Privacy Policy

Last updated: December 12, 2025

We respect and are committed to protecting your privacy. We may collect personally identifiable information when you visit our site. We also automatically receive and record information on our server logs from your browser including your IP address, cookie information and the page(s) you visited. We will not sell your personally identifiable information to anyone.

Froehling Anderson Ltd. (“Company”, “we”, “our”, or “us”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes how we collect personal data about you when you visit our websites that link to this policy (our “Website”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Website.
• In communications, including web form submissions, chat, and other electronic messages, between you and us through the Website.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party that does not link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.
• Any information you share with us in the course of receiving professional accounting, tax, or financial services from us. Such information is subject to separate confidentiality and regulatory obligations as may be described in privacy policies specific to those services (e.g., separate terms applicable to the third-party hosted customer portal used by our customers to upload tax records, separate terms applicable to payment information collected through the third-party hosted payment portal, etc.).

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Website or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children’s and Minors’ Data

Our Website is not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include:

• Contact information, including name, email address, phone number, and other contact information you provide us.
• Location information, including general geographic location such as country, state or province, or city.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
• Content and information you elect to provide through the “Contact Us” page on the Website.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website page or feature.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Website, such as clickstream information to, through, and from our Website (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Website, such as when you submit content through the “Contact Us” page.

Automatically Through Our Website

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Website, such as traffic data, location data, logs, and other communication data, and which resources and Website features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Website and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Website. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Website.
• Web Beacons. Some parts of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from the use of these automated technologies for such uses by submitting your request to CONTACTUS@FA-CPA.COM. Please note that some Website features may be unavailable as a result.

When you interact with the Website, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Your device manufacturer.
• Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal data, or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Website and any contents, features, information, products, or services that we make available through the Website.
• Fulfill any other purpose for which you provide it.
• Improve our Website, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Website and its features and how users interact with it.
• Promote our services, business, and offerings by publishing advertising on our own Website and by placing ads on third parties’ services. We may use your information to model, segment, target, offer, market, and advertise our services.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you about changes to any products or services we offer or provide through the Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The Usage Information We Collect

The usage information we collect, whether connected to your personal data or not, helps us improve our website and services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the website according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our website.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our organization (e.g., to Google Analytics for marketing analytics purposes).
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Froehling Anderson Ltd.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, Marketing, Cookies, and Other Tracking Technologies Choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some website features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our website may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
• Promotions by the Company. Our standard practice is to not use the information you submit to the website to promote our products or services beyond the scope of your inquiry. If at any time you do not wish us to use your information to promote our products or services, you can opt out by emailing us at CONTACTUS@FA-CPA.COM or by calling 952-979-3100 during regular business hours 8:00-4:00 Central Time Zone.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability.You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. Although our current practice is to not use your personal data for targeted advertising, profiling, and sales (except in response to your direct inquiries to us), you may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please email us at CONTACTUS@FA-CPA.COM or mail requests to Froehling Anderson, 400 Highway 169 S. Suite 400, Minneapolis, MN 55426. To appeal a decision regarding a consumer rights request, please email Ntran@fa-cpa.com.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

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 Website. You should carefully decide what information you send to us via the Website. Any transmission of personal data is at your own risk.

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

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Website, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Website. We may email or otherwise communicate reminders about this policy, but you should check our Website periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: CONTACTUS@FA-CPA.COM