Privacy Policy

Sinclair Accounting Inc. ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at sinclairaccounting.com (the "Website") or use our services.

This Privacy Policy complies with Quebec's Act respecting the protection of personal information in the private sector (Law 25) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

Privacy Officer: Terry Arvanitis Address: 5876 Chemin Upper Lachine, Montréal, QC Phone: 514-856-2552 Email: privacy@sinclairaccounting.com

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact our Privacy Officer using the information above.

We collect the following types of personal information:

Contact Information: • Name • Email address • Phone number • Mailing address

Professional Information: • Business name and details • Tax identification numbers • Financial information (when providing accounting services) • Employment information

Website Usage Information: • IP address • Browser type and version • Pages visited and time spent • Referral sources • Device information

Communication Records: • Records of your communications with us • Meeting notes and correspondence

We collect personal information through:

• Direct collection when you contact us via our website form, email, or phone • When you engage our accounting services • Through cookies and similar tracking technologies on our website • From public records when necessary for our accounting services • From third parties (with your consent) such as banks or other financial institutions

We use your personal information for:

• Providing accounting and bookkeeping services • Responding to your inquiries and requests • Communicating with you about our services • Website functionality and improvement • Legal and regulatory compliance • Fraud prevention and security • Marketing communications (with your consent)

We obtain your explicit consent before using your personal information for purposes not listed above.

We may disclose your personal information to:

• Government agencies (CRA, Revenu Québec) as required by law • Professional service providers (lawyers, IT support) under confidentiality agreements • Cloud service providers for data storage and processing • Third-party payment processors • Law enforcement when legally required

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

We obtain your explicit consent before collecting, using, or disclosing your personal information. Your consent may be:

• Express (clearly stated) • Implied (through your actions) • Opt-in for sensitive information • Opt-out for certain communications

You may withdraw your consent at any time, subject to legal or contractual restrictions.

Our website uses cookies and similar technologies:

Essential Cookies: Required for website functionality and security Analytics Cookies: To understand website usage and improve performance Google reCAPTCHA: To prevent spam and abuse (subject to Google's Privacy Policy)

You can control cookies through your browser settings. However, disabling cookies may affect website functionality.

We retain your personal information for:

• As long as you are our client • 7 years after our service relationship ends (as required by accounting regulations) • As required by applicable laws and regulations • Until you request deletion (where legally permissible)

We securely destroy or anonymize personal information when it is no longer needed.

Under Quebec Law 25 and PIPEDA, you have the right to:

• Access your personal information • Request correction of inaccurate information • Request deletion of your personal information (right to be forgotten) • Data portability (receive your data in a structured format) • Object to automated decision-making • Withdraw consent • File a complaint with privacy authorities

To exercise these rights, contact our Privacy Officer.

We implement appropriate technical and organizational measures to protect your personal information:

• Encryption of data in transit and at rest • Access controls and authentication • Regular security audits and updates • Employee training on privacy protection • Secure disposal of information • Incident response procedures

Despite these measures, no method of transmission over the internet is 100% secure.

Some of our service providers may store data outside Quebec or Canada. When we transfer your personal information internationally, we:

• Conduct privacy impact assessments • Ensure adequate protection through contracts • Obtain your consent when required • Comply with applicable data transfer regulations

We will inform you of any international transfers that may affect your personal information.

We do not knowingly collect personal information from individuals under 14 years of age without parental consent. If you are between 14-18 years old, we may collect your information with either your consent or your parent's/guardian's consent.

If we become aware that we have collected personal information from a child under 14 without parental consent, we will take steps to delete such information.

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting a notice on our website • Sending you an email notification • Other appropriate means

Changes become effective 30 days after notice is provided.

If you have concerns about our privacy practices, please contact our Privacy Officer first. If you are not satisfied with our response, you may file a complaint with:

Commission d'accès à l'information du Québec (CAI) Website: cai.gouv.qc.ca Phone: 1-888-528-7741

Office of the Privacy Commissioner of Canada Website: priv.gc.ca Phone: 1-800-282-1376