PRIVACY POLICY

2352418 Alberta Ltd., operating as Kaa-Services

Last updated: October 18, 2026

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1. WHO WE ARE

This website (www.kaa-services.com) is operated by 2352418 Alberta Ltd., operating as Kaa-Services ("Kaa-Services", "we", "us", "our"), a corporation registered in Alberta, Canada, based in Calgary, Alberta.

We are an accounting firm providing bookkeeping, tax preparation, payroll management, business planning, and business advisory services, delivered 100% online to clients across Alberta and Canada.

Protecting your personal information is essential to our business and to the trust you place in us. This policy explains what we collect, why, how we protect it, and your rights.

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2. YOUR PRIVACY OFFICER

Our privacy officer is responsible for our privacy practices, handling privacy inquiries and complaints, and managing our privacy breach process.

Rajesh Sabharwal, Privacy Officer Phone: (587) 772-1643 Email: Talk2us@kaa-services.com

Contact our privacy officer with any question about how we handle your personal information. We will acknowledge your inquiry promptly and keep a record of it.

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3. WHAT PERSONAL INFORMATION WE COLLECT

Personal information is any information about an identifiable individual. Because we are an accounting firm, the information entrusted to us is highly sensitive. It may include:

Identity and contact information: your name, home or business address, telephone number, email address, and date of birth.

Government and tax identifiers: your Social Insurance Number (SIN) and business number, where needed to prepare tax filings and payroll.

Financial information: income records, receipts, invoices, bank statements, payroll records, and tax returns and supporting documents.

Website visitor information: when you visit our website, we may collect basic technical information such as your IP address, browser type, and pages visited, through cookies and website analytics.

We do not collect payment card information through this website.

We limit the amount and type of information we collect to only what is necessary for the purposes described in this policy, and we take reasonable steps to keep it accurate and up to date.

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4. HOW WE COLLECT IT

We collect personal information directly from you — through our website contact form, by email, during client onboarding, and from the documents and records you provide through our online systems. We collect it by fair and lawful means, and only with your consent except where otherwise allowed by law.

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5. WHY WE USE YOUR INFORMATION

We use your personal information for the following purposes:

To respond to your inquiries and provide quotes for our services.

To deliver the services you engage us for: bookkeeping, tax preparation, payroll management, business planning, and business advisory.

To meet our legal and regulatory obligations, including Canada Revenue Agency record-keeping and tax filing requirements.

To improve our website and services.

We do not use your personal information for any purpose other than the ones described here without first obtaining your consent, unless such use is required or allowed by law.

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6. YOUR CONSENT

Your consent is valid only if it is reasonable to expect that you understand the nature, purpose, and consequences of the collection, use, or disclosure you are consenting to.

We obtain your consent at the beginning of our relationship — for example, when you submit our contact form or sign an engagement agreement — and we explain the purposes at that time. Where it is reasonable in the circumstances (for example, when you email us a question), your consent may be implied.

You may withdraw your consent at any time by contacting our privacy officer, subject to legal or contractual restrictions and reasonable notice. Please note that some information cannot be deleted on request — for example, tax and accounting records must be retained for at least 6 years as required by the Canada Revenue Agency.

If we wish to use your information for a new purpose, we will explain the new purpose and obtain your consent before proceeding.

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7. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to anyone.

We share it only as follows:

Service providers: we use trusted providers to operate our business — for example, our website host (Wix), our accounting software (such as QuickBooks Online), and IT support. They receive only the information they need, are bound by confidentiality obligations, and may only use it for the services they provide to us. Some providers store information on servers outside of Canada; where that is the case, your information may be subject to the laws of that country, and we will tell you so.

Legal requirements: we will disclose information where required or allowed by law — for example, to the Canada Revenue Agency, a court order, or law enforcement.

Business transactions: if our practice is ever sold, merged, or reorganized, client information may be transferred as part of the transaction under strict confidentiality, solely for purposes related to the transaction, and affected clients will be notified.

We never provide client names or information to third parties so they can market their services, unless you have been informed and have consented.

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8. HOW WE PROTECT YOUR INFORMATION

We use technological, physical, and organizational safeguards appropriate to the sensitivity of the information — accounting records demand the highest level of care.

Technological safeguards

Sensitive data is encrypted both when stored and when transmitted. Antivirus software and firewalls are installed and kept up to date on all business systems. Strong passwords are required (minimum eight characters, using capitals, lowercase, numbers, and symbols) and are never shared. Computers are locked or shut down when unattended. Emails and files containing sensitive personal information are password-protected or encrypted before sending.

Physical safeguards

Paper files containing personal information are kept in locked cabinets and never left unattended. Laptops and mobile devices are locked away when not in use and never left visible in vehicles. Client files are removed from the office only when absolutely necessary to serve you, and their removal is tracked.

Organizational safeguards

Access to client information is granted strictly on a need-to-know basis. Everyone who handles client information is bound by confidentiality obligations. Client matters are never discussed in public places. Before disclosing personal information by phone, we authenticate the caller to confirm they are entitled to receive it.

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9. IF A PRIVACY BREACH HAPPENS

A privacy breach is any unauthorized access to, unauthorized disclosure of, or loss of personal information — for example, a hacked system, a lost device containing client files, or an email with client information sent to the wrong recipient. A breach can be intentional, accidental, or the result of criminal activity.

If a breach occurs, we act immediately:

Containment: we work to stop the breach and recover the information — for example, recalling a misdirected email, changing passwords, engaging IT support, and contacting police where criminal activity is involved.

Assessment: we assess whether the breach creates a real risk of significant harm to you, considering how sensitive the information is, how it was obtained, whether it has been recovered, and how many people are affected.

Notification: where the law requires it, we will notify you and the Information and Privacy Commissioner of Alberta (for Alberta residents) or the Office of the Privacy Commissioner of Canada (for residents elsewhere) without unreasonable delay. Our notice to you will describe what happened, what information was involved, what we have done about it, what you can do to protect yourself, and how to reach us for more information.

Documentation and improvement: we document every breach, keep secure records, and review our safeguards and procedures to prevent it from happening again.

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10. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only as long as necessary to fulfill the purposes described in this policy, or as required or allowed by law.

Tax and accounting records are retained for at least 6 years, as required by the Canada Revenue Agency.

When information is no longer needed, we securely destroy it: paper materials are shredded (never recycled), and electronic data is securely wiped so it cannot be retrieved.

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11. YOUR RIGHTS — ACCESS AND CORRECTION

You have the right to request access to the personal information we hold about you, and to challenge its accuracy and completeness. If information is inaccurate or incomplete, we will correct or amend it; where we do not agree, we will note your disagreement on the file.

To make a request, contact our privacy officer at Talk2us@kaa-services.com or (587) 772-1643.

We will respond as quickly as possible and no later than 45 days after receiving your request if you are an Alberta resident, or 30 days if you reside elsewhere in Canada.

In limited circumstances we may need to refuse access — for example, where it would reveal another person's personal information — and if so, we will explain why in writing.

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12. WHICH LAW APPLIES

If you are a resident of Alberta, the collection, use, and disclosure of your personal information is governed by Alberta's Personal Information Protection Act (PIPA) and the federal laws of Canada applicable in Alberta. If you are resident outside of Alberta, it is governed by the federal Personal Information Protection and Electronic Documents Act (PIPEDA). Any dispute arising from this policy will be heard exclusively by the courts in Calgary, Alberta.

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13. COOKIES AND WEBSITE ANALYTICS

Our website uses cookies — small files stored on your device — to make the site work properly and to understand how visitors use it, including through website analytics. You can control cookies through your browser settings; disabling them may affect how the site functions.

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14. QUESTIONS AND COMPLAINTS

Start with our privacy officer — Rajesh Sabharwal, (587) 772-1643, Talk2us@kaa-services.com — who will acknowledge your concern promptly and work to resolve it.

If you remain unsatisfied, you may complain to the Office of the Information and Privacy Commissioner of Alberta (if you are an Alberta resident) or to the Office of the Privacy Commissioner of Canada (if you reside elsewhere in Canada).

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