Privacy &
AI Policy.

Part I

Privacy Policy

We collect information necessary to provide tax preparation, bookkeeping, and advisory services. This includes:

• Identity information: full name, date of birth, Social Security Number or ITIN, government-issued ID
• Financial information: income statements (W-2, 1099, K-1), bank and investment account records, business financial statements, QuickBooks or other accounting data
• Contact information: email address, phone number, mailing address
• Business information: entity type, EIN, ownership structure, state registrations, officer information
• Prior-year tax returns and supporting documentation
• Communications: emails, messages, and call notes related to your engagement
• Website usage data: IP address, browser type, pages visited, and referral source via standard web analytics

We use your information exclusively to:

• Prepare, review, and file federal and state tax returns on your behalf
• Provide bookkeeping, advisory, and financial planning services as engaged
• Communicate with you regarding your engagement, deliverables, and deadlines
• Comply with IRS, state tax authority, and regulatory requirements
• Maintain our internal records and practice management systems
• Send engagement-related documents, proposals, and invoices
• Improve our internal workflows and quality controls

We disclose client information only as permitted or required by IRC § 7216 and Circular 230 § 10.51. Specifically, we may share your information:

• With the IRS, state tax authorities, or other agencies as required to file returns or respond to notices on your behalf
• With third-party service providers directly supporting your engagement — including our practice management platform (TaxDome), proposal software (Ignition), and bookkeeping platform (QuickBooks Online) — who are contractually bound to protect your information
• With successor practitioners or firms if our practice is sold or transferred, with prior written consent
• As required by law, court order, or regulatory authority
• With your explicit written consent for any other purpose

We retain client records in accordance with IRS recordkeeping requirements and California state law. Tax return information is retained for a minimum of seven (7) years from the date of filing. Electronic records are stored in encrypted, access-controlled systems. Physical documents are stored securely and destroyed using certified methods when retention periods expire.

You have the right to:

• Request a copy of the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information, subject to our legal retention obligations
• Withdraw consent for any discretionary use of your information
• File a complaint with the IRS Office of Professional Responsibility or applicable state authority if you believe your information has been improperly disclosed

To exercise any of these rights, contact us at clay@mytrailhead.tax.

Part II

AI Use Policy

Our current AI tools were each deliberately selected because they operate under policies that prohibit using customer data to train their models. We use:

We do not use general-purpose free-tier consumer AI products for any work involving client financial data. Every AI tool that may touch client data must pass our vendor evaluation process before it is approved for use.

Our AI infrastructure is designed with the following data protections:

• AI calls involving client data route only through approved providers (Anthropic API, Google Workspace) — both contractually prohibit using inputs for model training
• No client data is routed through third-party API aggregators, model routers, or middleware that would introduce additional data handlers
• Client data processed by AI is stored in our own infrastructure, not in AI provider systems
• Access to AI-processed client records is limited to credentialed practitioners and authorized staff
• AI systems receive only the minimum data necessary to complete a specific task

Trailhead Tax continuously evaluates and adopts new systems — practice management tools, AI assistants, automation platforms, document processing services, and client-facing software. Because our work involves highly sensitive financial and tax data, every new system goes through a formal vetting process before client data is ever permitted to touch it.

Our evaluation criteria include:

No AI output becomes a client deliverable, filed document, or formal recommendation without explicit review and approval by a credentialed practitioner. This applies to:

• Tax return data, calculations, or supporting schedules
• Written tax advice or planning recommendations
• Client-facing communications generated or drafted by AI
• Document summaries or data extractions used in return preparation
• Automated insights surfaced through our client portal

AI-assisted actions that affect client engagements (such as proposal generation or advisory summaries) are held in draft state until reviewed and explicitly approved by Clay Welch, EA. Automated actions are never taken on a client's behalf without practitioner authorization.

All staff with access to AI tools and client data receive training covering:

• This AI Use Policy and the Circular 230 provisions it implements
• The prohibition on entering client data into unapproved AI systems
• How to identify and escalate AI-generated errors or hallucinations
• The review and approval workflow for AI-assisted deliverables
• IRC § 7216 data disclosure obligations

This policy is reviewed and updated at least annually, or whenever a new AI tool is adopted, applicable IRS guidance is issued, or a material change in our AI infrastructure occurs. The current version is always published at mytrailhead.tax/privacy.

Questions

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