Skip to content
FBAR Guard

Privacy Notice

Updated

In brief

FBAR Guard uses your information to prepare your FBAR and to keep your FBAR records organised while your plan is active. We do not sell your information, and we do not submit anything to FinCEN or the IRS for you.

Your confirmed FBAR records and the documents you upload are kept for different periods: uploaded statements can be deleted once they have served their purpose. After your subscription ends, you have 90 days to download your records.

1. Who is responsible for your information

FBAR Guard is the controller of the personal information described in this notice. FBAR Guard is a Dutch business registered with the Netherlands Chamber of Commerce (KVK) under number 98128477. Contact details are on the Contact page.

For privacy questions or requests, email privacy@fbarguard.com.

2. Information we process

CategoryExamples
Account and registrationName, email address, login credentials, your acceptance of the Terms and this notice, and the plan and family options you select.
Filer profileFor each person whose FBAR is prepared: name, address, date of birth, and a U.S. taxpayer identification number or, if there is none, a foreign identification document.
Foreign-account informationFinancial institution and its address, account number, account type, currency, ownership details such as joint owners, and annual maximum values.
Uploaded documentsStatements, exports and prior FBARs you upload so account information can be extracted or reviewed.
FBAR recordsThe prepared FBAR, its filing confirmation where available, and the calculation information behind each annual maximum.
Subscription and paymentSubscription status and identifiers from our payment provider. We do not store card numbers.
CommunicationsMessages you send us, for example support requests and complaints.
Technical informationIP address, browser and device information, and request logs needed to deliver and secure the website and Services.

When you only read this website, we process technical information only. The website does not currently use cookies or analytics; see the Cookie Policy.

3. Purposes and legal bases

PurposeLegal basis
Creating your account, registering your interest and providing the Services, including preparing FBARs and keeping your FBAR recordsPerformance of our contract with you, or steps you ask us to take before entering into it
Answering questions, support and complaintsPerformance of our contract; our legitimate interest in helping people who contact us
Billing, bookkeeping and tax administrationLegal obligation
Keeping the website and Services secure and preventing fraud and misuseOur legitimate interest in protecting our customers and our business
Establishing, exercising or defending legal claimsOur legitimate interest
Complying with other legal obligations, such as lawful requests from authoritiesLegal obligation

If we ever introduce optional analytics or similar technologies, we will rely on your consent where the law requires it, and you can withdraw that consent at any time.

4. Family profiles

An account holder can administer separate filer profiles for a spouse and children. In that case the account holder provides those family members’ information, and confirms under our Terms that they are authorised to do so.

  • Each family member’s information is used only to prepare that person’s FBAR and keep their records.
  • A joint account shared by family members is stored once and linked to each relevant profile, rather than copied.
  • A child’s information is administered by a parent or guardian. Family members can exercise their own privacy rights by contacting us (see section 10).

5. Automated extraction and human review

When you upload a document, account details may be extracted from it automatically. Extracted information is presented to you to confirm or correct; it is not used for your FBAR until you have reviewed it. FBAR Guard does not make decisions about you that have legal or similarly significant effects based solely on automated processing.

Some cases are also reviewed by a person, for example to check quality, resolve an exception or answer a support request. That person may see the information and documents involved. Access is limited to people who need it for that purpose and who are bound by confidentiality.

6. Who receives information

We share personal information only where needed for the purposes above:

  • Service providers who process information for us under our instructions, including website hosting and delivery (Cloudflare), payment processing (Stripe), email delivery, and secure hosting, storage and processing of the Services.
  • Professional advisers, such as our accountant or lawyers, where needed for their work for us.
  • Authorities, where the law requires us to provide information.

We do not sell personal information, and we do not share it for advertising. FBAR Guard does not send your FBAR to FinCEN or the IRS: you submit it yourself.

7. International transfers

Some service providers may process information outside the European Economic Area, for example in the United States. Where that happens, we use a transfer mechanism recognised under EU data-protection law, such as an adequacy decision of the European Commission or the European Commission’s standard contractual clauses. You can ask us for more information about the safeguards used.

8. How long we keep information

We keep information only as long as we need it, and we treat different kinds of information differently.

During a reporting year and after it ends

Information for a reporting year continues to be processed after 31 December while that year’s FBAR is prepared, reviewed and filed.

While your Annual Plan is active

Supported FBAR records from the reporting years your plan has covered can remain available to you as part of the ongoing paid recordkeeping service, during the recordkeeping period that applies to FBAR filers. These are the structured filing and account information you confirmed, annual maximum and calculation information, and the prepared FBAR with its filing confirmation where available.

Uploaded source documents

Statements and exports you upload so that information can be extracted or reviewed are not automatically kept for five years. They may be deleted earlier, once their purpose is complete, unless the Service specifically keeps them, you choose an available option to keep them, or another lawful basis requires us to keep them. The recordkeeping period that applies to FBAR filers is not a retention period for every document you upload.

One-time prior-year purchases

Buying a one-time service for an earlier reporting year does not include five years of hosted storage.

When your subscription ends

  • Your FBAR records remain available for 90 days so that you can download them.
  • After those 90 days, hosted access to your account can end, and we delete your information unless another lawful basis applies to particular information.

Information we keep for other reasons

Limited information may be kept after your subscription ends where we need it for accounting and tax records, security, fraud prevention, disputes and legal claims, or other legal obligations. We keep it only for as long as that purpose requires.

Your own records

You remain responsible for keeping the FBAR records the law requires you to keep. Download your records before hosted access ends.

9. Security

We protect personal information with technical and organisational measures appropriate to the risk, including encrypted connections, access limited to people who need it, and keeping card details with our payment provider rather than storing them ourselves.

Please do not send bank statements, FBARs or identification numbers by ordinary email. Upload documents through your account.

10. Your rights

Under data-protection law, you have the right to:

  • access the personal information we hold about you;
  • have inaccurate information corrected;
  • have information erased, where the law allows;
  • restrict our use of information, or object to processing based on our legitimate interests;
  • receive information you provided in a portable format; and
  • withdraw consent at any time, where we rely on consent.

To use these rights, email privacy@fbarguard.com. We may need to confirm your identity first. You can also complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or to the data-protection authority where you live or work.

11. Children

Accounts are for adults. A child’s filer profile is created and administered by a parent or guardian, and the child’s information is used only to prepare that child’s FBAR and keep their records. A parent or guardian can exercise the child’s privacy rights by contacting us.

12. Cookies and analytics

This website does not currently use cookies or analytics. FBAR, account, document and taxpayer-identification information is never sent to analytics tools. The Cookie Policy has the details.

13. Changes to this notice

We update this notice when the way we handle personal information changes. The current version is always on this page with the date it was last updated.