Privacy Policy

1. Scope and accountability

Two Ones Consulting Inc. ("Two Ones Consulting," "we," "us," or "our") is committed to protecting and safeguarding the privacy of your personal information. This policy explains how we collect, use, disclose, retain, and safeguard personal information in connection with our websites, applications, products, services, business relationships, prospective and current clients, client personnel, suppliers, service providers, referral sources, business partners, and other individuals who interact with us.

Information that is aggregated and/or anonymized and cannot be associated with an identifiable individual is not considered personal information.

This policy is intended to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and its regulations ("PIPEDA"), Canada's anti-spam legislation ("CASL"), as well as applicable provincial privacy laws and regulations.

In addition to being subject to these laws, we are bound by the confidentiality rules established by the professional orders and institutes of chartered accountants and chartered business valuators.

We have designated a Privacy Officer to oversee our privacy practices, respond to access or correction requests, and address questions or complaints. Contact details are provided at the end of this policy.

2. Information we collect

The types of personal information we collect depend on several factors, such as your relationship with us, the type of products or services you request or use, applicable legal and regulatory requirements, and how you communicate with us. Personal information collected may include:

• identification and contact details, such as your name, email, telephone number, company, and role;
• inquiry and relationship information, including service interests, communications, meeting notes, referrals, and preferences;
• business and professional information that you or your organization provides in the course of our work, such as financial and operational records, which may include information relating to owners, employees, customers, suppliers, compensation, payroll, banking, tax, transactions, forecasts, and business performance;
• billing, invoice, tax, payment-status, and transaction information;
• technical and usage information described below; and
• any other information you provide.

We collect information directly from you, from organizations you represent, from clients who authorize us to receive it, through referrals and existing business relationships, and from other sources permitted by law. We will not be liable for any loss resulting from inaccurate, false, imperfect, or incomplete personal information provided by you or anyone acting on your behalf.

Please do not provide personal information that is not reasonably needed for your inquiry or our engagement.

3. Information collected through online technologies

We may collect certain information electronically when you interact with our websites, applications, email, social media accounts, or online advertising, including through third-party technologies. These technologies may include cookies, log files, web beacons, pixels, and analytics engines that retrieve information about use of our websites, applications, or online services.

This information may include an IP address, browser type, operating system, referring and exit pages, page views, links selected, geolocation, website performance data, and identifiers associated with cookies or similar technologies. Whenever possible, we use your information in aggregate and/or anonymized form.

4. Social networks

We may collect personal information when you interact with us through our social media pages and accounts, such as LinkedIn, Facebook, Instagram, or X. This may include information the relevant platform permits us to receive about followers, subscribers, or other users, as well as messages, comments, reactions, profile information, and content you upload or make available on our pages.

Social media platforms independently determine how they collect, use, and disclose information. Your use of those services is also governed by their privacy policies and account settings.

5. How we use personal information

We may use the personal information you submit to provide products or services, manage our operations, carry out marketing activities, conduct research and analysis, or otherwise to the extent permitted or required by law, such as to:

• respond to inquiries, requests for information, and manage prospective-client relationships;
• provide consulting, advisory, valuation, financial, systems, professional, and related products or services;
• administer contracts, accounts, invoices, payments, records, and business operations;
• provide relevant updates, insights, or marketing communications as permitted by law;
• authenticate interactions, prevent fraud or misuse, maintain security, and troubleshoot technical issues;
• meet legal, tax, accounting, regulatory, insurance, and dispute-resolution requirements;
• improve and manage our services, products, and activities, or develop new ones;
• measure the effectiveness of our services, activities, communications, and marketing; and
• understand how visitors interact with our websites or applications and confirm that they are operating as expected.

6. Consent and marketing communications

Consent may be express or implied and may be provided by an authorized representative. We generally obtain your consent before collecting your personal information and, in all cases, before it is used or disclosed for any purpose. You may give us your consent in writing or electronically. You may also consent to the collection, use and disclosure of your personal information by providing it to us in a clearly intentional manner, such as by accessing our websites or apps, using our services, or submitting an information request. We may also rely on your implied consent to collect, use and disclose your personal information where implied consent is permitted by applicable legislation.

We may send commercial electronic messages where you have consented or where another legal basis permits us to do so. You may unsubscribe using the mechanism in a message or by contacting us. Withdrawing consent does not affect prior lawful processing and may limit our ability to provide a requested service.

7. Disclosure of information

We do not exchange or sell personal information. With your express or implied consent, we may disclose your personal information to third parties, only as described in this policy and as reasonably necessary, including to:

• independent consultants, subcontractors, implementation partners, service providers, referral partners, lawyers, accountants, insurers, and other professional advisers supporting our work, our operations, or as required in the course of their duties to us;
• clients and third parties you authorize us to work with; and
• government, regulatory, judicial, law-enforcement, or other parties where permitted or required by law, or where necessary to protect rights, safety, security, or property.

You must inform us immediately if you become aware that your personal information has been provided to us by another person without your consent or if you have not obtained consent before providing us with another person's personal information. Requests should be submitted in writing to the contact information provided below.

8. Data hosting and transfers outside Canada

Personal information provided to us may be processed or stored on servers in Canada and outside Canada. We may also use service providers located in other countries. Information stored in cloud environments may be distributed across multiple servers and locations.

We take reasonable steps designed to protect information handled by service providers, including assessing providers and using contractual, organizational, and technical safeguards where appropriate. However, information processed outside Canada is subject to the laws of the jurisdiction where it is held and may be accessible to courts, governments, law-enforcement agencies, or regulatory authorities in accordance with those laws.

9. Retention and safeguards

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, to provide services, maintain appropriate business and professional records, resolve disputes, enforce agreements, and meet legal, tax, accounting, insurance, and security requirements. Retention periods vary according to the nature of the information and the relevant relationship.

We use physical, administrative, contractual, and technical safeguards appropriate to the sensitivity and volume of information, its format and location, and the risks associated with its handling. No system can be guaranteed to be completely secure. If a privacy incident occurs, we will investigate and provide notifications where required by law.

10. Your privacy rights

Subject to applicable law, you may request access to personal information we hold about you, ask us to correct inaccurate or incomplete information, or withdraw consent to certain uses. You may also raise a concern about our privacy practices or request information about our use of service providers outside Canada.

Before granting you access to personal information on file, used or disclosed, we may ask you to provide us with sufficient proof of identity for that specific purpose only. Access may be limited where permitted or required by law.

We reserve the right to deny access for any reason permitted under applicable law. If we deny access to or correction of personal information, we will provide you with written reasons for such denial within thirty (30) days of your request.

To exercise your right of access, please submit a request in writing using the contact information provided below.

11. Third-party websites and services

Our websites, applications, communications, and social media pages may contain links to external websites or services. Those third parties are not governed by this policy. Information collected by a third party is subject to that third party's privacy policy and practices. We encourage you to review the applicable privacy policy before providing personal information.

Our products, services, applications, websites, communications, and social media pages are designed and intended for organizations and adults. We do not knowingly collect or maintain personal information provided by children or anyone under the age of 13 (collectively, "minor"). If we learn that we have unknowingly collected personal information about a minor without the consent of their parent or guardian, we will delete that information from our records.

12. Updates and contact

We may update this policy to reflect changes in our practices, services, technology, or legal obligations. The effective date at the top of this page indicates when the policy was last updated. Material changes will be communicated where appropriate.