Brown & Associates Ledger LLC - Privacy Policy for The Silence Tax
1. Introduction and Scope
This Privacy Policy ("Policy") explains how Brown & Associates Ledger LLC ("Company," "we," "us," or "our") collects, uses, discloses, and protects personal data of users ("User," "you," or "your") in connection with The Silence Tax™ website, archive, and related services ("Service").
By accessing or using the Service, you acknowledge that you have read and understood this Policy and agree to its terms.
This Policy is intended to comply with applicable data protection and privacy laws, including the European Union General Data Protection Regulation (GDPR, Regulation (EU) 2016/679, Articles 13-21), the California Consumer Privacy Act (CCPA, Cal. Civ. Code §§ 1798.100-1798.199), and other applicable privacy laws.
2. Definitions
"Personal Data" means any information relating to an identified or identifiable natural person.
"Processing" means any operation performed on Personal Data, including collection, storage, use, or disclosure.
"Controller" means the entity determining the purposes and means of processing Personal Data.
"Processor" means any entity processing Personal Data on behalf of the Controller.
"Third Party" means any natural or legal person other than the User, Controller, or Processor.
"Service" refers to The Silence Tax website, archive, podcast, and submission system operated by the Company
3. Information We Collect
We collect the following categories of information:
1. Identifiers - email address and payment details (processed securely by Stripe).
2. Usage Data - analytics such as page views, downloads, and session duration.
3. Transactional Data - subscription status, billing history, and toll submission details.
4. Technical Data - IP address (country-level only), browser type, and access timestamps. We do not collect names beyond those provided for payment, social media profiles, detailed location data, or behavioral tracking.
4. Legal Bases for Processing (GDPR Article 6)
We process Personal Data under the following legal bases: - Contractual necessity: To provide you with subscription access or toll submission services. - Legal obligation: To comply with financial, tax, and consumer protection laws. - Legitimate interest: To maintain system integrity and prevent fraud. - Consent: When required for optional communications or international data transfers.
5. How We Use Personal Data
We use Personal Data to: - Manage Archive subscriptions and toll submissions. - Process payments and comply with accounting requirements. - Communicate essential service information (no marketing). - Monitor technical performance and ensure service reliability. - Respond to lawful requests and enforce our Terms of Service.
We do not sell or rent Personal Data. We do not engage in automated decision-making or profiling.
6. Data Sharing and Third Parties
We share data only with trusted service providers essential to operating The Silence Tax:
| Category | Provider | Purpose |
|---|---|---|
| Payment Processor | Stripe, Inc. | Secure payment processing |
| Hosting | Ghost Foundation Ltd. | Website and archive hosting |
| Podcast Distribution | Buzzsprout, Inc. | RSS delivery and analytics |
| Security and DNS | Cloudflare, Inc. | Content delivery and protection |
Each provider processes data in accordance with its own privacy policy and under a data processing agreement with the Company. No Personal Data is sold, exchanged, or disclosed for advertising.
7. International Data Transfers
Personal Data may be transferred and stored outside your country of residence, including in the United States. When data is transferred from the European Economic Area (EEA) or the United Kingdom, such transfers are conducted under the European Commission's Standard Contractual Clauses or equivalent lawful safeguards.
8. Legal Requests and Disclosure
We may disclose information in response to lawful subpoenas, court orders, or government requests where required by law. When permitted, we will notify the affected user before disclosure.
9. Data Retention
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Payment records | Minimum 7 years | IRS and accounting compliance |
| Subscriber email addresses | Duration of subscription through end of contract + 90 days | Ongoing processing |
| Accepted toll submissions | Permanent | Archival record |
| Rejected submissions | 30 days post-decision | No business purpose |
| System logs | 3 years | Operational security |
After these periods, data is securely deleted or anonymized.
10. Data Security
We implement appropriate technical and organizational measures to protect Personal Data, including: - SSL/TLS encryption during transmission - Restricted administrative access - Periodic security audits - Data minimization and anonymization where possible
However, no online system is entirely secure, and the Company cannot guarantee absolute security.
11. Your Rights (GDPR Articles 13-21; CCPA §§ 1798.100-1798.199)
Users within the European Union (GDPR):
You have the right to access, rectify, delete, restrict, or object to processing of your Personal Data, and the right to data portability. You also have the right to lodge a complaint with your supervisory authority.
Archival Limitation on Erasure: Certain content published to the Archive is retained for archival and documentary purposes. Under GDPR Article 17(3)(d), the right to erasure does not apply where processing is necessary for archiving purposes in the public interest or for the establishment, exercise, or defense of legal claims. For that reason, while we may anonymize associated account or billing data upon request, we will not remove accepted Toll Submissions from the Archive except where we are legally required to do so or where publication presents a material legal risk.
Users within California (CCPA):
You may request disclosure of categories and specific pieces of Personal Data collected, request deletion of your Personal Data (subject to legal retention requirements), and opt out of any sale of data (we do not sell data).
To exercise these rights, email privacy@thesilencetax.com with your request. We may require verification of identity before fulfilling requests. Responses are provided within 30 days (GDPR) or 45 days (CCPA).
12. Children's Privacy
The Service is not intended for individuals under the age of 18. We do not knowingly collect data from minors. If we become aware that Personal Data has been collected from a child under 18, it will be deleted promptly.
13. Policy Updates and Notifications
We may update this Policy periodically. Any material changes will be posted on the Service with a revised "Last Updated" date. Continued use after such updates constitutes acceptance of the revised Policy.
14. Governing Law and Dispute Resolution
This Policy and any disputes arising under it are governed by the laws of the State of Wyoming, United States.
All disputes shall be resolved through confidential binding arbitration before an independent arbitrator located in Wyoming, unless prohibited by applicable law. Each party shall bear its own costs unless the arbitrator determines otherwise.
Judgment on the arbitration award may be entered in any court of competent jurisdiction.
15. Severability
If any provision of this Policy is found to be unlawful, void, or unenforceable, that provision shall be deemed severable and shall not affect the validity and enforceability of the remaining provisions.
16. Contact Information
For all privacy-related requests, questions, or concerns, please contact:
Email: privacy@thesilencetax.com
Mailing Address: Brown & Associates Ledger LLC, c/o Registered Agent, State of Wyoming, United States.
Designated Privacy Officer: Compliance & Data Protection Lead