LEGAL

Privacy Policy & Terms of Service

Effective Date: July 20, 2026. Last Reviewed: July 20, 2026.

Privacy Policy

Cromwell CFO, LLC, doing business as Cromwell Advisors | Accountants ("Cromwell," "we," "us," or "our"), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit cromwellcfo.com (the "Site") or engage our services. By using the Site, you agree to the practices described here.

1. Information We Collect

We collect information in the following ways:

Information you provide. Name, business name, email address, telephone number, and any details you submit through contact, onboarding, engagement, or affiliate forms, or by email or phone.
Financial and business information. In the course of providing bookkeeping, accounting, tax, and CFO advisory services, we receive financial records and related business information. This information is handled as confidential and is governed by your Client Engagement Agreement.
Information collected automatically. When you visit the Site, we may automatically collect device and usage data such as IP address, browser type, pages viewed, and referring URLs, through cookies and similar technologies.
Information from third parties. We may receive information from service providers, referral partners, or publicly available sources to support our services and communications.

2. How We Use Information

We use information to provide and administer our services; respond to inquiries; prepare proposals and engagement documents; operate, maintain, and improve the Site; send administrative and, where permitted, marketing communications; and comply with legal, tax, and professional obligations.

3. How We Share Information

We do not sell your personal information. We may share information with: service providers and subprocessors who support our operations (for example, accounting platforms, payment processors, email and hosting providers) under confidentiality obligations; professional advisors such as legal counsel; and authorities or other parties where required by law, to protect our rights, or in connection with a merger, acquisition, or sale of assets. Client financial information is disclosed only as necessary to deliver services or as authorized or required by law.

4. Cookies & Tracking Technologies

The Site may use cookies and similar technologies to enable functionality and to understand how the Site is used. You can control cookies through your browser settings; disabling them may affect some features.

5. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We retain information for as long as needed to provide services, maintain business and financial records, and comply with legal, tax, and professional retention requirements, after which it is deleted or de-identified.

7. Your Rights & Choices

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal information, or to object to or restrict certain processing. You may opt out of marketing emails at any time using the unsubscribe link. To exercise any right, contact us using the details below.

8. Third-Party Links

The Site may link to third-party websites we do not control. We are not responsible for the privacy practices or content of those sites, and encourage you to review their policies.

9. Children's Privacy

The Site is intended for a business audience and is not directed to children under 16. We do not knowingly collect personal information from children.

10. Your U.S. State Privacy Rights

Business audience; individual business owners. Cromwell provides services to businesses, and this Site is intended for a business (B2B) and professional audience. Many U.S. state privacy laws apply to information about individual "consumers" and contain exemptions for certain business-to-business and professional contexts. Because our clients and prospects are frequently individual business owners, sole proprietors, and other individuals, information we handle may relate to identifiable individuals. Where that is the case, applicable state consumer-privacy laws may apply, and we reasonably consider and seek to honor the rights and protections described below regardless of whether a particular exemption might otherwise apply.

Several U.S. states have enacted comprehensive consumer-privacy laws, including California (CCPA, as amended by the CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and a growing number of others. If you are a resident of one of these states, you may have some or all of the rights described below with respect to your personal information (or, under some laws, "personal data"). The specific rights available depend on your state of residence and applicable exemptions.

Rights that may be available to you:

Right to know / access. Request confirmation of whether we process your personal information and access to the specific pieces and categories we hold.
Right to correct. Request correction of inaccurate personal information.
Right to delete. Request deletion of personal information we have collected, subject to legal, tax, and professional recordkeeping exceptions.
Right to data portability. Request a copy of your personal information in a portable, readily usable format.
Right to opt out. Opt out of the "sale" or "sharing" of personal information and of "targeted advertising," and of certain "profiling" with legal or similarly significant effects, as those terms are defined under applicable law.
Right to limit use of sensitive information. Where applicable, limit the use and disclosure of sensitive personal information to what is necessary to provide our services.
Right to non-discrimination. You will not receive discriminatory treatment for exercising any of these rights.

We do not sell your personal information and do not "share" it for cross-context behavioral (targeted) advertising, as those terms are defined under the CCPA/CPRA and similar laws. We do not knowingly process the sensitive or personal information of consumers in ways that require opt-in consent without obtaining it where required.

Categories of personal information we collect may include identifiers (such as name, email address, and phone number); professional, employment, or business information; commercial and financial information provided in connection with our services; and internet or device activity such as usage data. We collect this information from you directly, automatically through the Site, and from service providers and referral partners, and we use and disclose it for the business purposes described in this Policy. We do not use or disclose personal information for purposes incompatible with those disclosed here.

How to exercise your rights. You (or an authorized agent acting on your behalf) may submit a request by emailing hello@cromwellcfo.com or calling 561-421-4992. We will verify your request using information reasonably necessary to confirm your identity, and we will respond within the timeframe required by your state's law (generally 45 days, subject to permitted extensions).

Appeals. If we decline to take action on your request, you may appeal our decision by replying to our response or contacting us at hello@cromwellcfo.com. Where required (for example, under Virginia, Colorado, and Connecticut law), we will inform you in writing of our decision on the appeal and, if the appeal is denied, of your right to contact your state Attorney General.

California "Shine the Light." California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing.

Do Not Track & opt-out preference signals. Where required by law, we honor recognized browser-based opt-out preference signals (such as Global Privacy Control) as a valid request to opt out of sale/sharing for the browser or device that sends them.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes are effective when posted, with the "Last Updated" date revised accordingly.

12. Contact Us

Cromwell CFO, LLC · Cromwell Advisors | Accountants · Jupiter, Florida
Email: hello@cromwellcfo.com · Phone/Text: 561-421-4992

Terms of Service

These Terms of Service ("Terms") govern your access to and use of cromwellcfo.com (the "Site"), operated by Cromwell CFO, LLC d/b/a Cromwell Advisors | Accountants ("Cromwell"). By accessing or using the Site, you agree to these Terms. If you do not agree, do not use the Site.

1. Services & the Engagement Relationship

The Site provides general information about Cromwell and its services. It does not itself create a client, advisory, accounting, tax, or attorney relationship. Professional services are provided only under a separate written Client Engagement Agreement, which governs the scope, fees, and terms of any engagement and controls in the event of any conflict with these Terms.

2. No Professional Advice

Content on the Site is provided for general informational purposes only and does not constitute accounting, tax, financial, investment, or legal advice, and should not be relied upon as such. You should consult a qualified professional regarding your specific circumstances before acting.

3. Eligibility

You must be at least 18 years old and able to form a binding contract to use the Site.

4. Acceptable Use

You agree not to use the Site unlawfully; to interfere with its operation or security; to attempt unauthorized access to any system or data; or to copy, scrape, or exploit Site content except as expressly permitted.

5. Intellectual Property

The Site and its content, including text, graphics, logos, the Cromwell name and lion crest, and design, are owned by or licensed to Cromwell and protected by intellectual-property laws. You may not use them without our prior written permission.

6. Third-Party Links & Content

The Site may contain links to third-party sites and resources provided for convenience. We do not endorse and are not responsible for their content, products, or practices.

7. Disclaimer of Warranties

The Site is provided "as is" and "as available," without warranties of any kind, whether express or implied, including merchantability, fitness for a particular purpose, and non-infringement. We do not warrant that the Site will be uninterrupted, error-free, or secure.

8. Limitation of Liability

To the fullest extent permitted by law, Cromwell and its members, officers, employees, and contractors will not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or data, arising from or related to your use of the Site.

9. Indemnification

You agree to indemnify and hold harmless Cromwell from any claims, losses, or expenses (including reasonable attorneys' fees) arising from your use of the Site or violation of these Terms.

10. Governing Law & Dispute Resolution

These Terms are governed by the laws of the State of Florida, without regard to its conflict-of-laws rules. Any dispute arising from these Terms or the Site will be subject to the exclusive jurisdiction of the state and federal courts located in Florida, unless otherwise required by applicable law.

11. Changes to These Terms

We may revise these Terms at any time. Changes are effective when posted, with the "Last Updated" date revised accordingly. Your continued use of the Site constitutes acceptance of the revised Terms.

12. Contact Us

Cromwell CFO, LLC · Cromwell Advisors | Accountants · Jupiter, Florida
Email: hello@cromwellcfo.com · Phone/Text: 561-421-4992