Privacy Policy

At Coefficient, our mission is to provide strategic, trustworthy & compliant bookkeeping services, empowering entrepreneurs with the freedom to dream big and succeed. To fulfill this mission, we collect information about you, our:

● Customers and prospective customers

● Visitors to Coefficient’s websites, or anyone contacting Coefficient support

● Employees and prospective employees

● Contractors and prospective contractors or business partners

Your privacy is important to us. This privacy policy (this “Privacy Policy”) outlines how we at Coefficient (Coefficient Holdings Inc. and its affiliates, collectively “Coefficient”) collect, use, disclose, and safeguard your personal information. We also describe the rights you have over your information.

Please read this Privacy Policy carefully. By using the Services (as defined below), you acknowledge that you have read, understand and agree to be legally bound by this Privacy Policy and other policies incorporated herein by reference.

This Privacy Policy was last updated and is effective on March 5, 2021.

Coefficient reserves the right to modify this Privacy Policy at any time, in our sole discretion. We may modify this Privacy Policy by providing notice via one of the following methods: (i) by email to the email account used by you to access the Services, (ii) by updating the ‘last updated’ date listed above, or (iii) by your acknowledgement as part of your login to the Services. By continuing to use the Services you confirm that you agree to the modified Privacy Policy. If you do not agree with the changes to the Privacy Policy, you should stop using the Services and close your account within 30 days of the change.

Our services and how this Privacy Policy applies:

Coefficient offers financial tools and services (such as bookkeeping, accounting, payroll, analysis, tax, strategic services and access to banking services) to entrepreneurs and partner companies through its online platform at www.coefficientbooks.com, accessible via our website and mobile applications, and through our employees, contractors and business partners. Through these platforms and methods, our Customers can access the tools they need to power their businesses or the businesses of their clients. We refer to our platform, websites, mobile applications, employee work, contractor work and business partner work collectively as our “Services”.

This Privacy Policy applies to our Services, and other interactions you may have with Coefficient, such as visiting our websites, customer service inquiries, electronic communications and or other forms of telecommunications, attendance at events / virtual events, etc. By using our Services, or otherwise interacting with Coefficient, you agree to the collection and use of your personal information in accordance with this Privacy Policy. Personal information is any information or data relating to you that may be used to identify you, either directly or indirectly, or to contact you.

What information we collect about you and why

Visitors

We collect the following personal information about you when you visit our website or contact Coefficient support:

What we collect 

Information about you that you provide us about yourself, like your name, address, email address, and phone number. 

Why we collect it

· To communicate with you via email or via chatbot or instant message, or other electronic means

· To advertise and market products or features to you

· To comply with legal requirements

What we collect 

Information about how you access our websites or other social media or electronic sites, apps and our Services, including information about the device and browser you use, your network connection, your IP address, and details about how you browse through our apps and sites, including search terms you may enter. 

Why we collect it

· To provide you use of, and to improve, our websites and related services (e.g., identifying ways to make our websites easier to use or navigate)

· To personalize your experience using our websites (e.g., by changing the layout of our webpages)

· To advertise and market products or features to you

What we collect 

Information you provide us for surveys, contests and events (such as webinars, in-person events, etc), including your contact information, your business name and address, and general information about your organization that you choose to provide, such as annual company revenue, number of employees, industry, etc. 

Why we collect it

· To register you for the survey, contest or event, and provide you with the results or contents of the event

· To advertise and market products or features to you

Coefficient employees, prospective employees, contractors, prospective contractors, business partners, prospective business partners & customers.

We collect the following personal information about you when you apply for a position with Coefficient or enquire to so business with us as a contractor or business partner:

What we collect 

Contact information about you that you provide us about yourself, like your name, address, email address, phone number, contact details or like details for your company. 

Why we collect it 

· To communicate with you during the recruitment process or business discovery process

· To book interviews with you or members of our team or your team

· To verify your identity

· To comply with legal requirements

 What we collect 

Additional personal information you provide us, such as your professional and employment history (such as your resume or CV, past employment experience, occupations and titles, your LinkedIn profile or other social media handles), your nationality, your education (such as your degrees and schooling, licenses and professional memberships), your references, etc. 

Why we collect it 

· To review your suitability for a position and qualify you for a role or to review suitability as a contractor or business partner

· To verify your legal ability to work in the United States, Canada or other countries

Your consent

We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.

a) Express Consent

Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada’s anti-spam laws, similar laws in the United States, or for other countries in which we do business.

b) Implied Consent

Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request.

c) Withdrawing Your Consent

Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request.

CASL POLICY

We are committed to compliance with the law known as Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication sent by us to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message we send (a “CEM”), which is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting this Policy, and to provide transparency about our compliance, we have undertaken various initiatives in order to ensure we are compliant with CASL in various respects:

Consent—We do not send CEMs without your consent. This consent typically must be “express” (or expressly acknowledged by you), but in certain circumstances consent can be “implied” and in others, messages are specifically exempt from consent requirements. We have modified or adopted our sign-up, registration and consent forms in order to ensure that the express consent obtained from you is in compliance with CASL. When we are collecting your electronic contact information, you will know what purposes we want to use it for.

Content—We have adopted processes to ensure that our CEMs contain the prescribed content of CASL. On any CEM from us (usually in the footer), we will clearly:

· Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;

· Provide you contact information where you can readily contact us; and

· Set out a clear, working unsubscribe mechanism (or preference center) that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the internet).

Clarity—We have ensured that each constituent element of a CEM (including its header, its content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.

If you have received a CEM from us, and you believe that you should not have or you do not wish to receive them (even if we are allowed to send them), we will endeavour to respect your inbox preferences. Without limiting our legal rights or obligations, we try to ensure that our messages all contain useful identity information and unsubscribe or preferences link in our messages—if you check the CEM itself, you will find clear instructions on how to stop receiving CEMs from us or manage your mail preferences. When you unsubscribe, it should happen very quickly – but as required by CASL we will make sure it occurs within 10 business days. If you have any questions or concerns about our unsubscribe methods, you may contact us at the address indicated below.

How we use your information

We use the personal information we collect from you to provide you with our Services, to fulfill a contractual obligation (for example, to process your subscription payments), to improve our Services or where we need your personal information for a legitimate business interest. These legitimate interests include:

● verifying your or your business’ identity

● preventing risk and fraud (for example, to detect and protect Coefficient and other third parties against error or omission, negligence, breach of contract, fraud, theft, money laundering and other illegal activity, and to audit compliance with Coefficient’s policies and contractual obligations)

● answering questions or providing other types of support

● providing, securing, debugging and improving our Services, website or other electronic communications

● providing reporting and analytics

● testing features or additional services

● assisting with marketing, advertising, or other communications

● understanding your needs and eligibility for products and services

● complying with legal and regulatory requirements

● enforcing our Terms of Use and / or compliance with this Privacy Policy

We may also collect and use your personal information for any other purpose to which you consent.

We only collect the personal information we consider necessary for achieving these purposes.

We may use information that is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person for any business purpose.
 

Your rights over your information

Depending on your use of our Services and where you reside, you may have the right to request access to, correct, amend, delete, or object to certain uses of your personal information (for example, by unsubscribing from direct marketing emails).

We strive to provide you with the ability to exercise these rights yourself via our Services. For example, you can access, update and correct most of your information from your account settings pages. If you cannot exercise a particular right via our Services, you can always email our privacy team at info@coefficient.com. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may ask to see documentation verifying your identity.

Please also note that there is a difference between the information we decide to collect for our own purposes (for example, your account sign-up information) and the information our Customers direct us to store or process via our Services (for example, names of employees or clients). If you are an individual who wishes to exercise your rights over information that one of our Customers may be storing or processing via our Services for their own purposes, you will need to contact the Customer directly. In this scenario, we are only a service provider acting at their direction, and we cannot decide how to process their information.

When and why we share your information with others

We restrict access to your information to authorized employees, contractors or business partners and only share your personal information with third parties in the following circumstances.

As a Customer or Accountant Client, we may share your personal information with the following service providers to provide you with our Services:

Service provider Service provided Location

AWS  Cloud storage and infrastructure USA/Canada

Sendgrid  Transactional email API  USA/Canada

Mandrill  Transactional email API  USA/Canada

Splunk  Centralized logging  USA/Canada

Service provider Service provided Location

Rollbar  Error monitoring  USA/Canada

FileThis  Consumer finance document API USA/Canada

Plaid  Technical financial infrastructure API USA/Canada

Stripe  Payments API  USA/Canada

Treasury Prime  Banking API  USA/Canada

Radius Bank  Bank account provider  USA/Canada

We may also share your personal information with the following categories of third parties for certain other business purposes:

● Other Service Providers, Partners, Contractors or Vendors: for analytics and reporting, marketing and advertising, auditing, communicating with you, managing our customer database, providing you with professional services, managing our recruitment process and conducting background checks (for prospective Coefficient employees, contractors or business partners).

● Successor Entities: if we merge with or are acquired by another company, are involved in a bankruptcy, or if the ownership or control of all or part of our Services or their assets changes, information about you may be transferred to such entities.

● Law Enforcement, Government Agencies, and Professional Advisors: to prevent or investigate suspected fraud, money laundering, threats to physical safety, illegal activity, or violations of a contract or our policies, or to comply with a law or regulation, or if we are otherwise legally required to do so, such as in response to a court order or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands.

 

Where your data resides and international data transfers

Our Services are managed by Coefficient’s team at its headquarters in Canada. We rely on Service Providers, mentioned above, to operate the Services. These service providers are all located in and process your data in the United States or Canada. Coefficient does not currently offer or market its Services to individuals or businesses outside of the United States or Canada.

 

Data retention

Coefficient is a Canadian company, serving Canadian and American persons and businesses, and as such, we and our third party affiliates may be subject to various legal compliance and reporting obligations that require us to retain your personal information for a specific periods of time which may be beyond the time when you stop using the Services.
 

Removal of your information

We keep your information only as long as required for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.

If at any time you would like to unsubscribe from receiving future emails from us, you can do so by clicking the unsubscribe link in our email, or you can email us at info@coefficientbooks.com with the subject line “Unsubscribe”. We will promptly remove you from our mailing list.

How we protect your information

We maintain industry standard security safeguards to protect your information and ensure its confidentiality, integrity and availability. While we do our best to protect your information on our platform, we cannot guarantee absolute security of your personal information. 

General Security Practices

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, authorized contractors or authorized business partners, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.

Online Security

We follow generally accepted industry standards to protect personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the internet. Remember, if you have any questions about security on our website or platforms / Services, you can always contact us at info@coefficientbooks.com.

How we use cookies and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our Services.
 

Changes to this Privacy Policy

We may make changes to this Privacy Policy at any time to reflect updates to our Services, applicable laws, and other factors. We will notify you as outlined above when we make any material changes, but we encourage you to stay informed by reviewing this policy periodically.
 

How you can reach us

If you would like to ask about, make a request relating to, or complain about how we process your personal information, you can contact us by email at info@coefficient.com, or call us toll-free at 1-800-503-9025.

© Coefficient Strategic Bookkeeping 2021 (Coefficient Holdings Inc)