Draft -- not yet in effect. This document is pending legal review and still has details to fill in (shown in [brackets]).
Privacy Policy
Effective date: [not yet set] · Terms of Service
[PRODUCT NAME] is provided by [LEGAL ENTITY NAME] (“we”, “us”). This policy explains what personal information we handle, why, who we share it with and your choices. We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).
1. Two kinds of information, two roles
- Account information -- about the accounting practices and businesses that subscribe (“customers”) and the people on their teams. We decide how this is used and are responsible for it.
- Customer data -- what customers enter or import about their own business, their clients, and the employees of either: names, addresses, Social Insurance Numbers, dates of birth, pay, deductions, bank account details, tax forms and financial records. We process it only on the customer's behalf and on their instructions, to provide the service. The customer is responsible for having the authority and any consents needed to give it to us, and for answering requests from the people it's about.
2. What we collect
- Account details: name, email address and sign-in information (handled by Clerk).
- Organization details: business name, team members, their roles and access levels.
- Billing details: plan and payment status. Card numbers are entered with and held by Stripe; we never see or store them.
- Customer data, as described above.
- Messages you send us through Contact support, including your email address.
- Technical information: server logs with IP addresses and request details, and an audit trail of who changed what in the service.
- Email open tracking: pay stub emails contain a small image that records the first time the email is opened, so the employer or their bookkeeper can see whether an employee received their pay stub.
3. How we use it
- To run the service: calculate payroll, keep books, produce reports, slips and payment files.
- To send the emails your team asks the service to send.
- To bill for the service and to answer support requests.
- To keep the service secure, investigate problems and prevent misuse.
- To meet our legal obligations.
We do not sell personal information, and we do not use customer data for advertising or to build profiles.
4. Who we share it with
We use these service providers, each bound to protect the information and use it only to serve us:
| Provider | What for | Where |
|---|---|---|
| Render | Hosts the application and its database | United States (Oregon) |
| Clerk | Sign-in, user accounts and team invitations | United States |
| Stripe | Subscription billing; card payments on invoices for companies that connect their own Stripe account | United States and Canada |
| Resend | Delivers the emails the service sends (pay stubs, invitations, notices) | United States |
| Anthropic | Reads bank statements and bills you choose to scan with the AI import features -- only when used | United States |
| Telpay | Payroll and CRA remittance payments -- only for customers that choose to pay through Telpay | Canada |
When a customer uses the AI import features, the document is sent to Anthropic to read its transactions. Anthropic processes it under its commercial terms, which don't allow it to train its models on that content.
We also disclose information when the customer directs us to (for example, files they choose to send to the Canada Revenue Agency or their bank), or when the law requires it.
5. Storage outside Canada
Our database and servers are in the United States, and several providers above are based there. Information stored in another country is subject to that country's laws and may be accessible to its courts, law enforcement and national security authorities. Customers with clients or employees in Quebec should consider their own obligations for information communicated outside Quebec; we will provide the information they need to do so.
6. How we protect it
- All connections use encryption (HTTPS).
- Social Insurance Numbers and employee bank account numbers are also encrypted in the database, and shown masked.
- Each customer's data is kept separate by database-level controls, and team members only reach the companies and areas their access allows.
- Changes are recorded in an audit trail.
No system is perfectly secure, but we work to protect information in proportion to its sensitivity.
7. How long we keep it
We keep account information and customer data while the customer's account is open. Employers must generally keep payroll records for six years; that obligation is the customer's, and customers can export their data at any time. After an account closes we delete its customer data within 90 days, unless the law requires us to keep it longer. Copies in backups are removed as those backups expire.
8. Your choices and rights
- Team members and customers can ask to see or correct the personal information we hold about them, or ask questions about how it's handled, by writing to our Privacy Officer (below).
- If you are a client or employee of one of our customers, please contact that practice or employer first -- they control your information in the service. Employees with portal access can see and update some of their own details there. We will help our customers answer your request.
- You can withdraw consent to optional uses, subject to legal and contractual limits.
9. If something goes wrong
If a breach of security safeguards involving personal information creates a real risk of significant harm, we will notify affected customers without undue delay, report it to the Office of the Privacy Commissioner of Canada as the law requires, and help customers notify the people affected.
10. Cookies
We use only the cookies needed to sign you in and keep your session secure. We don't use advertising or analytics cookies.
11. Children
The service is for businesses and is not meant for anyone under 18 to use. Customers may enter information about employees who are minors, as part of customer data.
12. Changes to this policy
We will post any changes here with a new effective date, and tell customers by email or in the service before a significant change takes effect.
13. Contact us
Privacy Officer: [PRIVACY OFFICER NAME], [LEGAL ENTITY NAME], [MAILING ADDRESS] -- [PRIVACY EMAIL]
If you're not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada. See also our Terms of Service.