Draft generated for CTRL + Ledger. Review by qualified Canadian/Ontario legal counsel is recommended before production use. This document does not constitute legal advice and does not guarantee legal compliance or eliminate liability.
Effective date: [EFFECTIVE DATE] Business: [LEGAL BUSINESS NAME] ([ONTARIO CORPORATION NUMBER]) Address: [BUSINESS ADDRESS]
This Privacy Policy describes how [LEGAL BUSINESS NAME] ("CTRL + Ledger", "we") collects, uses, and protects personal information in connection with our website and services. We are committed to handling personal information in accordance with applicable Canadian privacy law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) where applicable.
1. Privacy accountability
CTRL + Ledger has appointed a Privacy Officer responsible for compliance with this policy and applicable privacy law. Privacy Officer contact: [PRIVACY EMAIL]
2. Information we may collect
Depending on the services you use, we may collect: name; company; title; email; telephone; billing information; account credentials; IP address; authentication information; device/browser information; website usage; client communications; accounting records; invoices; transactions; vendor information; customer information; bank/accounting information; financial reports; uploaded files; QuickBooks information; and business KPIs. We only collect categories of information that are reasonably necessary for the purposes identified below.
3. Purposes of collection
We collect personal information to: provide services; create and administer accounts; authenticate users; perform bookkeeping; prepare dashboards; generate reports; provide customer support; invoice and collect payment; prevent fraud; maintain security; improve the service; comply with legal obligations; and operate authorized integrations.
4. Consent
By providing information and using the Services, you consent to the collection, use, and disclosure described in this policy. Where consent is required and you wish to withdraw it, you may contact the Privacy Officer. Withdrawal may limit our ability to provide certain services where the information is reasonably necessary.
5. Limited collection
We seek to collect only information reasonably necessary for the stated purposes.
6. Use and disclosure
We use personal information for the purposes identified above. We may share information with service providers who act on our behalf under appropriate safeguards and only to provide the Services. We do not sell personal information.
7. Service providers (subprocessors)
Categories of service providers we may use include: cloud hosting; databases; authentication; accounting integrations; AI systems; email; analytics; payments; CRM; and customer support. The current subprocessor register is maintained by CTRL + Ledger and disclosed in the Data Processing & Subprocessor Disclosure.
8. International processing
Information may be processed or stored outside your province or outside Canada. Where this occurs, the information may be subject to the laws of the jurisdiction where it is processed. We do not represent that all data remains in Canada unless this is technically confirmed.
9. Security
We use reasonable administrative, organizational, and technical safeguards to protect personal information. No method of electronic storage or transmission can guarantee absolute security, and we do not represent that our systems are impossible to breach.
10. Retention
We retain personal information only as long as reasonably required for the identified purposes and to meet applicable legal and business obligations. Retention periods are determined based on the nature of the information and the purpose.
11. Access and correction
Individuals may request access to or correction of their personal information by contacting the Privacy Officer. We will respond in accordance with applicable law.
12. Privacy complaints
Complaints may be directed to the Privacy Officer at [PRIVACY EMAIL]. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.
13. Cookies
For information about cookies, see our Cookie Policy.
14. Changes
We may update this policy with a new effective date. Material changes will be communicated where required.
Contact
Privacy Officer: [PRIVACY EMAIL] Legal inquiries: [LEGAL EMAIL]