Privacy Policy

Effective date: December 9, 2020

This is the website of CliftonLarsonAllen LLP (“CliftonLarsonAllen” or “CLA”). CLA exists to create opportunities for clients, people, and communities through industry-focused wealth advisory, outsourcing, audit, tax, and consulting services.

This privacy policy outlines how we use the data we collect when we interact with you via this website and other sites we operate, and in connection with the services we provide. Certain CLA services or subsidiaries may require additional agreements or consent with regard to how your data is collected, used or disclosed. If you are a client of CLA, please refer to your engagement letter for additional information about the data we collect and use.

By accessing this website, you willingly accept and consent to the privacy policy as described.  In addition, by submitting information to us, you consent to our use of such personal information in accordance with this Privacy Policy.

Information we collect

Personal information that you may submit or may otherwise be collected by CLA on our website includes your name, job title, company name, address, email address, IP address, telephone number, subscription preferences, and internet activity. 

We may also obtain personal information from other websites, social media, CLA personnel, educational institutions, contractors, vendors, suppliers, and subsidiaries.

Personal information we may collect as part of our recruitment or hiring activities includes your name, birth date, marital status, gender, social security number, email address, street address, career experience, educational experience, licenses and certifications, data related to race or ethnic origin, criminal record, and other personal information. By providing such information, you explicitly consent to CLA’s use of that information in accordance with this Privacy Policy or as otherwise agreed upon at the time of disclosure.

How will we use your data?

CLA collects this data so that we can:

  • Aggregate information on what pages users access and use this information to improve and/or personalize the content and design of our website.
  • Send you educational information such as newsletters.
  • Send you administrative communications.
  • Inform you about products, services, events, and promotional offers that you might find interesting. 

We use Workday to display open positions and collect job applications. If you apply for job openings, we may use the personal information you submit to process and evaluate your employment application and to communicate with you about current or future employment opportunities. This information may become part of your employment file. View Workday’s privacy policy here.

Personal information that may be disclosed

CLA may share your personal information as follows:

  • With CLA subsidiaries, to provide services to you or inform you about our services
  • With third-party service providers, who are required to maintain the security and confidentiality of the information we provide to them, and who may not use or disclose the information for any purpose other than for providing services to CLA 
  • To comply with court orders, subpoenas, government investigations, or law enforcement requirements
Cookies

To make this site work properly, we must sometimes place small data files called cookies on your device. Most big websites do this too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size, and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?
  • We use cookies to record session information, record user-specific information on what pages users access or visit, and record past activity at a site in order to personalize site content to user preferences. Cookies may also record websites visited just before and just after our website.
  • Cookies also link users to their customer relationship management (CRM) record if a user is a member of the CLA CRM. This action personalizes site content to visitor preferences (e.g., industry and topic areas of interest).
  • Cookies also identify users across devices (e.g., a user clicks a link in an email from his/her desktop, then, later visits the website via mobile or tablet device; we marry those cookies so users have a consistent website experience across devices).
  • The cookies we employ are not essential for the website to function properly. Cookies are used to enhance the user experience on the site through personalization.
  • We use both session cookies and permanent cookies. A session cookie is stored in temporary memory and is not retained after the browser is closed. In some instances we use permanent cookies. A permanent cookie stores itself on the user’s hard drive in order to remember preferences from session to session.
  • We employ targeting cookies to deliver advertisements relevant to you and your interests on outside websites. A cookie records that you have visited a website (ours and others) or conducted a relevant web search. The cookies and advertisements are placed by advertising networks with our permission. We, our advertisers, and ad serving companies may also use small pieces of code called “web beacons” or “clear gifs” to determine which advertisements and promotions users have seen and how users responded to them.

What types of cookies do we use?

CLA uses both first- and third-party cookies on our website:

First party

SC_ANALYTICS_GLOBAL_COOKIE
ASP.NET_SessionId
CycleProtectionManager
updated_tracker
custom_personal

Third party cookies Google Analytics
Hotjar
Hubspot
Twitter
Facebook
LinkedIn
Google Ads / Double click

We use Google Analytics to analyze how visitors use our site, including its advertising features. Information sent by your browser, including your IP address, may be used as anonymous aggregated statistical data to analyze our web traffic, improve the quality of our website, and enhance your browsing experience. View Google’s privacy policy. You can opt out of Google’s Advertising features through ad settings, ad settings for mobile, or any other available means. Access Google Analytics’ available opt-outs.

We use Hotjar, a technology service that helps us better understand our visitors’ experience (e.g., how much time they spend on which pages, which links they choose to click, what visitors do and don’t like, etc.), and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our visitors’ behavior and their devices (in particular, a device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual visitors or to match it with further data on an individual visitor. For further details, please see Hotjar’s privacy policy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site, and Hotjar’s use of tracking cookies on other websites by opting out here.

Requests to update personal information

All visitors can make a request to update their personal information by sending us an email at the above address, calling us at the above telephone number, writing to us at the above address, or contacting us here.

Data security

At CLA, we place a priority on maintaining the confidentiality and privacy of your information, and we adhere to all professional standards to protect confidentiality, including maintaining internal policies, procedures, and safeguards. However, data submitted via the internet is never completely secure. By accessing this website, you willingly accept and acknowledge all risks associated with such use.

Data retention

CLA retains personal data only for as long as required to provide the services an individual opts to receive, unless laws, regulations or professional standards require a longer retention period.

Children privacy protection

CLA does not intentionally or knowingly collect or maintain personally identifiable information about children under the age of 13.

Your California Privacy Rights

The California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and data portability rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • 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 that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

CLA collects volunteered information that is categorized as Identifiers and Personal information under CCPA. 

Category

Examples

Collected

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, Manual Entry Using Form Required

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, 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, Manual Entry Using Form Required

Personal information does not include:

  • Publicly available information from government records.
  • De-identified 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 of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    - personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Deletion request rights

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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion 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. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal and regulatory obligations.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising access, data portability, and deletion rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize 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 may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • 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 CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How we respond to Do Not Track signals

The Site does not respond to "do-not-track" requests or similar features.

Your General Data Protection Regulation rights

Individuals in the European Union may have additional rights, including to be informed how their personal data is being processed, to be sent a copy of their personal data, to correct inaccurate personal data, and to request that their data be deleted.

You may exercise your rights by submitting a request through our GDPR Rights Request Form, by emailing webmaster@claconnect.com, or by writing to us at the address at the bottom of this page.

Unsubscribe

If you do not want to receive email or phone calls from us in the future, please let us know by sending us an email at the address below, writing to us at the address below, or contacting us here. To stop receiving emails from CLA, click "Unsubscribe" in one of our emails, or visit our subscription center to update your preference. 

Changes to this policy

We will update this privacy policy when necessary to reflect changes to our service offerings or in response to legal or regulatory changes. The effective date at the top of this policy will denote when the policy was last updated. 

How to contact us

If you have any questions about our privacy policy or our data practices, please do not hesitate to contact us.

Email us at webmaster@CLAconnect.com.  

Our postal address is:
220 South Sixth Street, Suite 300
Minneapolis, MN 55402

Call us at 888-529-2648.