Engagement Letter
In the event of a conflict between these terms and any of the above documents, the document most specific to the subject matter of the conflict will control.
12. Contact Information
If you have questions about these terms or the platform, you may contact ITIN Connect at:
Financial Connect CPA PLLC d/b/a ITIN Connect
150 W 51st Street
New York, NY
support@itin-connect.com
Document ID: DOC-CMKT-20260815 | Version: v1.1.0 | Effective: August 15, 2026 | Financial Connect CPA PLLC d/b/a ITIN Connect
Lead-Sharing Disclosure
ITIN Connect — Operated by Financial Connect CPA PLLC
150 W 51st Street, New York, NY
Document ID: DOC-LDSH-20260815 | Version: v1.1.0 | Effective: August 15, 2026
1. Purpose of This Disclosure
This disclosure explains what happens to your personal information when you are matched with a tax professional through the ITIN Connect platform. Please read this document carefully before your information is shared with any provider. By proceeding with the match, you confirm that you have read and understood this disclosure.
2. What Is ITIN Connect?
ITIN Connect is a technology marketplace operated by Financial Connect CPA PLLC. ITIN Connect is not a tax preparer and does not prepare or file any tax documents on your behalf. The platform connects taxpayers who need an Individual Taxpayer Identification Number (ITIN) with credentialed tax professionals who can assist them.
3. Who Is the Provider?
The provider you are matched with is an independent tax professional. Providers on the ITIN Connect platform may be:
Certifying Acceptance Agents (CAAs)
Acceptance Agents (AAs)
Certified Public Accountants (CPAs)
Enrolled Agents (EAs)
Licensed Attorneys
You select your provider from the available matches shown to you on the platform. The provider is not an employee or agent of ITIN Connect. The provider operates under their own professional license and is independently responsible for the services they provide to you.
4. What Information Is Shared With the Provider?
When you are matched with a provider, the following information about you will be made available to that provider:
Your full name
Your contact information, including your email address and phone number
Five data fields extracted from your identity documents by the platform's document-processing technology: full name, date of birth, country of document issuance, document number, and document expiration date
Your application details as submitted through the ITIN Connect intake form
Your uploaded identity documents, made available to the provider for review
A record confirming that you have provided your consent to this disclosure under Internal Revenue Code Section 7216
5. How the Provider May Use Your Information
The provider may use your information only for the purpose of preparing and submitting your ITIN application. Specifically:
The provider is contractually required to use your information solely for your ITIN application
The provider may not use your information for any other purpose
The provider may not share your information with any third party, except as strictly necessary to prepare and submit your ITIN application
6. What ITIN Connect Receives
ITIN Connect charges a flat technology fee for access to the platform. This fee is paid by the provider and is not tied to your personal information. ITIN Connect does not receive a referral fee or any portion of the provider's professional fee. The matching of you with a provider is not a sale of your personal information.
7. California Privacy Notice (CCPA/CPRA)
If you are a California resident, please note the following. This disclosure does not constitute a "sale" or "sharing" of your personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA). ITIN Connect does not receive monetary or other valuable consideration from the provider in exchange for your personal information. The provider pays a flat technology fee for access to the platform, not a fee connected to or dependent on your information.
8. Your Rights and Choices
8.1 Right to Decline
You may choose not to be matched with a provider. If you choose not to proceed, your information will not be shared. Please be aware that if you decline the match, you will not be able to use the ITIN Connect platform to obtain ITIN application services.
8.2 Right to Request a Different Provider
Before your engagement with a provider formally begins, you may request to be matched with a different provider. Please contact ITIN Connect support to make this request.
8.3 Limitation After Engagement Begins
Once a provider has been engaged and work on your ITIN application has commenced, you may not withdraw this lead-sharing disclosure or request that the provider's access to your information already shared be reversed. At that stage, your application is in process and the provider is acting in reliance on the information provided.
9. Questions
If you have questions about this disclosure or about how your information is handled, please contact ITIN Connect at:
Financial Connect CPA PLLC d/b/a ITIN Connect
150 W 51st Street, New York, NY
support@itin-connect.com
Document ID: DOC-LDSH-20260815 | Version: v1.1.0 | Effective: August 15, 2026 | Financial Connect CPA PLLC d/b/a ITIN Connect
Marketing Email Consent
Checkbox Label
☐ Yes, I'd like to receive occasional marketing emails from ITIN Connect. (Optional — you do not need to check this box to use the platform.)
Disclosure
By checking the box above, you agree to receive promotional emails from Financial Connect CPA PLLC d/b/a ITIN Connect, 150 W 51st Street, New York, NY, including updates about platform features, new services, and related financial or tax services. These emails will be sent infrequently — on average no more than twice per month. This consent covers email only and does not authorize SMS marketing or the sharing of your information with third-party advertisers or data brokers. Every marketing email will include an unsubscribe link, and you may opt out at any time; unsubscribe requests will be honored within 10 business days as required by the CAN-SPAM Act. Unsubscribing from marketing emails has no effect on transactional messages or communications about your ITIN case, which are sent separately and are not governed by this consent.
Document ID: DOC-MKEC-20260815 | Version: v1.0.0 | Effective: August 15, 2026 | Financial Connect CPA PLLC d/b/a ITIN Connect