CUMMINS WORLDWIDE™

Privacy Policy

Effective Date: July 1, 2026

Cummins Worldwide™ ("Company," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, and protect the personal information of our clients, prospective clients, and website visitors (collectively, "you") in connection with the services we provide and our website.

Cummins Worldwide™ provides financial, operational, and family office services to its clients.

We do not sell your personal information. Ever.

1. Information We Collect

We collect only what we need to provide our services and comply with applicable law. This falls into two categories:

Information you provide. When you engage us or contact us, you may give us:

• Name, address, phone number, and email address
• Government-issued identifiers (e.g., Social Security number or tax identification number) required for tax preparation and filing
• Financial records, income information, business records, and accounting data necessary to perform our services
• Employment and personnel information for clients using our HR and staffing services
• Any other information you submit through our intake forms or client portal

Information we collect automatically. When you visit our website, we collect standard usage data such as your IP address, browser type, pages visited, and cookies. This information helps us keep the site running and understand how it is used.

Information from third parties. We may receive information from banks, prior accountants, or other parties you authorize, when that information is needed to deliver a service.

2. How We Use Your Information

We use your information to:

• Perform the services you have engaged us for
• Prepare financial statements, tax returns, and other documents and reports
• Meet our legal and regulatory obligations, including IRS requirements, GLBA obligations, and applicable Florida law
• Communicate with you about your account, updates to our services, or administrative matters
• Detect and prevent fraud and protect the security of our systems and your information

We do not use your personal information for targeted advertising and we do not sell it to any third party for any purpose.

3. How We Share Your Information

We share your information only to the extent necessary to do our job or comply with the law. Specifically:

• With service providers (such as cloud storage, software platforms, and payment processors) who are bound by confidentiality obligations and may not use your data for any other purpose
• With government agencies, taxing authorities, or regulators when required by law (for example, when filing a tax return on your behalf or responding to a lawful subpoena)
• With professional advisors (such as attorneys or other accountants) when you direct us to coordinate with them
• In connection with a business transfer such as a merger or acquisition, subject to equivalent confidentiality protections
• With your explicit written consent for any other purpose

We do not share your personal information with affiliates or business partners for their own marketing or commercial purposes.

4. Financial Privacy Notice (GLBA)

Because we provide financial services, federal law — specifically the Gramm-Leach-Bliley Act ("GLBA") — gives you the right to limit certain sharing of your financial information. We share your nonpublic personal financial information only as described in Section 3 above. We do not share it with unaffiliated third parties for marketing purposes. You do not need to take any action to opt out of sharing we are not doing.

5. Data Security

We protect your information using reasonable physical, electronic, and administrative safeguards — including password protection, encryption, and access controls. No security system is perfect. While we work hard to protect your data, we cannot guarantee that unauthorized access will never occur.

6. Data Breach Notification

If we determine that a breach of your personal information has occurred that creates a risk of harm, we will notify you in accordance with applicable law, including Florida's Information Protection Act (Fla. Stat. § 501.171), which generally requires notification within thirty (30) days of determining a breach has occurred. If a breach affects more than five hundred (500) Florida residents, we will also notify the Florida Department of Legal Affairs.

7. Data Retention

We keep your information for as long as necessary to provide our services, satisfy our legal obligations, and resolve any disputes. Tax and financial records are generally retained for a minimum of seven (7) years, consistent with IRS requirements and applicable law. When we no longer need your information, we dispose of it securely.

8. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, or request deletion of your personal information. California residents have additional rights under the California Consumer Privacy Act ("CCPA"), including the right to know what categories of personal information we have collected about you, the right to request deletion, and the right to know that we do not sell your personal information.

To exercise any of these rights, contact us using the details in Section 11. We will respond within forty-five (45) days, as required by law, or notify you if we need additional time.

9. Cookies and Website Tracking

Our website uses essential cookies to function properly. We may also use analytics cookies (such as Google Analytics) to understand how visitors use the site. Analytics cookies collect data in a way that does not directly identify you. You can control or disable cookies through your browser settings; doing so may affect how the site functions.

Our website is not responsible for the privacy practices of any third-party websites we may link to. Once you leave our site, this Privacy Policy no longer applies.

10. Children's Privacy

Our services and website are not directed to anyone under the age of eighteen (18). We do not knowingly collect personal information from children.

11. Contact Us

If you have questions about this Privacy Policy, want to exercise your rights, or need to report a concern, please contact us:

Cummins Worldwide™
625 Court St, Suite 100, Clearwater, FL 33756
Email: Info@Cummins.World
Phone: +1 (727) 223-5335

We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy on our website and update the Effective Date above. Continued use of our services after a change constitutes acceptance of the updated policy.