Privacy Policy

1. Scope of This Policy

TLW Professional Services Inc. ("TLW," "we," "us") provides accounting, tax, insurance, business consulting, and financial, investment & retirement planning services to Canadian individuals and businesses. This policy explains what personal information we collect, how we use and share it, and the choices available to you, in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

This policy covers personal information we collect through:

• This public website, including our consultation and contact forms
• Our services once you engage us as a client — including documents you send us, our secure Client Portal, and the notification channels (email, SMS, or phone) you've consented to

If you are a website visitor who hasn't engaged our services, most of this policy won't apply to you — Section 2's "Website visitors" subsection describes what we collect from you specifically.

2. Information We Collect

Website visitors

When you browse this website or submit a form, we may collect:

• Contact details you provide — name, email, phone number, and message content
• The service line you're inquiring about
• Basic technical information such as browser type, device type, and pages visited

Clients & Client Portal users

Once you engage us for a service, we collect the additional personal information necessary to deliver it, verify your identity, and meet our regulatory obligations as an accounting and advisory firm. This can include:

• Identity & contact information — full name, date of birth, mailing address, email, phone, and your preferred contact channel
• Government identifiers — your Social Insurance Number (SIN), for individuals, or your CRA Business Number (BN), for corporations, collected only where needed to prepare filings or verify identity. These are encrypted before they're stored — see Section 8
• Financial & tax documents you provide — bank statements, T4s and other tax slips, pay stubs, notices of assessment, financial statements, investment account statements, and insurance or mortgage application materials relevant to the service you've engaged
• Government-issued ID, where identity verification is required for a specific engagement
• Billing information — invoices and payment status. We don't store full payment card numbers ourselves; payment processing is handled by our payment processor
• Communications — emails, calls, SMS messages, portal messages, meeting notes, and your consent and communication preferences

3. How We Use Your Information

We use your information to:

• Respond to consultation requests and inquiries
• Deliver the bookkeeping, tax, insurance, business consulting, or financial planning services you've engaged us for, including preparing and filing returns with the CRA and other authorities on your behalf where you've authorized us to do so
• Verify your identity where required
• Schedule and manage appointments, including syncing appointment times with a calendar you've chosen to connect (e.g., Google Calendar) — only if you've opted in to that integration
• Process payments and manage invoicing
• Send documents to you for review and electronic signature
• Communicate with you about your file, through the channel(s) you've consented to
• Meet our own recordkeeping, audit, and professional/regulatory obligations
• Improve our services and this website

We do not sell your personal information.

4. AI-Assisted Document Processing

To speed up data entry from documents you provide, some documents (for example, a bank statement or a T4) may be routed through an AI-assisted extraction tool that reads the document and pulls out structured data for our team to review. We've built this with the following controls:

• Only the document content needed to extract data — the document itself, and your name for matching purposes — is sent to the AI provider
• Your full SIN, Business Number, and financial account numbers are never sent. Our systems restrict what's shared to, at most, the last 4 digits of these identifiers
• Every AI-assisted extraction is reviewed, and confirmed, corrected, or rejected, by a member of our team before it's applied to your file — extracted data is never applied automatically without human review
• We use AI providers that commit not to use your data to train their models
• Every AI interaction is logged for audit purposes

AI-assisted extraction is a data-entry convenience, not a substitute for professional judgment — it does not itself constitute accounting, tax, insurance, or financial advice, and every output is checked by a qualified team member before we rely on it.

Because our AI provider's infrastructure may be located outside Canada, using this feature involves a cross-border transfer of the limited document data described above. We select providers under contractual data-protection and no-training commitments, consistent with our obligations under Canadian privacy law.

5. Electronic Signatures

Where a document needs your signature, we send it to you through our e-signature system, which runs on infrastructure we control rather than a third-party signing service. We retain the signed document along with the signature metadata (name, timestamp, and IP address) as part of your record.

6. Cookies & Analytics

This website may use cookies and similar technologies to remember your preferences and to understand, in aggregate, how visitors use our site so we can improve it. You can control or disable cookies through your browser settings; doing so may affect how some parts of the site function.

7. How We Share Your Information

We don't sell your personal information. We share it only with service providers who help us operate our website and deliver our services (each bound by confidentiality and data-protection terms), and in the limited circumstances listed below.

We may also disclose personal information:

• As required by law, or in response to a valid request from the CRA or another regulator or authority
• To professional bodies or our insurers, where required in connection with our practice
• In connection with a merger, sale, or other business transaction involving TLW
• With your consent

8. Data Security

We take the following technical and organizational measures to protect your personal information:

• Your SIN and Business Number are encrypted at rest (AES-256-GCM) — not stored as plain text in our database
• Data is encrypted in transit using TLS
• Access to client records in the Client Portal and our internal systems is role-based and permissioned to staff who need it to serve you
• System activity, including AI interactions and document access, is logged for audit purposes

No system is completely secure. If you have concerns about the security of your information, please contact us using the details in Section 13.

9. Data Retention

How long we keep your information depends on what it is and why we collected it:

When a retention period ends, the record is flagged for review before it's archived or deleted — not deleted automatically without review.

10. Your Rights & Choices

Under PIPEDA and applicable provincial privacy law, you have the right to access, correct, or request deletion of your personal information, and to withdraw consent at any time, subject to legal or contractual restrictions.

Where you're a client, we track your consent separately for each of the following, so you can withdraw one without affecting the others:

• General data processing needed to deliver your engaged services
• AI-assisted document processing (Section 4)
• Marketing communications
• Each notification channel — email, SMS, and WhatsApp — individually

To make a request or withdraw consent, contact us using the details in Section 13. Some information must be retained regardless of a deletion request where we have a legal or regulatory obligation to keep it — for example, CRA recordkeeping requirements described in Section 9.

11. Children's Privacy

This website and our services are not directed at children, and we do not knowingly collect personal information from anyone under the age of majority in their province without the involvement of a parent, guardian, or legal representative.

12. Changes to This Policy

We may update this policy from time to time. The "last updated" date above reflects the most recent revision. Where a change materially affects how we use your information as a client, we'll seek your renewed consent where required.

13. Contact Us

Questions about this policy, or requests relating to your personal information, can be directed to us through our Contact page or by phone at +1 (403) 477-1793.