Privacy Policy

Norton McMullen LLP’s Privacy Policy

Effective - January 22, 2026

TABLE OF CONTENTS

1. General

2. Agreeing To The Terms Of Our Privacy Policy

3. Right to Withdraw Consent

4. What Personal Information Do We Collect?

5. Information Collection and Use

6. When Do We Share Your Personal Information

7. Your Rights

8. Security

9. Personal Information used by Third Party Websites

10. Artificial Intelligence

11. Age of Majority

12. Personal Information Retention and Data Deletion

13. Personal Information Outside Canada

14. Changes to the Privacy Policy

15. Limitation of Liability

16. Job Applicants

17. Governing law

18. Contact

1. General

At Norton McMullen LLP (“NMLLP”, “we”, “us”, or “our”) we take the privacy of our users very seriously. This privacy policy (“Privacy Policy”) describes our policies on the collection, use, and disclosure of personal information of individuals who engage with NMLPP for our support, services or otherwise, visit our website(s), including https://www.nmcpa.ca/ (“Website”), or contribute to NMLLP’s social media platforms.

The Website includes, but is not limited to, all other sites owned and operated by NMLLP that redirect to the Website, all subdomains provided through such other site or the Website, and all downloadable applications, features, functionality, content, or information that is made available or provided on the Website. The Website is made available to you for the purpose of providing you with access to information about NMLLP and our services. “Users” and “you” refer to anyone who visits our Website, uses our services, or communicates with us.

For the purposes of this Privacy Policy, “personal information” is any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information excludes business contact information.

This Privacy Policy applies to all personal information collected by NMLLP. It will notify you of the following:

(a) What personal information is collected from you, how it is used, and with whom it may be shared.

(b) What choices are available to you regarding the use of your personal information.

(d) How you can correct any inaccuracies in your personal information.

2. Agreeing To The Terms Of Our Privacy Policy

Before using the Website or any services available on or through the Website, or submitting any personal information to NMLLP, please review this Privacy Policy carefully and contact us if you have any questions. By visiting and making use of the Website and our services, you are in agreement with this Privacy Policy, meaning you expressly consent to the personal information handling practices in accordance with this Privacy Policy. You acknowledge and agree that such personal information may be transferred from your current location to the offices and servers of NMLLP and authorized third parties referred to herein. If you do not agree to this Privacy Policy, please do not access the Website or use our services, or otherwise provide personal information to NMLLP.

Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to NMLLP’s collection, use, and disclosure of personal information in accordance with this Privacy Policy.

3. Right to Withdraw Consent

Subject to certain legal and contractual limitations, you have the right to withdraw your consent from us processing your personal information. This may limit our ability to provide you with our products and services, act on your behalf or engage with you as you would like. To withdraw your consent to certain processing by NMLLP, you may declare to our designated Privacy Officer (contact information provided below) in writing, at any time, of your desire to withdraw consent. NMLLP will inform you of the implications of such withdrawal within thirty (30) days of your written request. Any withdrawal of consent will apply thereafter and not to information handling practices that have been previously undertaken based on prior consent. We may, however, collect, use or disclose Personal Information without your knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

4. What Personal Information Do We Collect?

The personal information we may collect or obtain includes, but is not limited to:

(a) Information Provided to Our Professionals: The provision of our accounting and financial services may require you to provide certain personal information about yourself, your spouse and/or your dependants, to our professionals, including in person, through our Website, by way of secure portal, by mail, by email, and from third parties whom you have authorized to disclose personal information to us. The personal information we may collect to provide our services may include: your full name, date of birth, SIN, driver’s license or passport number, home address, email, phone number, bank account information, investment details, tax slips, payroll records, employer name, income details, medical expense receipts, disability credit forms, business registration information, and tax account numbers.

(b) Transaction Information: When you engage us to provide you with our services, we collect information on your payment and transaction history, including details of commercial or other transactions, credit card details, bank account information, billing address, and payment or other information. Information may be collected through our client intake forms or engagement letters or directly to our professionals.

(c) Communication Information: We may collect personal information when you contact us with questions or concerns (such as for support purposes) and when you voluntarily respond to questionnaires, surveys, or requests for market research seeking your opinion and feedback. Providing communication information is optional to you. We collect the information you provide to us, including your name, email address, and phone number and our response to your communication requests.

(d) Client Portal: NMLLP maintains a client portal that allows our clients to share information with our financial and accounting professionals. When you use our client portal, we may collect profile information from you, including your username and password and other account credentials, and any additional information you upload to the portal.

(e) Social Media Information: We have pages on social media sites like LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal information will be collected by fair and lawful means. We will not take more personal information than we need, and you decide how and what you want to share.

5. Information Collection and Use

We only have access to/collect information that you voluntarily give us, including via email or other direct contact from you, or which you authorize another person to share. We will not sell or rent this information to anyone.

We may use your personal information for the following purposes:

(i) NMLLP provides various financial and accounting services to individuals, privately held businesses and not-for-profit organizations. Our services may include the preparation of financial statements, the preparation and filing of various types of government tax returns (including personal, trust, corporate, and charities returns), conducting consultations, providing assurance-type engagements, managing payroll, and preparing tax slips, such as T4 and T5 slips. We use the personal information we collect from you to fulfil our contractual obligations to you, maintain the client relationship and provide you with our services.

(ii) We use the personal information we collect from you to respond to your requests, communicate with you, and customize your use of our Website or services. This includes sending you marketing communications, including notifying you of special promotions, offers, and events via email and other means. We will not share your personal information with any third party outside of our organization without your knowledge and consent, other than as described in this Privacy Policy or as necessary to fulfill your request.

(iii) To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals and customers in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information collected online and offline, including information from third party sources. We may share anonymized data with third parties for business development purposes.

(iv) We may also use your personal information in other ways with consent or as permitted by applicable law.

By using the Website and/or our services, you agree that we are hereby licensed to collect, use, share, and store data collected through the Website or your use of our services for benchmarking, analytics, metrics, research, reporting, machine learning, and other business purposes.

Unless you ask us not to, we may contact you via email to specifically answer your requests or notify you of changes to this Privacy Policy.

6. When Do We Share Your Personal Information

There are some circumstances where we may share your personal information with a third party. For example:

(a) Government Organizations: We may share your personal information with certain government organizations, such as Canada Revenue Agency, in order to fulfil our engagement with you for the provision of financial, accounting or tax services.

(b) Legal Matters: We reserve the right to disclose personal information if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with legal process, enforce the terms of use for our Website or our engagement letters with clients, respond to claims, or to protect the rights, property or safety of NMLLP, our affiliates, our customers, service providers, or the public.

(c) Professional Advisors: We may share personal information with our affiliates or any business partners or agents acting on our behalf or with our financial, insurance, legal, or other advisors that provide professional services to us.

(d) Maintenance: Your personal information may be disclosed to a company or individual employed or engaged by us to perform functions on our behalf such as data processing or document retention. Any such disclosure of your personal information is made on a strictly confidential basis, and the information is to be used only for the purpose for which it was shared. We ensure that the company or individual adheres to this Privacy Policy.

(e) Business Matters: We may share, disclose or transfer personal information to a buyer, investor, new affiliate, or other successor in the event NMLLP or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of NMLLP or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).

(f) Regulatory Requirements: Subject to applicable regulations, we may disclose your personal information to a government agency, court, or law enforcement personnel.

In the instances described above, we may be required to share your personal information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.

7. Your Rights

Privacy legislation provides you with specific rights regarding your personal information. These may include:

(a) Right to Accuracy: You have the right to verify the accuracy and completeness of your personal information in our records to request that we correct information that you believe is inaccurate.

(b) Right to Access: You have the right to request access to your personal information, which enables you to receive a copy of the personal information we have collected from you. You may also ask us to provide you with a copy of the personal information you provided us in a commonly used and structured electronic format, or that we share such information with a third party designated by you.

(c) Right to Opt-Out: You have the right to opt-out of certain personal information handling practices, including the disclosure of personal information to third parties which is not reasonably necessary for providing the services you’ve requested or as otherwise required by law.

(d) Right to Make a Complaint: You have the right to make a complaint with the Privacy Commissioner.

(e) Other Privacy Rights: You have the right to receive information that identifies any third-party companies or individuals that we have shared your personal information with, as well as a description of the categories of personal information disclosed to that third party.

You may exercise your rights with NMLLP by contacting our Privacy Officer at the address below.

8. Security

We take precautions and implement safeguards designed to protect your personal information. Your use the Website our services at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. In addition, our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information. Some of our measures include:

(a) physical measures, such as, locking filing cabinets and restricting access to offices;

(b) organizational measures, such as, security passes, limiting access to personal information on a “need-to-know” basis, staff training and device management policies;

(c) technological measures including the use of firewalls, intrusion detection, passwords, encryption, multi-factor authentication, role-based access controls, audit logs and sensitivity labels; and

(d) procedural measures, such as, the shredding of sensitive personal information.

Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. In particular, email sent to or from us may not be secure. Therefore, despite our efforts, we cannot guarantee its absolute security. Consequently, you should take special care in deciding what information you provide to us. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Website or our services, or third party websites. We encourage all individuals to provide only the information they are comfortable with providing a third party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible.

In the event there has been a breach of our security safeguards which involve your personal information, including the unauthorized access, use or disclosure of your personal information, loss of your personal information, or other breach, and where there is a risk that significant harm will come to you as a result of that breach, NMLLP will notify you and, if required, the Privacy Commissioner.

NMLLP also maintains a secure client portal which you should use to upload sensitive financial information that may be required by NMLLP in the provision of accounting services.

WE DO NOT WARRANT OR REPRESENT THAT PERSONAL INFORMATION ABOUT YOU WILL BE PROTECTED AGAINST, LOSS, MISUSE, OR ALTERATION BY THIRD PARTIES.

9. Personal Information used by Third Party Websites

From time to time, we may include links to third party websites which are not controlled or maintained by us. We are not responsible for personal information submitted by you to third party websites or the personal information collected by third party websites. The information that you share with third party websites will be governed by their specific privacy policies and terms of service and not by this Privacy Policy. By providing these links, we do not imply that we endorse or have reviewed these websites. You should review the privacy policies of third party websites or contact the third party website’s operator if you have questions or concerns.

10. Artificial Intelligence

We may utilize artificial intelligence (“AI”) tools and automated processing technologies made available by our service providers to support and enhance certain aspects of our services and our internal operations. These technologies may assist in improving efficiency, streamlining workflows, supporting client communications, generating insights, identifying errors or anomalies, and providing more tailored and responsive services to our clients. Where AI-powered features are used, your personal information may be processed through a combination of automated systems and, where necessary, human review to ensure accuracy, reliability, and appropriate oversight.

Any personal information processed through AI systems is used solely for the purpose of delivering our services and improving service quality. Such information is not used to develop, train, improve, or retrain any generalized AI or machine learning models. Data originating from third-party platforms or integrations is used strictly to perform services on your behalf, and is not repurposed for unrelated AI development.

11. Age of Majority

NMLLP does not knowingly collect personal information from individuals under the age of 18 without verification of parental consent, and the Website and our services are not intended for them. If we learn we have collected or received personal information from an individual under the age of 18 without verification of parental consent, we will delete such personal information. If you believe we might have any information from or about any such individual, please contact us as set forth below.

12. Personal Information Retention and Data Deletion

We keep personal information until:

(a) We no longer need it to satisfy the purposes described in this Privacy Policy; and

(b) We have no legal obligation to keep it.

If you wish to have us delete your data held on our servers, please contact us at the support contact information listed in this Privacy Policy. Our clients are also able to edit and delete certain information through our client portal.

13. Personal Information Outside Canada

Personal information provided to our service providers may be stored outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.

14. Changes to the Privacy Policy

We may change this Privacy Policy from time to time in our sole discretion, so please be sure to check back periodically. You can tell if this Privacy Policy has changed by checking the last updated date that appears at the beginning of this Privacy Policy. We may, but are not obligated to, provide you with notice in case of any material changes made to this Privacy Policy. You should not continue using the Services if you do not agree with the version of this Privacy Policy in effect at that time. By continuing to use the Services, you agree and accept the version of this Privacy Policy in effect at that time. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

15. Limitation of Liability

UNDER NO CIRCUMSTANCES SHALL NMLLP BE LIABLE FOR ANY DIRECT OR INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES THAT MAY ARISE FROM A CLAIM OF BREACH OF THIS PRIVACY POLICY. Some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages. In such jurisdictions, our liability is limited to the greatest extent permitted by law, or $5, whichever is less.

16. Job Applicants

When you apply for a job with NMLLP, we collect the information that you provide in connection with your job application. This includes name, contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or provided during interviews (which may be recorded). This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information.

We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information (a) to improve our Website; (b) as otherwise necessary to comply with relevant laws; (c) to respond to subpoenas or warrants served on NMLLP; and (d) to protect and defend the rights or property of NMLLP or others.

17. Governing law

This Privacy Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.

18. Contact

NMLLP’s Privacy Officer is responsible for the implementation of this Privacy Policy and monitoring our adherence to its terms and all applicable laws. The Privacy Officer also handles questions and concerns about our Privacy Policy, as well as personal information access requests and complaints. You may also seek advice from the Office of the Privacy Commissioner of Canada and, if appropriate, file a written complaint with the Commissioner’s office

If you have any requests, questions or comments about your personal information or this Privacy Policy, you may contact our Privacy Officer, David Austring:

(a) By email: daustring@nmcpa.ca

(b) By Phone: 905-479-7001