Wipfli LLP Privacy Statement

last updated December 23, 2019

Wipfli LLP believes your right to privacy is important.  This privacy statement (“Privacy Statement”) is an explanation of the privacy practices of Wipfli LLP (“Wipfli”, “we”, or “us”).  This Privacy Statement explains the types of information we collect via our website(s) and through other interactions with you, and how we use, share, and protect this information and your rights regarding your personal information.  By using our website or otherwise continuing to access information or communications from Wipfli, you agree to our use of such information in accordance with this Privacy Statement.

Information We Collect

In the course of offering and providing our products and services, we may receive information from and about you through information you provide, automatic tracking technologies and third parties. This information may include information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). 

In connection with our business operations, we may have reason to collect information such as:

  1. Identifying information: such as a real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers, usually related to a registration or directly provided by you.
  2. Financial Information: such as bank account number, credit card number, debit card number or any other financial information, usually as a result of your providing that information to purchase a product or a service or allow us to deliver a service.
  3. Commercial information: such as records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
  4. Internet or other similar network activity: such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  5. Professional or employment-related information: such as your name, employer, current job title, company address, email address, telephone number, and records of correspondence with us.

We do not usually seek to collect sensitive personal information except as necessary to render services requested by you.  Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information.

How We Collect Personal Information

We may collect personal information about you because you provide it directly to us in connection with the services that Wipfli provides or has previously provided, or otherwise.  We may receive personal information from Wipfli affiliates or from third parties, such as your employer, entities in which you have an ownership interest, or a tax authority and/or other relevant authority/administrative bodies.  In some cases we may observe or infer personal information from the information you provide to us and/or the way you interact with us.  In addition, we may receive personal information directly or indirectly from activity on our website (www.wipfli.com).

This personal information may be received by us through many different mediums, including in-person discussions, telephone conversations, and electronic or other written communications.  Without access to all the personal information necessary to deliver a product or service, we may be unable to provide or deliver the product or services. 

Where another party (such as a company or a partnership or any third parties acting on your or their behalf) provides your personal information to us, they must also comply with their obligations under relevant privacy laws and regulations.  If you believe that the entity for whom you work or a third party has not provided you with details of the personal information that it holds about you and/or has not obtained your authority to provide us with that personal information for processing as described in this Privacy Statement, then please contact such entity directly.

Personal Information Relating to Third Parties

If any personal information which you provide to us relates to any third party, for example a spouse or civil partner, individuals (including children) who depend on you financially, or a joint account holder or a beneficiary or trustee of a trust, then by providing us with their personal information you will need to ensure that you have obtained any necessary permissions from those persons to the use of their personal information in the way set out in this Privacy Statement, or you are otherwise permitted to give us this personal information.  You should share a copy of this Privacy Statement with those other individuals before disclosing any personal information about them to us.

How We Use Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  1. To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a tax return, we will use that information to prepare the return and submit it to the applicable taxing authorities.
  2. To provide you with information, products or services that you request from us or our related affiliates.
  3. To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  4. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  5. To improve our website and present its contents to you.
  6. For testing, research, analysis and product development.
  7. As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  9. As described to you when collecting your personal information.
  10. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

How We Share Your Personal Information

We may disclose your personal information to a third party for the following purposes:

  1. Where relevant, we have a contract with you to provide services and processing your personal information is necessary for the performance of such contract.
  2. We have a legitimate interest in processing your personal information, which may be to:
    • provide services to you and/or to the entity that has engaged us to provide the services;
    • support the management of our client engagements;
    • evaluate, develop or improve our services or products; or
    • protect our business interests.
  3. We are subject to legal, regulatory or professional obligations.

When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except in performing the contract.

Third Parties to Whom We Disclose Personal Information

In connection with one or more of the purposes outlined in this Privacy Statement, we may disclose your personal information to:

  1. Wipfli affiliates.
  2. Those with whom you have requested us to share information, such as your spouse or civil partner.
  3. Competent authorities, including courts and authorities regulating us, in each case to comply with legal, regulatory or professional obligations or requests.
  4. Vendors and administrative, support, infrastructure and other service providers handling your information on our behalf; in each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement.
  5. Third parties to whom we disclose information in the course of providing services to you or to the entity that has engaged us to provide the services.

Wipfli does not sell or lease your personal information to others.

Please note that some of the recipients of your personal information referred to above may be based in countries or regions without data protection rules similar to those in effect in your area of residence.  In such cases, adequate safeguards will be in place to protect your personal information.  

For further details about the transfers described above and the adequate safeguards used by Wipfli with respect to such transfers, please contact us using the details below.

Security

We have in place reasonable commercial standards of technology and operational security to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Only authorized personnel, with appropriate awareness of privacy obligations, are provided access to your personal information.

Retention Period

We retain personal information as long as is necessary to fulfil the purposes identified in this Privacy Statement or (i) as otherwise necessary to comply with applicable laws or professional standards, or (ii) as long as the period in which litigation or investigations might arise in respect of our services.

Your Rights

You have various rights in relation to your personal information depending on the jurisdiction in which you are located.  In particular, you may have a right to:

  1. Obtain confirmation that we are processing your personal information and request:
    • A copy of the personal information we hold about you (sometimes referred to as “data portability”);
    • The categories of personal information we collected about you;
    • The categories of sources for the personal information we collected about you;
    • Our business or commercial purpose for collecting or selling that personal information; and
    • The categories of third parties with whom we share that personal information.
  2. Ask that we update the personal information we hold about you, or correct such information that you think is inaccurate or incomplete.
  3. Ask that we delete personal information that we hold about you, or restrict the way in which we use your personal information.
  4. Withdraw consent to our processing of your personal information (to the extent our processing is based on your consent).
  5. Ask us to stop or start sending you marketing messages at any time.
  6. To the extent not inconsistent with applicable professional standards and the ownership of client workpapers, obtain and/or move your personal information to another service provider.
  7. Object to our processing of your personal information.

Where our processing of special category personal information is reliant on your consent and you withdraw that consent, we will cease processing the relevant information for the purposes of providing our services and the effect may be that we are no longer able to provide the services.

However, we may still retain a copy of the relevant information for as long as necessary to comply with applicable laws or professional standards, or as long as the period in which litigation or investigations might arise in respect of our services.

We also may deny your request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  5. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  6. Otherwise comply with local or federal law.

To exercise any of your rights or raise any questions that you have about our use of your personal information, please contact us using the details below.

You or a person authorized to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You are limited as to how frequently you may make a verifiable consumer request for access or data portability. The verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights.

Changes to this Privacy Statement

We may modify or amend this Privacy Statement from time to time at our discretion.  When we make changes to this Privacy Statement, we will amend the revision date at the top of this page and the modified or amended Privacy Statement shall apply to you and your personal information as of that revision date.  We encourage you to review the Privacy Statement on our website periodically to be informed about how we are protecting your personal information.

Contact us

If you have any questions or concerns regarding this Privacy Statement or your personal information, please contact our data protection officer by email at privacy@wipfli.com or by phone at 1.800.265.9577.