DRAFT — FOR ATTORNEY REVIEW

This draft has not been reviewed by counsel and is not a binding or final document. It does not establish legal compliance. Highlighted placeholders mark facts or decisions that are still open.

Privacy Policy

Version 2026-10-19-draft.1 · Effective 2026-10-19 (draft)

How Prowyse describes the information it handles for tax professionals and their clients. Draft for counsel; several facts are still open.

Who this covers

Prowyse is a tax intelligence and client engagement platform used by tax professionals (CPAs, EAs and similar) and their clients. It is not a tax filing service and does not prepare or file tax returns.

Placeholder — counsel/product input required: Prowyse legal entity name, jurisdiction of formation, and mailing address — to be supplied by the product owner. Not established by the repository.

Placeholder — counsel/product input required: Roles of the parties under privacy law (controller/business vs processor/service provider) for each activity below — counsel decision. See the DPA draft for the working assumption.

Information the platform handles

Known from the code:

  • Account details: name, email address, role, and sign-in records (one-time codes are stored only as hashes).
  • Access requests submitted on the public site: name, email, optional firm name and phone.
  • Documents uploaded by clients or their tax professional, including Forms 1040 and supporting tax documents (PDF), stored in private object storage.
  • Information extracted from those documents: tax facts, detected signals, generated alerts, opportunities and document-request status.
  • Client profile and questionnaire answers, including address, household members and — encrypted — SSN/ITIN where entered.
  • Messages between a client and their tax professional.
  • Records of legal-document acceptance and a limited audit log of platform actions. No IP address or device identifier is stored with an acceptance.
  • Email delivery records, which identify recipients by a one-way hash.

Placeholder — counsel/product input required: Whether any analytics, advertising or error-monitoring tools are used in production — none were found in the code; confirm.

How information is used

To operate the platform for the tax professional–client relationship: authenticate users, store and read documents, build a tax profile from uploaded returns, flag document needs, send service emails and let a client and their tax professional communicate.

Placeholder — counsel/product input required: Whether Prowyse uses any customer data for its own purposes (product improvement, analytics, model training) — counsel/product decision. The code does not train models on customer data.

Automated processing and AI providers

Known from the code: text is extracted from uploaded PDFs locally on Prowyse's servers. When document classification is enabled, extracted text from a document, after pattern-based masking of obvious identifiers such as Social Security-style numbers and phone numbers, can be sent to the Jev model service operated by TypeSafe to identify the document type. Masking is not guaranteed to remove all sensitive information.

The code also contains additional OpenAI-based features (a client assistant, a tax professional assistant, and tax-season summaries). They are switched off by default and are blocked unless the deployment is explicitly approved for them, the client's account is activated and the client has accepted the current documents. They are not part of document classification and are under product and legal review.

Prowyse does not use AI to give tax advice, prepare or file returns, or make tax recommendations. Classification suggestions are reviewed by a tax professional.

Placeholder — counsel/product input required: Provider retention, training and data-use terms for TypeSafe/Jev and OpenAI, including any zero-retention arrangement, processing regions and signed data-processing terms — NOT established by the repository. Do not state any assurance until confirmed in writing.

Placeholder — counsel/product input required: Whether a separate, specific consent is required before tax-return information is disclosed to these providers, including review of IRC §7216 and its regulations and any state analogues — counsel decision. Acceptance of this Policy or the Terms is not assumed to satisfy any such requirement. Until resolved, external AI transmission stays disabled by default.

Service providers

Configuration in the repository indicates the following categories. Nothing here confirms what is live in production.

  • Hosting and request rate limiting: Vercel (indicated by the code and runbook).
  • Database: PostgreSQL, Neon indicated for staging.
  • Document storage: Cloudflare R2 (S3-compatible, private bucket).
  • Email: an SMTP provider.
  • AI: TypeSafe (Jev) and OpenAI, as described above.

Placeholder — counsel/product input required: Production providers, sub-processors, processing regions and the SMTP vendor — to be confirmed. Backups and logging providers are not established by the repository.

Sharing

A client's information is visible to that client and the tax professional who invited them. Prowyse staff access, if any, and disclosures required by law:

Placeholder — counsel/product input required: Staff access policy, law-enforcement and legal-process disclosures, and business-transfer language — counsel to draft.

Retention, deletion and export

Known from the code: a client can delete documents they uploaded, which removes the stored file and its record. The code does not currently provide account deletion, data export, automatic retention limits or a termination process.

Placeholder — counsel/product input required: Retention periods, deletion on request or termination, backup retention, data export/portability and legal-hold practices — NOT established; do not state periods until decided.

Security

Known from the code: private document storage accessed only through authenticated routes, encrypted SSN/ITIN fields, one-time-code sign-in, session inactivity logout and rate limiting. No security certification is claimed.

Placeholder — counsel/product input required: Any further security statements (certifications, penetration tests, breach-notification commitments) — only if verified.

Your choices and rights

Placeholder — counsel/product input required: Applicable state privacy laws, the rights they give (access, deletion, correction, opt-out), how requests are received and verified, and whether the Gramm-Leach-Bliley Act or similar regimes apply — counsel decision.

Placeholder — counsel/product input required: Privacy/legal contact (name or role and monitored email address) — to be supplied by the product owner.

Changes

When this Policy changes, the version recorded on this page changes and signed-in users are asked to review and accept the new version before continuing.

Related: Terms of Use · Data Processing Addendum