Privacy Policy
Last updated: March 16, 2026
1. Introduction
Dis Optimus Capital LLC (“Company,” “we,” “us,” or “our”) operates the Act 60 Review service (“Service”). This Privacy Policy describes how we collect, use, store, and protect your personal information when you use our Service. We are committed to protecting the privacy and security of the sensitive financial information you entrust to us.
2. Information We Collect
Information you provide directly:
- Contact information (name, email address)
- Tax return documents (Planilla/Form 482, Form 1040, schedules)
- Supporting tax documents (Form 8938, FBAR filings, Act 60 decree)
- Transfer pricing documentation
- Hacienda correspondence
- Payment information (processed by Stripe; we do not store card numbers)
Information collected automatically:
- IP address and approximate geographic location
- Browser type and operating system
- Pages viewed and time spent on the Service
- Referring URL
3. How We Use Your Information
- To perform the AI-powered compliance analysis of your tax documents
- To facilitate CPA review of flagged findings
- To generate and deliver your compliance report
- To process your payment
- To communicate with you about your review
- To improve the accuracy and functionality of the Service
- To comply with legal obligations
4. Data Security
We implement industry-standard security measures to protect your information:
- Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
- Isolated processing: Tax documents are processed in isolated, ephemeral compute environments
- Access controls: Strict role-based access; only authorized CPA reviewers and essential personnel can access your documents
- SOC 2 compliance: Our infrastructure is SOC 2 Type II compliant
- No AI training: Your tax documents are never used to train AI models
5. Data Retention and Deletion
Uploaded tax documents and associated analysis data are permanently deleted thirty (30) days after your review is complete. Your compliance report is available for download during this period. After deletion, no copies of your tax documents are retained on our systems. Account information (name, email, purchase history) is retained for as long as your account is active or as needed to comply with legal and tax obligations.
6. Information Sharing
We do not sell, rent, or trade your personal information. We share information only with:
- CPA reviewers: Licensed Puerto Rico CPAs who verify AI-generated findings as part of the Service
- Payment processor: Stripe, Inc. processes your payment (subject to Stripe's Privacy Policy)
- Legal compliance: When required by law, subpoena, court order, or government request
- Business transfer: In connection with a merger, acquisition, or sale of assets, with prior notice to you
7. Your Rights
You have the right to:
- Request access to your personal information
- Request correction of inaccurate information
- Request deletion of your personal information
- Request a copy of your data in a portable format
- Opt out of marketing communications
To exercise any of these rights, contact us at support@act60review.com. We will respond to your request within thirty (30) days.
8. Cookies
We use essential cookies required for the Service to function (session management, security). We do not use advertising or tracking cookies. Analytics data is collected in aggregate and cannot be used to identify individual users.
9. Children's Privacy
The Service is not intended for individuals under 18 years of age. We do not knowingly collect information from children under 18.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. We encourage you to review this page periodically.
11. Contact
For privacy-related questions or to exercise your data rights:
Dis Optimus Capital LLC
San Juan, Puerto Rico
support@act60review.com