Privacy Policy

When you submit the Forensic Trace Intake Form on our website, we collect the following categories of information:

• Business Identity Information: Legal entity name, Employer Identification Number (EIN), and IRS filing address.

• Contact Information: Authorized signatory name, title, email address, and phone number.

• Payroll & Operational Data: Payroll system, average W-2 headcount, and niche eligibility indicators (H-2B, Veteran, SNAP/WOTC, High-Turnover).

• Tax & Filing History: IRS 941 filing history, prior 941-X filings, CAF conflicts, and IRS correspondence regarding unapplied credits.

• Audit Scope Selection: Tax years selected for forensic review.

• Technical Metadata: IP address, browser user agent, screen resolution, language settings, and timezone (collected for audit trail and fraud prevention).

Trace Capital Systems uses your information exclusively for the following purposes:

• To initiate and complete a read-only IRS Tax Information Authorization (Form 8821) via DocuSign eSignature.

• To identify unapplied capital positions (TC76X markers) and OBBBA-related ledger offsets (TC-846) on the Federal Tax Ledger.

• To communicate with you regarding your forensic trace case status, recovery eligibility, and next steps.

• To maintain a compliant audit trail as required by IRS Circular 230 for PTIN-registered practitioner entities.

• To satisfy IRS identity authentication requirements for remote practitioners (NIST IAL2 standard).

We do not sell, rent, lease, or otherwise share your information with any third party for marketing or commercial purposes.

As a PTIN-registered forensic practitioner, we are required to verify the identity of all signatories before processing a Form 8821. By submitting our intake form, you authorize us to initiate an identity verification process through DocuSign, which may include:

• Government-issued photo ID upload.

• Liveness detection (selfie match).

• Knowledge-Based Authentication (KBA).

This process generates a DocuSign Certificate of Completion, which is retained as part of our IRS compliance record. Identity verification data is processed by DocuSign, Inc. under their own Privacy Policy (docusign.com/privacy) and is subject to their data security practices.

Trace Capital Systems employs enterprise-grade security measures to protect your information:

• AES-256 Encryption: All sensitive data is encrypted at rest and in transit.

• TLS 1.3: All data transmissions between your browser and our servers use Transport Layer Security.

• Access Controls: Internal access to client data is restricted to authorized personnel on a need-to-know basis.

• Audit Logging: All access to client records is logged and timestamped.

• Signed PDF Storage: Executed Form 8821 documents and DocuSign Certificates of Completion are stored in an encrypted, access-controlled vault.

While we implement industry-standard security practices, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your information.

We retain your information for as long as necessary to fulfill the purposes outlined in this policy and to comply with applicable legal and regulatory obligations, including IRS record-keeping requirements for PTIN holders.

• Active case files are retained for a minimum of 7 years from the date of final resolution, consistent with IRS record retention guidelines.

• Signed Form 8821 documents and identity verification certificates are retained for the duration required by IRS Circular 230.

• If you choose not to proceed with our services after submitting an inquiry, you may request deletion of your non-legally-required records by contacting us at the address below.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you.

• Right to Correction: Request correction of inaccurate or incomplete information.

• Right to Deletion: Request deletion of your personal information, subject to our legal retention obligations.

• Right to Withdraw Consent: Withdraw your authorization at any time by submitting a written revocation of Form 8821 to the IRS.

To exercise any of these rights, contact us at rogers@tracecapitalsystems.com. We will respond within 30 days.

Trace Capital Systems is a forensic recovery firm and does not operate as a Certified Public Accounting (CPA) firm, law firm, or investment advisor. Our services are strictly limited to the identification of unapplied capital (TC76X) and OBBBA-related ledger offsets (TC-846) within the Federal Tax Ledger.

Nothing on this website or provided through our services constitutes tax advice, legal counsel, or fiduciary guidance. Clients are encouraged to consult a licensed CPA or tax attorney for advice specific to their circumstances.

We use the following third-party services in connection with our platform. Each operates under their own privacy policy:

• DocuSign, Inc. — Electronic signature and identity verification platform.

• Base44 — Application hosting and database infrastructure.

We are not responsible for the privacy practices of these third parties. We encourage you to review their respective privacy policies.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the revised policy on this page with an updated effective date. Your continued use of our services after any changes constitutes acceptance of the updated policy.

For questions, concerns, or requests related to this Privacy Policy, contact us at:

Trace Capital Systems

Attn: Privacy & Compliance

rogers@tracecapitalsystems.com

725.234.1388

Ms. Rogers, Director of Client Relations