Privacy Policy
Citadel Partners LLC
Effective Date: December 12, 2025
Last Reviewed: August 23, 2026
This Privacy Policy describes how Citadel Partners LLC ("Company," "we," "us," or "our") collects, uses, processes, discloses, and protects information through www.ctdtax.com (the "Site") and in connection with the tax, accounting, financial, and related services we provide (the "Services"). We are committed to protecting the privacy and confidentiality of the personal and financial information entrusted to us.
A note on scope. Citadel Partners LLC is based in California, and the great majority of the individuals whose personal information we handle are California residents. This Policy is written to reflect the privacy laws most relevant to a California-based firm, including the Gramm-Leach-Bliley Act ("GLBA"), the confidentiality rules for tax return information under 26 U.S.C. Section 7216, and the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"). We extend the California Consumer Privacy Rights described in Section 6 to our clients and Site visitors as a matter of policy, regardless of whether our firm meets every CCPA/CPRA statutory threshold, except with respect to personal information that is exempt under the GLBA (see Section 5).
1. Information We Collect and Retain
1.1 Categories of Personal Information (Last 12 Months)
The categories of personal information we have collected about our clients, prospective clients, and Site visitors in the preceding 12 months, along with why we collect it and how long we generally keep it, are as follows:
Identifiers
Examples: Name, address, email, phone number, IP address, online account name, Social Security Number or Employer Identification Number (SSN/EIN).
Purpose: Providing tax and accounting services, communicating with you, verifying identity, complying with legal and regulatory obligations.
Retention: Generally 7 years after the engagement ends, consistent with IRS recordkeeping rules, or longer if required by law.
Sensitive Personal Information
Examples: SSN/EIN, financial account numbers, government-issued ID numbers, and, only where relevant to a specific credit or benefit you are claiming, demographic information such as racial or ethnic origin.
Purpose: Preparing and filing tax returns, verifying eligibility for certain credits or programs, complying with the GLBA, IRS regulations, and anti-money-laundering laws.
Retention: Same as Identifiers above. We do not use or disclose this information for purposes that would trigger a CCPA "Right to Limit" request.
Financial/Commercial Information
Examples: Income, expenses, investment and account data, transaction history, credit history, assets, and liabilities.
Purpose: Tax preparation, accounting and advisory services, billing, fraud prevention, anti-money-laundering compliance.
Retention: Retained as required under the GLBA and IRS regulations, generally 7 years.
Internet/Network Activity
Examples: Pages visited on the Site, browser and device information, approximate location, interaction with our online forms and client portal.
Purpose: Operating and securing the Site, analytics, improving our online services.
Retention: Typically 12-24 months, except security or audit logs, which may be retained longer.
Professional/Employment Data
Examples: Job title, employer name, employment and income history.
Purpose: Tax preparation and financial planning services.
Retention: Retained with your related client file, generally 7 years.
Inferences Drawn
Examples: Observations about your financial situation, preferences, or planning needs, drawn from the categories above.
Purpose: Tailoring advice and recommendations; internal service improvement.
Retention: Retained only as long as reasonably necessary for the purpose collected, and no longer than the related client file.
1.2 Sources of Personal Information
We obtain the categories of personal information listed above from the following sources:
- Directly from you: through engagement forms, our secure client portal, and verbal, written, or email communications.
- From your devices: through your interaction with our Site and Services, including cookies and server logs (see Section 1.3).
- From third-party service providers: companies we engage for payment processing, identity verification, document management, or IT hosting.
- From financial and government institutions: financial custodians, banks, employers, and government agencies (for example, the IRS or state tax boards) as necessary to perform the Services.
1.3 Cookies and Similar Technologies
Our Site uses cookies, pixels, and similar technologies to operate the Site securely, remember your preferences, and understand how visitors use the Site (for example, through analytics tools). We do not use these technologies to sell your personal information. Most browsers let you block or delete cookies through their settings; doing so may limit some Site functionality. Where applicable, we honor the Global Privacy Control ("GPC") signal as an opt-out preference signal for California residents, as described in Section 6.4.
2. How We Use Your Information
In addition to the purposes listed above, we use personal information to:
- Prepare, review, and file tax returns and related schedules and elections;
- Provide accounting, bookkeeping, payroll, and advisory services you have engaged us to perform;
- Communicate with you about your account, engagement, and our Services, including appointment reminders and document requests;
- Bill for and collect payment for Services;
- Detect, investigate, and prevent fraud, unauthorized transactions, and other illegal activity;
- Comply with applicable law, regulation, professional standards (including IRS Circular 230), and valid legal process; and
- With your consent, send marketing communications about additional services (see Section 12).
3. Disclosure of Personal Information
We do not sell your personal information as "sale" is defined under the CCPA/CPRA, and we have not sold any personal information in the preceding 12 months. We also do not "share" personal information for cross-context behavioral advertising.
We disclose personal information, for business purposes only, to the following categories of recipients:
- Service providers: vendors that perform services on our behalf, such as secure hosting, IT security, document storage, and data analytics, under contracts that limit their use of your information to the services they provide us.
- Governmental and regulatory bodies: the IRS, state tax agencies, and other regulators, as required to prepare and file returns or as otherwise required by law.
- Professional advisers: attorneys, auditors, or other professional advisers, in connection with our business operations or legal obligations.
- Successors: a successor entity in the event of a merger, acquisition, or sale of firm assets, subject to confidentiality protections.
Nevada law permits residents to opt out of certain sales of "covered information" as defined under Nevada Revised Statutes Chapter 603A. Because we do not sell covered information, no action is required to exercise this right; residents with questions may still contact us at the address in Section 16.
4. Special Notice Regarding Your Tax Return Information (IRC Section 7216)
As a paid tax return preparer, we are separately governed by 26 U.S.C. Section 7216 and its implementing Treasury regulations, which restrict how we may use or disclose the tax return information you provide to us. Except as described below, we will not use your tax return information for any purpose other than preparing your return, and we will not disclose it to anyone outside our firm, without your prior written, signed, and dated consent, obtained in the form required by law.
Consistent with Section 7216, we may use or disclose tax return information without separate written consent to:
- Prepare and file your return and communicate with the IRS or state tax authorities on your behalf;
- Other preparers within our firm working on your engagement, and for internal administrative purposes such as quality and peer review;
- Comply with a valid court order, administrative order, or other legal process; and
- Use your name, address, and the fact that you are our client to offer you additional tax preparation services in future years.
For any other use or disclosure - for example, referring you to a third-party financial product, sharing your information with an unaffiliated business, or using it to market non-tax services - we will ask you to sign a separate, specific consent that meets the requirements of Section 7216. You are never required to sign such a consent as a condition of receiving tax preparation services from us, and you may revoke a consent at any time by notifying us in writing.
5. The Gramm-Leach-Bliley Act and Financial Privacy
Citadel Partners LLC is a "financial institution" for purposes of the GLBA because we provide tax preparation and related financial services. The GLBA, its Privacy Rule (Regulation P), and the FTC Safeguards Rule govern how we collect, share, and protect nonpublic personal financial information, and they require us to maintain a written information security program.
If you engage us for Services, you may separately receive an annual financial privacy notice describing our information-sharing practices in the format required by federal law; that notice supplements this Policy and controls with respect to GLBA-covered information in the event of any conflict.
The CCPA/CPRA does not apply to personal information that is collected, processed, or disclosed pursuant to the GLBA and its implementing regulations. Most of the sensitive financial information we collect to provide tax and accounting services is governed by the GLBA and is therefore exempt from the CCPA/CPRA rights described in Section 6. Those rights apply only to personal information that is not covered by the GLBA exemption - for example, general Site browsing data or marketing contact details collected before a client relationship begins.
6. California Consumer Privacy Rights
As a California-based firm, we make the following rights available to California consumers with respect to personal information that is not exempt under the GLBA (see Section 5), regardless of whether our firm independently meets every CCPA/CPRA statutory applicability threshold. If you are a California resident, you have the following rights:
6.1 Right to Know
You may request that we disclose the categories and specific pieces of personal information we have collected, used, and disclosed about you over the past 12 months, and the categories of sources and recipients involved.
6.2 Right to Delete
You may request deletion of your personal information, subject to exceptions such as legal or regulatory retention requirements (for example, IRS recordkeeping rules) and our need to complete a transaction you requested.
6.3 Right to Correct
6.4 Right to Opt Out of Sale or Sharing
We do not sell or share personal information as those terms are defined under the CCPA/CPRA. To the extent we ever use non-GLBA data (such as Site cookies) for cross-context behavioral advertising, you would have the right to opt out, and we honor the Global Privacy Control signal as a valid opt-out request.
6.5 Right to Limit Use of Sensitive Personal Information
We use sensitive personal information only to provide the tax and financial services you have requested, which is the purpose for which it was collected. Our use is therefore already limited to necessary, expected purposes, and we do not use or disclose it in ways that would trigger an additional right to limit.
6.6 Right to Non-Discrimination
We will not deny you goods or services, charge different prices, or provide a different level of service because you exercised a right under the CCPA/CPRA.
6.7 California "Shine the Light" Law
California Civil Code Section 1798.83 separately allows California customers to request certain information about our disclosure of personal information to third parties for those third parties' own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes, so no action is required to exercise this right. If you have questions, you may still contact us using the information in Section 16.
7. Other State Privacy Laws
Because we are based in California and California law is our primary compliance framework, this Policy is written first from that perspective. A number of other states - including Virginia, Colorado, Connecticut, Utah, and others - have also enacted comprehensive privacy laws that, like the CCPA/CPRA, generally exempt information covered by the GLBA. If you reside in one of these states and have questions about rights that may apply to any non-exempt information we hold about you, please contact us using the information in Section 16 and we will address your request under the law applicable to you.
8. How to Exercise Your Rights
To exercise the Right to Know, Right to Correct, or Right to Delete described in Section 6, please submit a verifiable request through one of the following methods:
- Email: privacy@ctdtax.com
- Toll-Free Telephone: (877) 322-1040
We will need to verify your identity before processing your request, which may require you to confirm information we already have on file. You may designate an authorized agent to submit a request on your behalf by providing the agent with written permission signed by you, or a power of attorney; we may still require you to verify your own identity directly with us. We aim to confirm receipt of a verifiable request within 10 business days and to substantively respond within 45 days, with one 45-day extension where reasonably necessary and permitted by law.
9. Data Security
We maintain a written information security program, consistent with the FTC Safeguards Rule, that includes administrative, technical, and physical safeguards designed to protect personal and financial information from unauthorized access, use, alteration, or disclosure. These safeguards include encryption of sensitive information in transit and at rest, multi-factor authentication for access to systems holding client data, restricted employee access on a need-to-know basis, employee training, and oversight of service providers who handle client information on our behalf. No security program can guarantee absolute security, and we encourage you to also take reasonable steps to protect information you share with us, such as using strong passwords for our client portal.
10. Data Retention
We generally retain client records, including tax returns and supporting information, for a minimum of seven years from the end of the engagement, consistent with IRS recordkeeping guidance and our professional obligations, unless a longer period is required by law or a shorter period is appropriate for information not tied to a specific engagement (see Section 1.1). When information is no longer needed, we securely delete or destroy it.
11. Third-Party Links and Services
Our Site may contain links to third-party websites or services, such as a secure client portal, payment processor, or e-filing provider. This Policy does not apply to those third parties, and we encourage you to review their privacy policies before providing them with information.
12. Marketing Communications
If we send you marketing communications by email, you may opt out at any time using the unsubscribe link included in the message or by contacting us at privacy@ctdtax.com. If we contact you by text message, you may reply STOP to opt out. Opting out of marketing communications will not affect service-related communications, such as messages about an active engagement or filing deadline.
13. Children's Privacy
Our Site and Services are not directed to individuals under the age of 16, and we do not knowingly collect personal information from, or sell or share the personal information of, anyone we know to be under 16 years of age. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.
14. Governing Law
This Privacy Policy, and any dispute arising out of or relating to it, is governed by the laws of the State of California, without regard to its conflict-of-laws principles, except to the extent superseded by applicable federal law (including the GLBA and 26 U.S.C. Section 7216). Any legal action relating to this Policy will be brought in the state or federal courts located in Los Angeles County, California, and you consent to the personal jurisdiction of those courts.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. We will post the revised Policy on this page and update the "Effective Date" above. If we make material changes, we will provide additional notice as required by law.
16. Contact Us
If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:
Citadel Partners LLC (ctdtax.com)
Email: privacy@ctdtax.com
Mailing Address: 2390 Crenshaw Blvd, #E508, Torrance, CA 90501
Telephone: (877) 322-1040