Privacy Policy

1. About This Policy

Boreal Numbers operates as an accounting and tax advisory firm serving small businesses in Manitoba, Canada. We are subject to Canada's federal Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, provincial privacy legislation.

This policy applies to information collected through our website at cariboucounts.online, through our client intake process, and through the ongoing delivery of our bookkeeping, tax preparation, and financial planning services.

2. Information We Collect

We collect personal information only when there is a clear reason to do so. The categories of information we may collect include:

• Contact details — name, email address, phone number, business address
• Business information — business name, business number (BN), industry type, annual revenue range
• Financial records — transaction data, bank statements, receipts, invoices, and related documents shared for bookkeeping or tax purposes
• Tax identification information — SIN, corporation number, GST/HST registration numbers as required for CRA filings
• Website usage data — pages visited, browser type, approximate geographic location via IP address (collected anonymously through analytics tools)
• Communication records — emails, meeting notes, and any correspondence related to our engagement

We collect information directly from you through our contact form, client onboarding documents, email correspondence, and document-sharing platforms. We do not purchase personal data from third parties.

3. Legal Basis for Processing

Under PIPEDA, we process your personal information based on:

• Consent — when you submit our contact form, engage our services, or agree to communications
• Contractual necessity — to fulfil the obligations described in our engagement agreement
• Legal obligation — when CRA or other regulatory requirements necessitate the retention or disclosure of certain records
• Legitimate interest — for internal record-keeping, service improvement, and security monitoring

4. How We Use Your Information

Personal information collected through our services is used to:

• Provide bookkeeping, tax preparation, and financial planning services as engaged
• Communicate with you about your file, upcoming deadlines, and required documentation
• Prepare and file tax returns with the Canada Revenue Agency on your behalf
• Maintain accurate financial records in compliance with CRA requirements
• Send occasional service-related updates (you may opt out at any time)
• Improve our internal processes and service quality
• Meet our legal and professional obligations as a CPA-affiliated practice

We do not use your personal information for automated decision-making or profiling. We do not sell or rent your data to third parties for marketing purposes.

5. Data Sharing and Third Parties

We share your information only when necessary and with appropriate safeguards in place. Parties who may receive your information include:

• Canada Revenue Agency (CRA) — for tax filings conducted on your behalf
• Manitoba provincial tax authorities — as required for provincial filings
• Cloud accounting software providers (such as QuickBooks Online or Xero) — for secure storage and access to bookkeeping records
• Secure document-sharing platforms — used for client file exchange
• Analytics services — anonymized website usage data only (no personal identifiers shared)

Where we engage third-party service providers, we confirm that appropriate data processing agreements are in place and that these providers maintain standards consistent with PIPEDA.

6. How Long We Keep Your Information

We retain personal and financial records for a minimum of seven years following the end of an engagement, in accordance with CRA requirements and CPA Canada professional standards. After this period, records are securely destroyed.

Website contact form submissions not resulting in an engagement are retained for up to 12 months before being deleted.

You may request earlier deletion of non-mandatory records; however, where legal or professional retention obligations apply, we are required to maintain those records for the specified period.

7. How We Protect Your Information

We take the security of your financial and personal information seriously. Our protective measures include:

• Encrypted data transmission (TLS/SSL) for all digital communications
• Secure, password-protected access to client files within cloud accounting platforms
• Multi-factor authentication required for staff access to client data
• Restricted access — only staff members working on your file can view your records
• Regular review of our data handling practices
• Staff training on privacy obligations and secure data handling

In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA.

8. Cookies and Website Tracking

Our website uses cookies to understand how visitors interact with our pages and to remember your preferences. We use the following categories:

• Essential cookies — required for the site to function correctly
• Analytics cookies — help us understand which pages are most useful (no personal identifiers)
• Preference cookies — remember your cookie consent choices

You can manage your cookie preferences at any time by visiting our Cookie Policy page, which includes functional controls for each category.

9. Your Privacy Rights

Under PIPEDA, you have the right to:

• Access — request a copy of the personal information we hold about you
• Correction — ask us to correct inaccurate or incomplete information
• Withdrawal of consent — withdraw consent for non-mandatory processing at any time
• Complaint — lodge a complaint with the Office of the Privacy Commissioner of Canada if you believe your rights have been affected
• Information about disclosures — ask which third parties have received your information

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

If you are unsatisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or by calling 1-800-282-1376.

10. External Links

Our website may contain links to third-party resources such as the Canada Revenue Agency website or accounting software platforms. Once you leave our site, this privacy policy no longer applies, and we encourage you to review the privacy policies of any external services you visit.

11. Minimum Age

Our services are intended for business owners and adults aged 18 and over. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently received information from a minor, please contact us so we can address it promptly.

12. Changes to This Policy

We may update this policy from time to time as our practices evolve or as legal requirements change. When we make meaningful changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

Continued use of our website or services after changes are posted constitutes acceptance of the revised policy.

13. Contact Information

For privacy-related questions, access requests, or concerns, please reach out to:

• Boreal Numbers
• 274 Portage Avenue, Winnipeg, MB R3C 0B9
• Email: [email protected]
• Phone: +1 (204) 857-3946