Privacy Policy (California Residents/CCPA)

Effective Date: May 26, 2026

This California Privacy Policy describes how GC Consultants, Inc. (“Company,” “we,” or “us”) collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information in an employment capacity. Employees, job applicants, contractors, interns, or other workers seeking more information about our employment-related personal information policies and practices should send an email to privacy@gcconsultants.com

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy policy at: https://gcconsultants.com/privacy/

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.

Personal Information Categories Chart

The chart below identifies the categories of personal information we collected from our consumers within the last 12 months.

Category	Examples	Collected	Retention Period
A. Identifiers.	A real name, alias, 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.	YES	7 years
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“California Customer Records”).	A name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, membership in professional organizations, professional licenses and certifications, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	7 years
C. Protected classification characteristics under California or federal law (“Protected Classes”).	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).	YES	7 years
D. Commercial information.	Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	7 years
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	N/A
F. Internet or other similar network activity.	Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.	NO	N/A
G. Geolocation data.	Physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited.	YES	N/A
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.	NO	N/A
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES	7 years
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (“FERPA Information”).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO	N/A
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO	N/A
L. Sensitive personal information.	Further identified in the chart below.	YES	7 years

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sensitive Personal Information Category	Collected to Infer Characteristics?	Retention Period
L.1. Government identifiers, such as your Social Security number (SSN), driver’s license, state identification card, or passport number.	NO	N/A
L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.	NO	N/A
L.3. Precise geolocation, such as GPS data from a consumer’s mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet.	NO	N/A
L.4. Racial or ethnic origin.	NO	N/A
L.5. Citizenship or immigration status.	NO	N/A
L.6. Religious or philosophical beliefs.	NO	NA
L.7. Union membership.	NO	N/A
L.8. Mail, email, or text messages not directed to the Company.	NO	N/A
L.9. Genetic data.	NO	N/A
L.10. Neural Data, such as information generated by measuring a consumer’s central or peripheral nervous system’s activity that is not inferred from nonneural information.	NO	N/A
L.11. Unique identifying biometric information.	NO	N/A
L.12. Health information.	NO	N/A
L.13. Sex life or sexual orientation information.	NO	N/A
L.14. Children’s personal information (under age 16).	NO	N/A

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as from interviews with you and financial documents, forms, letters and email, text, chat, and other electronic messages or other information you provide to the Company.
• In tax returns you or an authorized person provide to us
• Indirectly from you, such as from your interactions with the Company’s website, mobile application, personal Sharefile folder, or emails
• From information provided to us by trusted advisors (with your consent)
• Government databases, such as federal and state tax authorities.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose personal information, including sensitive personal information, we collect to advance the Company’s business and commercial purposes, specifically to:

• Develop, offer, and provide you with our products and services, such as audit and review, income tax preparation and compliance, sales tax, transfer pricing, accounting services, bookkeeping services, preparation of financial statements, tax due diligence, back office consulting, business management consulting, advisory services, valuation, payroll services, and management of benefit plans, or other services.
• Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
• Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Protect our Company, employees, or operations.
• In the course of a review of our firm’s practices under the authorization of a state or national licensing board, or as necessary to properly respond to an inquiry from such a licensing board or organization.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• Manage your consumer relationship with us, including for:
• Sharefile folder creation, maintenance, and security;
• reaching you, when needed, about your account.
• Perform data analytics and benchmarking.
• Administer and maintain the Company’s systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, affiliates, clients, contractors, and agents.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
• disclose sensitive personal information to another third party; or
• use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
• verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
• improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes. Subject to your limitation rights, the additional sensitive personal information use purposes include all of the purposes described in the Personal Information Collection, Use, and Disclosure Purposes section. For more on your right to limit these additional sensitive personal information use purposes, see Your Rights and Choices.

Additional Categories or Other Purposes

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. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or de-identified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to you as the client, service providers and contractors, and federal and state tax authorities, for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to support our business functions. For example, we may disclose information from your visits to the Company’s website to a cybersecurity consultant to help secure the website.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The chart below identifies the personal information categories we disclosed to service providers or contractors for a business purpose over the preceding 12 months and the specific business or commercial purpose for disclosing that information/categories of entities to whom we have disclosed our consumers’ personal information for a business purpose over the preceding 12 months, along with the personal information categories disclosed and the disclosure’s business purposes.

Business Purposes Disclosure Recipient Category, Personal Information Category, and Purposes Chart

Category of Business Purpose Disclosure Recipients	Personal Information Categories Disclosed	Sensitive Personal Information Categories Disclosed	Business Purpose Disclosures
Order Fulfillment and Shipping Providers	A. Identifiers. B. California Customer Records. D. Commercial information.	None	To deliver products you purchased from us.
Customer Service Support Providers	A. Identifiers. B. California Customer Records. C. Commercial Information.	NONE	To support customers with using our products and services, including online account management and troubleshooting.
Advertising networks	Non applicable	NONE	To deliver location-based advertising.

Selling or Sharing Personal Information

We do not sell your personal information, including sensitive personal information, to third parties and have not sold it in the preceding 12 months.

Our personal information sharing does not include information about consumers we know are under age 18.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of:
• personal information we collected about you; and
• sources from which we collected your personal information.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
• disclosed for a business purpose to each category of persons; and
• sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit”). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes, we do not currently provide this consumer right.

For more on the Permitted SPI Purposes and our additional use purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”).

As we do not sell or share consumers’ personal data, we do not currently provide these consumer rights/We cannot share your personal information after we receive your request to opt-out unless you later consent to the sharing of your personal information. For more on exercising your opt-out rights, see Exercising the Right to Limit or Opt-Out.

Right to Non-Discrimination

You have the right not to be discriminated against or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct

To exercise the right to know (including data portability), delete, or correct described above, please submit a verifiable request to us by either:

• Emailing us at privacy@gcconsultants.com or sending mail to the address in the Contact Us field.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.

Exercising the Right to Limit or Opt-Out.

You can submit your request to limit or opt-out through:

• Emailing us at privacy@gcconsultants.com or sending mail to the address in the Contact Us field.

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, email us at privacy@gcconsultants.com or send mail to the address in the Contact Us field, We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information, such as identity verification and authority to act.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

We consider requests made through your password-protected Sharefile folder with our company sufficiently verified when the request relates to personal information associated with that specific account. You do not need to create an account with us to submit a request to know, correct, or delete.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact privacy@gcconsultants.com.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort.

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 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.

Response and Timing on Rights to Limit or Opt-Out

In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. You do not need to create a Sharefile folder with us to exercise your limitation and opt-out rights. We will only use personal information provided within your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request to limit or opt-out and instruct them to both:

• Comply with your request.
• Forward the request to their own downstream recipients, if applicable.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.

Once you make a request to limit or opt-out, we will wait at least 12 months before asking you to reauthorize the use or disclosure of your sensitive personal information for purposes other than the Permitted SPI Purposes or personal information sharing. However, you may change your mind and opt back in at any time by sending an email to privacy@gcconsultants.com.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us through these communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depend on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Applicable Law

All disputes against GC Consultants, Inc., including but not limited to disputes as to this Policy, website access restriction and/or termination, our intellectual property, privacy and disclaimer of warranties shall be governed by the laws of the State of New York (without giving effect to its conflicts of law principles). Except otherwise expressly provided, all legal proceedings arising out of or in connection with this Policy and other website policies shall be brought solely in the City of New York, State of New York. Use of the website is unauthorized in any jurisdiction that does not give effect to all provisions of this Policy.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time as we continue to develop our compliance program in response to legal developments of the CCPA. If we make any material changes to this Privacy Policy, we will update the policy’s effective date and post the updated policy on our https://gcconsultants.com/privacy-california// We encourage you to check our https://gcconsultants.com/privacy-california/ to review the current Privacy Policy in effect.

Applicable Law

All disputes against GC Consultants, Inc., including but not limited to disputes as to this Policy, website access restriction and/or termination, our intellectual property, privacy and disclaimer of warranties shall be governed by the laws of the State of New York (without giving effect to its conflicts of law principles). Except otherwise expressly provided, all legal proceedings arising out of or in connection with this Policy and other website policies shall be brought solely in the State of New York in the county in which our offices reside. Use of the website is unauthorized in any jurisdiction that does not give effect to all provisions of this Policy.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use or wish to exercise your rights under California law, or if you need to access this Privacy Policy in an alternative format due to a disability, please do not hesitate to contact us at:

PHONE: 212-310-9311

ADDRESS: 444 Madison Ave, #1206, New York, NY 10022

EMAIL ADDRESS: privacy@gcconsultants.com

To register a complaint or concern, please email privacy@gcconsultants.com.