Privacy Policy

Effective Date: July 29, 2026

Who We Are

Affirm LLP Chartered Professional Accountants (“Affirm LLP”) and First & First Consulting Ltd. are independent entities that work together to provide accounting, tax, bookkeeping, financial planning, and related advisory services. For purposes of this Privacy Policy, these entities may be referred to collectively as the “Affirm Network,” “we,” “us,” or “our.”

First & First Consulting Ltd. is independently owned and provides bookkeeping and accounting services to clients of the Affirm Network. If you have engaged us for bookkeeping services these may be provided by First & First Consulting Ltd. but invoiced through Affirm LLP.

Purpose of This Policy

The purpose of this Privacy Policy is to explain how we collect, use, disclose, retain, and protect personal information when providing our professional services.

We are committed to protecting personal information in accordance with applicable privacy laws, including Alberta’s Personal Information Protection Act (PIPA), and other applicable federal and provincial laws.

If you have questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer using the contact information provided below.

What Is Personal Information?

“Personal Information” means information about an identifiable individual. Depending on the services we provide, Personal Information may include:

• Name, address, telephone number, and email address;
• Date of birth;
• Social Insurance Number;
• Marital or family status;
• Employment and business information;
• Identity verification information;
• Tax information and tax filings;
• Financial information, including income, assets, liabilities, investments, and net worth;
• Banking and payment information;
• Information obtained from government agencies with your authorization; and
• Other information required to provide professional services to you.

Personal Information does not generally include business contact information used solely to communicate with an individual in their business capacity where permitted by applicable law.

Accountability

We are responsible for Personal Information under our control and have designated a Privacy Officer responsible for overseeing compliance with this Privacy Policy and applicable privacy legislation.

All team members with access to Personal Information are required to maintain confidentiality and comply with our privacy and security procedures.

What Information We Collect

The Personal Information we collect depends on the services requested and our legal and professional obligations.

We may collect:

Contact Information

Information used to communicate with you, including:

• Name;
• Mailing address;
• Telephone number;
• Email address.

Identity Information

Information required to verify identity, comply with professional standards, legal obligations, and regulatory requirements, including:

• Date of birth;
• Social Insurance Number;
• Government-issued identification;
• Occupation.

Financial Information

Information necessary to provide tax, accounting, financial planning, bookkeeping, and advisory services, including:

• Income information;
• Investment information;
• Employment history;
• Asset and liability information;
• Business financial information;
• Tax records and filings.

How We Collect Personal Information

We collect Personal Information directly from you whenever possible, including when you:

• Engage us to provide services;
• Meet with us in person;
• Communicate with us by email, telephone, mail, or other means;
• Submit documents through our secure client portal;
• Complete forms or questionnaires.

With your authorization, we may also collect information from third parties including:

• Canada Revenue Agency;
• Alberta Tax and Revenue Administration;
• Financial institutions;
• Employers;
• Professional advisors;
• Government agencies;
• Legal representatives.

Where required by law, we will obtain your consent before collecting Personal Information from third parties.

Personal Information of Minors

We may collect and use Personal Information relating to individuals under the age of 18 where necessary to provide tax, accounting, estate, trust, financial planning, or other professional services.

When providing information relating to a minor, you represent that you have the legal authority to provide that information and consent to its collection, use, and disclosure as described in this Policy.

How We Use Personal Information

We collect, use, and disclose Personal Information for purposes including:

• Verifying identity;
• Establishing and managing client relationships;
• Providing accounting, tax, bookkeeping, financial planning, and advisory services;
• Preparing tax returns, financial statements, and regulatory filings;
• Understanding your financial circumstances and objectives;
• Providing recommendations regarding services that may benefit you;
• Responding to inquiries and requests;
• Preventing fraud and unauthorized activity;
• Collecting fees and managing accounts;
• Meeting professional, legal, regulatory, insurance, risk management, and compliance requirements;
• Maintaining and improving our services;
• Protecting our legal rights and interests.

We limit our collection and use of Personal Information to that which is reasonable and necessary for the identified purposes.

Consent

By engaging our services or providing Personal Information to us, you consent to the collection, use, and disclosure of your Personal Information for the purposes described in this Privacy Policy and as otherwise permitted or required by law.

You may withdraw your consent at any time, subject to legal, contractual, professional, or regulatory restrictions and reasonable notice.

Withdrawal of consent may limit our ability to provide services to you or continue our professional relationship.

How Long We Retain Personal Information

We retain Personal Information only as long as necessary to:

• Fulfill the purposes for which it was collected;
• Meet legal, regulatory, professional, insurance, and business requirements;
• Resolve disputes;
• Defend legal claims.

Retention periods may vary depending on the nature of the information and services provided but are typically retained for a minimum of 7 years but is often kept longer in the event a statute barred period is not adhered to in order to defend a tax position taken.

When Personal Information is no longer required, it will be securely destroyed, anonymized, or permanently deleted in accordance with our records retention practices and applicable legal requirements.

Sharing Personal Information

We do not sell Personal Information.

We may disclose Personal Information where necessary to provide services or as otherwise permitted or required by law, including to:

• Employees, contractors, and service providers who require the information to perform their duties;
• Cloud service providers and technology providers;
• Bookkeeping and administrative service providers within the Affirm Network;
• Professional advisors, including legal counsel and insurers;
• Government agencies and regulatory authorities;
• Courts, tribunals, and law enforcement agencies when required or authorized by law.

We may disclose information without consent if required by law for example, but not limited to the following situations:

• To prevent, detect or suppress fraud or financial abuse
• In connection with an investigation
• To comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies
• To a government institution that has requested the information, identified its lawful authority, and has indicated that disclosure is for the purpose of enforcing, administering, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law, or to national security or the conduct of international affairs
• To an investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affairs.

Cross-Border Storage and Processing

Personal Information may be stored, processed, or accessed outside Alberta or Canada by service providers that assist us in delivering our services.

As a result, Personal Information may be subject to the laws of foreign jurisdictions and may be accessible to government authorities, courts, or regulators in those jurisdictions in accordance with applicable laws.

Where Personal Information is transferred outside Canada, we take reasonable steps to ensure appropriate safeguards are in place.

Your Privacy Rights

Subject to legal and professional restrictions, you may:

• Request access to Personal Information we hold about you;
• Request information about how your Personal Information has been used or disclosed;
• Request correction of inaccurate, incomplete, or outdated Personal Information;
• Withdraw consent where applicable;
• Make a complaint regarding our privacy practices.

Requests should be submitted to our Privacy Officer using the contact information below.

We may require verification of identity before responding to a request.

Safeguarding Personal Information

We use physical, organizational, contractual, and technological safeguards appropriate to the sensitivity of the Personal Information we hold.

These safeguards may include:

• Secure client portals;
• Encryption technologies where appropriate;
• Access controls and authentication procedures;
• Confidentiality obligations for personnel;
• Secure storage and destruction procedures;
• Ongoing monitoring and security reviews.

While we employ reasonable safeguards, no method of transmission or storage can be guaranteed to be completely secure. Individuals should exercise reasonable care when communicating electronically.

Privacy Breaches

If a privacy or security incident involving Personal Information occurs, we will investigate the incident promptly.

Where required by applicable law, we will notify affected individuals and relevant regulatory authorities if the incident creates a real risk of significant harm or otherwise triggers legal reporting obligations.

Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in our services, business operations, technology, legal requirements, or privacy practices.

The most current version will be posted on our website and will become effective upon posting unless otherwise stated.

Contact Our Privacy Officer

If you have questions, concerns, requests for access or correction, or wish to make a privacy complaint, please contact:

Privacy Officer
Affirm LLP Chartered Professional Accountants
Phone: 1-587-333-0018
Email: info@affirmcpa.com