Privacy Policy

1. Who We Are

Total Wealth Tax Advisory ("Total Wealth Tax", "we", "our", or "us") is a CPA and tax-advisory firm headquartered at 4165 E Thousand Oaks Blvd, STE #355, Westlake Village, CA 91362. We provide tax preparation, tax advisory, bookkeeping, payroll, IRS and state representation, and related professional services to businesses and individuals throughout California and nationwide.

Total Wealth Tax Advisory works in coordination with Total Wealth Services, LLC — an SEC-registered investment adviser ("RIA") — as two complementary professional practices under shared leadership. Each firm is a separate legal entity; the RIA provides investment advisory services and the CPA firm provides tax services. This coordination is how we deliver integrated tax and investment planning to our clients.

This Privacy Policy describes how we collect, use, store, share, and protect your personal and financial information when you visit https://totalwealthtax.dev (the "Site"), use our secure client portal, submit an inquiry, upload documents, or engage us as a client.

By using our Site or submitting information to us, you acknowledge that you have read and understood this Policy. If you do not agree with these terms, please do not use our Site or submit personal information to us.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily submit, including:

• Contact and identification data — name, email address, phone number, mailing address, and business name provided through our contact, inquiry, or appointment request forms.
• Engagement intake data — filing status, entity type, estimated annual revenue, industry, number of employees, tax year, and similar information you share when initiating a consultation or engagement.
• Financial and tax records — prior-year returns, W-2s, 1099s, K-1s, financial statements, payroll records, bank statements, and other documents you upload through our secure Onvio client portal or share with our team directly.
• Account credentials — email address and password for your portal account (passwords are stored using industry-standard hashing; we never see your plaintext password).
• Communications — messages, notes, and attachments you send us by email, phone, or through the portal.

2.2 Information Collected Automatically

When you visit our Site, our infrastructure and analytics tools may automatically collect:

• IP address and approximate geographic location
• Browser type, operating system, and device identifiers
• Pages visited, time on page, and referral URL
• Session and cookie identifiers (see Section 7)

This data is used to operate and improve the Site and is not used to build individual advertising profiles.

2.3 Information from Third Parties

We may receive supplemental information from our software partners when you authorize those integrations as part of your engagement — for example, bookkeeping or payroll platforms connected during an active engagement. We do not purchase marketing lists or data from data brokers.

3. How We Use Your Information

We use your information for the following purposes:

• Service delivery — preparing tax returns, providing advisory services, managing bookkeeping and payroll engagements, and representing you before tax authorities.
• Client communications — responding to inquiries, sending engagement updates, sharing documents, scheduling appointments, and providing year-round advisory support.
• Portal and account management — authenticating your identity, maintaining your tax organizer responses, tracking workflow tasks, and storing documents securely.
• Coordinated advisory — sharing relevant data between the CPA firm and Total Wealth Services, LLC to deliver integrated tax and investment planning, subject to the confidentiality obligations described in Section 4.
• Compliance and legal obligations — maintaining records as required by CPA professional standards, IRS Circular 230, California Board of Accountancy rules, SEC Regulation S-P (for RIA clients), and applicable state and federal law.
• Security and fraud prevention — monitoring for unauthorized access, detecting suspicious activity, and safeguarding client data.
• Site improvement — analyzing aggregate, anonymized usage data to improve Site functionality and user experience.
• Marketing (with consent) — if you have opted in, sending newsletters, tax planning reminders, or service updates. You may unsubscribe at any time.

We do not sell your personal information. We do not use your financial or tax data for any purpose unrelated to delivering our professional services to you.

4. Professional Duty of Confidentiality

As a licensed CPA firm, we are bound by the American Institute of CPAs (AICPA) Code of Professional Conduct, IRS Circular 230, and California Business & Professions Code Section 5063 (accountant-client privilege). As a coordinated RIA, Total Wealth Services, LLC is bound by its fiduciary duty and SEC Regulation S-P. All client tax information, financial records, and communications related to an active or former engagement are treated as strictly confidential.

We do not disclose client information to third parties except:

• with your express written consent;
• as required by law, court order, or regulatory obligation (e.g., IRS summons, subpoena, SEC examination, or professional board inquiry);
• to engage subcontractors or service providers who perform work on your engagement, subject to the confidentiality and data-security obligations described in Section 5; or
• in connection with a lawful transfer of the practice, in which case affected clients will be notified in advance.

Information shared between Total Wealth Tax Advisory and Total Wealth Services, LLC in connection with coordinated client engagements is covered by the confidentiality obligations of both firms and is not a "disclosure" for purposes of this Policy.

5. Information Sharing and Third-Party Service Providers

We work with a limited set of vetted third-party platforms to operate our practice. Each receives only the data necessary for its specific function:

We require all service providers to maintain appropriate data-security measures and to use client information solely to perform services on our behalf. We do not authorize them to use your data for their own marketing or to sell it to others.

6. Document Storage, Onvio Portal, and Retention

Documents you submit as part of an engagement are handled through our Thomson Reuters Onvio client portal, which uses encrypted cloud infrastructure for secure upload, storage, and exchange. Access is restricted to you and to Total Wealth Tax personnel assigned to your engagement.

Documents may also be stored in our internal Supabase-backed portal for workflow tracking and communication. Both systems use encryption at rest and in transit. All personnel access is role-based and logged.

We retain client records for a minimum of seven (7) years after the conclusion of an engagement, consistent with IRS guidelines, AICPA standards, SEC recordkeeping rules, and California professional licensing requirements. After the applicable retention period, records are securely deleted or permanently anonymized.

You may request copies of your records at any time by contacting us at info@totalwealthtax.com. We will respond within ten (10) business days.

7. Cookies and Tracking Technologies

Our Site uses cookies and similar technologies to authenticate sessions, remember preferences, and collect aggregate analytics. We do not use third-party advertising cookies or cross-site tracking cookies.

Strictly necessary cookies — required for login session management and security. These cannot be disabled without affecting core functionality.

Analytics cookies — aggregate, anonymized data on Site usage. No personally identifiable information is shared with analytics providers.

Most browsers allow you to block or delete cookies in your settings. Blocking strictly necessary cookies may prevent you from accessing the client portal.

8. Data Security

We implement and maintain reasonable administrative, technical, and physical safeguards to protect your personal and financial information, including:

• TLS/HTTPS encryption for all data transmitted to and from our Site;
• AES-256 encryption for data stored in our database and file storage;
• Role-based access controls limiting who can view client records;
• Multi-factor authentication required for staff portal access;
• Regular security reviews of our infrastructure and third-party integrations.

No system is perfectly secure. In the event of a breach that materially affects your personal information, we will notify you as required by applicable law (California Civil Code § 1798.82 and, for RIA clients, SEC Regulation S-P). Notice will be provided by email to the address on file or, if email is unavailable, by written notice.

9. Investment Advisory Privacy (RIA Affiliation)

If you receive investment advisory services through Total Wealth Services, LLC, that engagement is separately governed by the RIA's Form ADV Part 2 and its privacy notice provided at or before the commencement of the advisory relationship, as required by SEC Regulation S-P. Your information held in the investment advisory capacity is subject to the RIA's fiduciary duty and the applicable federal privacy rules.

The coordination of information between the CPA firm and the RIA — for example, sharing your tax projection with your financial planner — is done for the purpose of delivering integrated services and is disclosed to you as part of the engagement process. It is not a sale or marketing use of your data.

Clients may request a copy of the current Form ADV Part 2 or Form CRS for Total Wealth Services, LLC at any time by contacting us at info@totalwealthtax.com.

10. California Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know — you may request a summary of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to Delete — you may request deletion of personal information we hold about you, subject to our legal retention obligations and professional-standards requirements.
• Right to Correct — you may request correction of inaccurate personal information.
• Right to Opt Out of Sale / Sharing — we do not sell or share personal information for cross-context behavioral advertising. No opt-out is required.
• Right to Non-Discrimination — we will not discriminate against you for exercising any CCPA/CPRA rights.

Note: Much of the financial data we hold as a CPA firm is exempt from certain CCPA provisions under the Gramm-Leach-Bliley Act (GLBA) financial institution exemption, and investment advisory data is governed separately by SEC Regulation S-P. Where an exemption applies, we will inform you.

To exercise any of the above rights, contact us at info@totalwealthtax.com or call (805) 751-6760. We may need to verify your identity before processing your request.

11. Children's Privacy

Our Site and services are directed to adults and businesses. We do not knowingly collect personal information from children under the age of 13. If you believe we have inadvertently collected information from a child, please contact us immediately and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. When we make material changes, we will post the revised policy on this page with an updated "Last Updated" date and, for active clients, send notice by email. Your continued use of the Site after the effective date of a revised policy constitutes acceptance of the changes.

13. Contact Us

Questions, requests, or concerns about this Privacy Policy or our data practices may be directed to: