Privacy and Personal Information Protection Policy

Last updated: September 3, 2026

Éric Brunelle, CPA, MBA, a sole proprietor carrying on professional activities under the trade name Impotax (“Impotax,” “we,” “our” or “us”), places great importance on the confidentiality and protection of the personal information entrusted to us.

This policy explains how Impotax collects, uses, discloses, retains and protects personal information in connection with its income tax return preparation services.

It applies when you:

• visit our website;
• communicate with us by telephone or email;
• book an appointment;
• submit documents through our secure portal;
• attend an in-person appointment;
• have your income tax returns prepared;
• sign your EFILE authorization forms;
• make a payment;
• apply for a position with Impotax.

This policy has been established in accordance with applicable privacy legislation, including Quebec’s Act respecting the protection of personal information in the private sector.

As a Chartered Professional Accountant, Éric Brunelle is also subject to the Code of ethics of chartered professional accountants and the professional obligations concerning confidentiality and professional secrecy. Impotax team members must preserve the confidentiality of all information they access while performing their duties.

1. Privacy Officer

Because Impotax is operated by Éric Brunelle as a sole proprietor, he also acts as the person responsible for the protection of personal information.

The Privacy Officer oversees the application of this policy and Impotax’s compliance with its privacy obligations.

Privacy Officer: Éric Brunelle, CPA, MBA
Position: Owner of Impotax and Privacy Officer
Legal status: Sole proprietor
Trade name: Impotax
Address: 633 Sœur-Marie-Rose Street, Lachenaie (Terrebonne), Quebec, J6V 1P1
Telephone: 514-234-3737
Email: info@impotax.org

Questions, requests for access or correction, complaints and concerns regarding your personal information may be directed to the Privacy Officer.

2. Personal Information We Collect

Impotax collects only the personal information reasonably necessary to prepare your income tax returns and administer your file.

Depending on your tax situation, we may collect the following categories of information.

Identification Information

• first and last name;
• date of birth;
• mailing address;
• telephone number;
• email address;
• marital status;
• preferred language;
• social insurance number;
• information about your spouse and dependants.

Tax and Financial Information

• federal and provincial tax slips;
• employment, pension, investment, rental or self-employment income;
• notices of assessment or reassessment;
• information concerning registered plans;
• expenses, credits and tax deductions;
• rental property information;
• information relating to self-employment activities;
• banking information required for direct deposit;
• prior-year income tax returns;
• correspondence from the Canada Revenue Agency, Revenu Québec or another tax authority.

Family and Medical Information

When required to prepare your income tax returns, we may also review:

• medical expense receipts;
• information concerning an impairment or limitation;
• childcare expense information;
• information about dependants;
• information relating to a separation, divorce or death;
• information concerning support payments or caregivers.

Service-Related Information

• information provided when booking an appointment;
• telephone and email communications;
• signed authorization forms;
• information required for invoicing and payment;
• requests for adjustments or prior-year income tax returns.

Some of this information, including social insurance numbers and tax, financial and medical information, is considered particularly sensitive.

3. Sources of Personal Information

We collect personal information primarily from you.

With your authorization or where permitted by law, information may also be obtained from:

• your spouse;
• your legal representative, authorized representative or liquidator;
• the Canada Revenue Agency;
• Revenu Québec;
• another provincial tax authority;
• an employer;
• a financial institution;
• a government organization;
• a technology service used to send us information.

If you provide personal information about another person, you must ensure that you are authorized to disclose it to us.

Information Concerning Children

Impotax may receive information about a child when it is required to prepare the income tax return of the child’s parent or legal representative, including:

• the child’s name;
• date of birth;
• social insurance number;
• childcare expenses;
• educational information;
• income;
• medical expenses;
• benefits or tax credits concerning the child.

Information concerning a child under 14 years of age must be provided by the child’s parent, legal guardian or another legally authorized person.

Impotax does not knowingly solicit personal information directly from children under 14 through its website.

4. How We Collect Personal Information

We may collect personal information through:

• telephone conversations;
• email communications;
• in-person appointments;
• our secure document submission portal;
• our appointment scheduling system;
• paper or electronic forms;
• tax documents temporarily provided to us;
• the online services of the Canada Revenue Agency and Revenu Québec, with your authorization;
• our website.

Google Workspace Secure Portal

Impotax uses Google Workspace to allow clients to submit documents electronically.

Uploaded documents are used only to prepare and review the requested income tax returns. Impotax does not retain clients’ supporting documents once the file has been completed.

Appointment Scheduling Through Square

Impotax uses Square to schedule and manage appointments.

When you book an appointment, Square may collect the information required to manage your reservation, including:

• your name;
• your email address;
• your telephone number;
• the date and time of the appointment;
• the type of service requested;
• information you voluntarily enter in the booking form.

Information collected directly by Square is also subject to Square’s own privacy policy.

Do not enter your social insurance number or detailed tax information in the comments section of your appointment booking.

In-Person Appointments

During an in-person appointment, the client brings the documents required to prepare their income tax returns.

The documents are reviewed and used during the appointment. The client then leaves with all original documents.

Impotax does not retain paper or electronic copies of these supporting documents.

5. Why We Use Personal Information

Personal information may be used to:

• verify your identity;
• communicate with you;
• schedule and confirm an appointment;
• prepare your income tax returns;
• verify the accuracy and completeness of the information received;
• identify applicable tax credits, deductions and elections;
• submit your income tax returns to the appropriate tax authorities;
• prepare adjustments or prior-year income tax returns;
• obtain tax information with your authorization;
• respond to requests from the Canada Revenue Agency or Revenu Québec;
• prepare and obtain signatures on required forms;
• issue an invoice and confirm payment;
• comply with our tax, legal and professional obligations;
• prevent errors, fraud and security incidents;
• process an employment application.

Impotax does not use your personal information to create an advertising profile.

No decision producing legal effects concerning you is made exclusively through an automated decision-making system.

6. Consent

When you provide personal information to us, you consent to its collection, use and disclosure for the purposes described in this policy.

Your consent may be required to allow Impotax to:

• access certain information from tax authorities;
• electronically file your income tax returns;
• disclose your information to the appropriate tax authorities;
• use the information and documents provided to prepare your income tax returns.

You may withdraw your consent, subject to applicable legal, tax, professional and contractual obligations.

Refusing to provide certain information or withdrawing your consent may prevent Impotax from preparing or filing your income tax returns.

Where permitted or required by law, certain personal information may be collected, used or disclosed without consent.

7. Access to Personal Information Within Impotax

Access to personal information is limited to individuals who require it to perform their work, including:

• Éric Brunelle, CPA;
• income tax return preparers;
• reviewers;
• authorized administrative personnel;
• information technology technicians when their assistance is required.

Team members are required to protect the confidentiality of the information they access.

They receive instructions concerning:

• file confidentiality;
• professional secrecy;
• secure use of computer systems;
• document transmission;
• password management;
• prevention of privacy incidents;
• destruction of information in accordance with established retention periods.

8. Disclosure of Personal Information to Third Parties

Impotax does not sell or rent your personal information.

Where necessary to provide our services or as permitted by law, information may be disclosed to:

• the Canada Revenue Agency;
• Revenu Québec;
• other applicable tax authorities;
• our tax software provider;
• Google Workspace for document transmission;
• Square for appointment scheduling and management;
• HostPapa for website hosting and operation;
• electronic signature service providers;
• information technology service providers;
• financial institutions or payment service providers;
• the Ordre des comptables professionnels agréés du Québec;
• legal counsel, insurers or other professional advisers;
• government, law enforcement or judicial authorities when required or permitted by law.

Service providers are authorized to use the information they access only to provide the agreed-upon services or comply with their legal obligations.

9. Technology Service Providers

Impotax uses the following technology service providers.

HostPapa

The Impotax website is hosted by HostPapa. This provider may process certain technical data required to operate, maintain and secure the website.

Google Workspace

Our document submission portal and certain communication tools are provided through Google Workspace.

Documents submitted through the portal are used to prepare income tax returns. Impotax deletes them after the file has been completed.

Square

Appointments are scheduled through Square. Square processes the information required to create, confirm and manage appointments.

These providers have their own privacy policies and security measures.

Depending on each provider’s technology infrastructure and terms of service, information processed through these services may be stored or processed outside Quebec or Canada.

10. Retention and Destruction of Personal Information

Impotax limits the retention of personal information based on its purpose and applicable obligations.

Documents Submitted Electronically

Tax slips, receipts, statements, invoices and other supporting documents submitted through the secure portal are used to prepare income tax returns.

Impotax deletes these documents once the file has been completed. They are not retained in a permanent client file.

Depending on how the technology services operate, residual copies may temporarily remain in protected backups before being deleted through the normal backup replacement cycle.

Documents Provided During In-Person Appointments

Documents brought to an appointment are returned to the client before they leave.

Impotax does not retain paper or electronic copies of these supporting documents.

Emails

Incoming and outgoing emails are retained for a maximum of one year and are then deleted according to Impotax’s retention schedule.

An email may exceptionally be retained for a longer period where required because of a legal obligation, audit, claim or dispute.

Signed EFILE Authorization Forms

Signed EFILE authorization forms, including the federal T183 and Quebec TP-1000.TE forms, are retained for seven years.

These forms are retained to comply with the requirements applicable to the electronic filing of income tax returns.

They are securely destroyed at the end of the retention period.

Employment Applications

Résumés, cover letters and communications relating to employment applications are retained for a maximum of one year and then deleted, unless the applicant consents to a longer retention period.

Contact Information Used for Christmas Cards

Impotax does not send newsletters or recurring promotional emails.

However, we may use our clients’ names and mailing addresses to send them a Christmas card.

You may ask us to stop sending you Christmas cards at any time by emailing info@impotax.org.

11. Client Responsibility for Tax Documents

Because Impotax does not retain tax slips, receipts or other supporting documents used to prepare income tax returns, clients are responsible for retaining their own records.

We recommend keeping the following documents for at least six years:

• tax slips;
• receipts;
• invoices;
• bank statements;
• proof of payment;
• documents supporting credits and deductions;
• copies of income tax returns;
• notices of assessment;
• any other relevant supporting document.

The Canada Revenue Agency or Revenu Québec may request these documents at a later date to verify income, expenses, deductions or tax credits.

12. Security Measures

Impotax applies administrative, technical and physical measures appropriate to the sensitivity of the personal information being processed.

These measures include:

• restricting access to authorized individuals;
• using individual user accounts;
• protecting workstations;
• secure password management;
• using protected software and systems;
• regularly updating systems;
• securely transmitting documents;
• backing up information that must be retained;
• training personnel regarding confidentiality;
• requiring confidentiality commitments;
• securely retaining signed EFILE authorization forms;
• securely destroying information at the end of its retention period;
• periodically reviewing our security practices.

No technology can guarantee absolute security. Clients must also protect their devices, email accounts and passwords.

13. Secure Transmission Methods

To protect your personal information, we recommend using the Impotax secure portal to submit your tax documents.

Never send your social insurance number or tax documents through:

• text message;
• Messenger;
• a private message on social media;
• an unapproved instant messaging platform.

If you send information by email, verify that you are using the correct address and limit the sensitive information entered directly in the message.

When using our secure portal, protect access to your account and email address. Use a unique password and do not share it with anyone.

14. Privacy Incidents

A privacy incident may include:

• unauthorized access to personal information;
• unauthorized use or disclosure of information;
• loss of a document or device;
• a security breach affecting a system;
• sending a document to the wrong person.

If an incident occurs, Impotax will take reasonable measures to:

• limit its consequences;
• recover or secure the information where possible;
• assess the risk of harm;
• prevent a similar incident from happening again;
• document the incident;
• notify the affected individuals and the Commission d’accès à l’information du Québec when required by law.

If you believe that information submitted to Impotax has been lost, accessed or disclosed without authorization, promptly email info@impotax.org.

15. Cookies and Technical Data

When you visit our website, the website or its hosting provider may automatically collect certain technical information, including:

• your IP address;
• device type;
• operating system;
• browser type;
• date and time of your visit;
• pages viewed;
• the website or link that directed you to our site.

This information may be used to:

• operate the website;
• maintain its security;
• detect unusual activity;
• correct technical problems;
• produce general usage statistics.

The website may use cookies that are essential to its operation. These cookies are not used to create an advertising profile or display targeted advertising.

You can configure your browser to block or delete certain cookies. However, doing so may affect the operation of some parts of the website.

External pages and services, including Square and Google, may use their own cookies in accordance with their respective privacy policies.

16. Links to External Websites

Our website may contain links to websites operated by third parties, including:

• the Canada Revenue Agency;
• Revenu Québec;
• Google;
• Square;
• HostPapa;
• Adobe;
• YouTube;
• government or privately operated tax tools.

When you visit an external website, that third party’s privacy policy applies. Impotax is not responsible for the privacy practices of external websites.

17. Your Rights

Subject to the restrictions provided by law, you may request:

• confirmation of whether we hold personal information about you;
• access to your personal information;
• correction of inaccurate, incomplete or ambiguous information;
• information about how your personal information has been used or disclosed;
• withdrawal of your consent;
• the discontinuation of certain uses or disclosures;
• access to certain computerized information in a structured and commonly used technological format;
• transmission of that information to an authorized person or organization where the legal conditions are met.

Requests must be made in writing to the Privacy Officer.

To avoid disclosing information to the wrong person, Impotax may verify your identity before responding to a request.

We will respond within the period prescribed by law. If we cannot grant a request, we will explain the reasons for our decision, subject to applicable restrictions.

18. Complaints

Complaints concerning the collection, use, disclosure, retention or destruction of personal information may be submitted to:

Éric Brunelle, CPA, MBA
Owner of Impotax and Privacy Officer
info@impotax.org
514-234-3737

Complaints will be handled confidentially. We will review the matter and contact the individual concerned to provide our response or request additional information.

Individuals who are not satisfied with our response may also contact the Commission d’accès à l’information du Québec.

19. Changes to This Policy

Impotax may amend this policy to reflect:

• changes to our services;
• technological changes;
• the use of a new service provider;
• changes to our practices;
• new legal or regulatory requirements.

The most recent version will be published on this page. The date of the latest update will appear at the beginning of the policy.

20. Contact Us

For questions about this policy or the protection of your personal information:

Éric Brunelle, CPA, MBA
Sole proprietor operating under the trade name Impotax
Owner and Privacy Officer
633 Sœur-Marie-Rose Street
Lachenaie (Terrebonne), Quebec, J6V 1P1

Telephone: 514-234-3737
Email: info@impotax.org