1. Introduction

Gain Accounting LLC ("Gain Accounting," "we," "us," or "our") respects your privacy and is committed to protecting the personal and financial information you entrust to us. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at gainacc.com (the "Site"), engage us for fractional CFO, bookkeeping, accounting, or related advisory services (the "Services"), or otherwise interact with us.

As a provider of accounting and financial services, we are considered a "financial institution" under the federal Gramm-Leach-Bliley Act ("GLBA"). This Policy, together with any privacy notice we provide to you as a client, describes our practices for handling nonpublic personal information in accordance with the GLBA and the FTC Safeguards Rule.

Please read this Policy carefully. By using our Site or Services, you acknowledge that you have read and understood the practices described here. If you do not agree with this Policy, please do not use our Site or Services.

2. Scope

This Policy applies to information we collect:

• On or through our Site;

• In the course of providing Services to our clients and their businesses;

• Through email, telephone, text message, and other electronic communications between you and us; and

• Through third-party tools and platforms we use to deliver our Services.

This Policy does not apply to information collected by any third party, including through any application or content that may link to or be accessible from the Site.

3. Information We Collect

We collect several categories of information, depending on how you interact with us.

3.1 Information You Provide Directly

• Contact and identity information — name, business name, title, email address, telephone number, and mailing address.

• Client and engagement information — details about your business, its operations, ownership, and financial goals that you share during onboarding and throughout the engagement.

• Financial information — bank and credit card statements, general ledgers, invoices, receipts, payroll records, tax identification numbers (including EINs and, where necessary, Social Security numbers), financial statements, and other records necessary to perform bookkeeping, accounting, CFO, and tax-related Services.

• Login and access credentials — where you grant us access to your accounting software, banking portals, payroll platforms, or other financial systems, we may collect and store credentials or use secure, token-based connections to those systems.

• Communications — the content of emails, messages, and documents you send to us.

3.2 Information Collected Automatically

When you visit our Site, we may automatically collect certain information about your device and browsing activity, including:

• IP address, browser type, operating system, and device identifiers;

• Pages viewed, links clicked, time spent on pages, and referring URLs; and

• Information collected through cookies and similar tracking technologies (see Section 8).

3.3 Information From Third Parties

We may receive information about you from:

• Your accounting, banking, payroll, or payment platforms, where you have authorized a connection;

• Referral sources and business partners; and

• Publicly available sources and business databases.

4. How We Use Your Information

We use the information we collect to:

• Provide, perform, and administer our Services, including bookkeeping, accounting, fractional CFO, and advisory work;

• Communicate with you about your engagement, respond to inquiries, and provide support;

• Prepare and deliver financial statements, reports, analyses, and other deliverables;

• Process payments and manage billing;

• Operate, maintain, and improve our Site and Services;

• Send administrative information, service updates, and, where permitted, marketing communications about our Services (you may opt out of marketing at any time);

• Comply with legal, regulatory, and professional obligations, including recordkeeping and reporting requirements; and

• Detect, prevent, and address fraud, security incidents, and other harmful or unlawful activity.

We do not sell your personal or financial information.

5. How We Share Your Information

We share information only as necessary to deliver our Services and operate our business, and only as described below. We treat client financial information as confidential.

5.1 Service Providers and Software Platforms

We share information with trusted third-party providers who perform functions on our behalf, such as accounting and bookkeeping software, payroll processors, payment processors, document storage and cloud hosting, and communication tools. These providers are permitted to use your information only as necessary to provide services to us and are obligated to protect it.

5.2 With Your Direction or Consent

We may share information with third parties — such as your bank, attorney, tax preparer, lender, or other advisors — when you direct us to do so or otherwise consent.

5.3 Legal and Regulatory Requirements

We may disclose information when we believe in good faith that disclosure is necessary to comply with a law, regulation, subpoena, court order, or other legal or governmental request, or to enforce our agreements or protect our rights, property, or safety, or those of others.

5.4 Business Transfers

If Gain Accounting is involved in a merger, acquisition, financing, or sale of all or a portion of its assets, your information may be transferred as part of that transaction, subject to the commitments made in this Policy.

6. Data Security

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect nonpublic personal information, consistent with the FTC Safeguards Rule. These measures include access controls, encryption of data in transit and, where appropriate, at rest, secure credential management, and ongoing monitoring.

No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping any credentials you use to access our systems or shared platforms confidential.

If we become aware of a security incident affecting your information, we will notify you and any applicable authorities as required by law.

7. Data Retention

We retain your information for as long as necessary to provide the Services, maintain our business records, and comply with our legal, regulatory, and professional obligations. Accounting and tax records are typically subject to retention periods established by the IRS, state authorities, and professional standards, and may be retained for several years after an engagement ends. When information is no longer needed, we securely dispose of or de-identify it.

8. Cookies and Tracking Technologies

Our Site may use cookies, web beacons, and similar technologies to operate the Site, remember your preferences, analyze traffic, and understand how visitors use the Site. These technologies may be first-party (set by us) or third-party (set by our analytics or advertising providers).

You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain parts of the Site. If we use analytics or advertising services that involve tracking across sites, we will honor applicable opt-out mechanisms, including browser-based signals where required by law.

9. Third-Party Links

Our Site may contain links to third-party websites and services that we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

10. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information, which may include:

• Access — the right to request a copy of the personal information we hold about you;

• Correction — the right to request that we correct inaccurate information;

• Deletion — the right to request deletion of your personal information, subject to legal and recordkeeping exceptions;

• Opt-out of marketing — the right to unsubscribe from marketing communications; and

• Non-discrimination — the right not to be discriminated against for exercising your privacy rights.

Certain rights and exceptions differ by state, and some information we hold — particularly financial records subject to the GLBA and professional recordkeeping requirements — may be exempt from deletion or other requests. To exercise any right, contact us using the information in Section 14. We will respond within the timeframe required by applicable law and may need to verify your identity before fulfilling your request.

11. Children's Privacy

Our Site and Services are intended for businesses and individuals aged 18 and older. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us and we will delete it.

12. GLBA Privacy Notice for Clients

As a financial institution under the GLBA, we are required to inform our clients about our information practices:

• Types of information collected — we collect nonpublic personal information from you and from your transactions and financial accounts as described in Section 3.

• Parties to whom we disclose — we do not disclose your nonpublic personal information to anyone except as permitted by law and as described in Section 5.

• Confidentiality and security — we restrict access to your nonpublic personal information to those who need it to provide Services to you, and we maintain safeguards to protect it.

This notice applies to current and former clients and continues to apply after our engagement ends.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the "Last Updated" date above and, where appropriate, notify you. Your continued use of the Site or Services after changes take effect constitutes acceptance of the revised Policy.

14. Contact Us

If you have questions about this Privacy Policy or our information practices, or if you wish to exercise your privacy rights, please contact us:

Gain Accounting LLC Email: info@gaincfos.com Website: gaincfos.com

This Privacy Policy is provided for general informational purposes and does not constitute legal advice. We recommend having it reviewed by a licensed attorney to confirm it meets your specific obligations under applicable federal and state law before publishing.