Privacy Policy

Synomos

Effective date: September 19, 2026

1. Introduction

Synomos ("we," "us," or "our") is committed to protecting the personal information we collect, use, and disclose in the course of providing consulting, advisory, and forensic accounting services, in accordance with applicable privacy legislation. Synomos operates as a sole proprietorship providing these services in Ontario.

This Privacy Policy sets out how we collect, use, disclose, and safeguard personal information in the course of our practice.

2. What Is Personal Information

Personal information means information about an identifiable individual. It does not generally include business contact information, such as a person's name, title, or business telephone number or email address, used to contact them in a business capacity.

3. Accountability and Privacy Governance

We are responsible under applicable privacy legislation for the personal information in our possession or control. We have appointed a Privacy Officer to oversee privacy matters for our practice and have implemented policies and procedures intended to protect personal information from unauthorized access, use, or disclosure, and to respond to privacy inquiries and complaints in a timely manner. Our Privacy Officer can be reached using the contact information in Section 15.

4. How We Collect and Use Personal Information

We collect personal information directly from individuals wherever practicable. In some circumstances we may also collect personal information indirectly, such as from a referral source or from another party involved in an engagement, or automatically through our website, as described in Section 11.

Consulting Services

In the course of providing our services, we collect, use, and disclose personal information to:

establish and manage the client and engagement relationship;
perform the services requested, including the review and analysis of financial and business records;
communicate with third parties as necessary to complete an engagement, such as auditors, advisors, or other professionals retained by a client;
issue invoices and manage accounts receivable; and
comply with applicable regulatory and contractual requirements.

We treat information obtained in the course of an engagement as confidential. We will not disclose it outside the engagement except as the client directs, as reasonably necessary to carry out the engagement, or as required by law.

Newsletters and Updates

If you subscribe to receive updates, newsletters, or similar publications from us, we collect your name, email address, and organization in order to send you that content. You may unsubscribe at any time using the link provided in each communication or by contacting us using the information in Section 15.

Job Applicants

If you apply for a position with us, we collect the personal information contained in your application materials, such as a resume and cover letter, to assess your suitability for the position and to conduct the hiring process. With your consent, we may also contact references or conduct background checks.

General

We may also use personal information to maintain our business and financial records, respond to inquiries, and administer our practice.

5. Consent

We collect, use, and disclose personal information only with the knowledge and consent of the individual concerned, except where otherwise permitted or required by law. Consent may be express or implied, and may be given by an authorized representative. By retaining us, or by voluntarily providing personal information to us, an individual consents to our collection, use, and disclosure of that information for the purposes described in this Policy.

If a client provides us with personal information about a third party, such as an employee, counterparty, or other individual, the client is responsible for ensuring they have the authority to do so.

We may collect, use, or disclose personal information without consent where permitted or required by law, including:

where required to comply with a court order, subpoena, or other lawful demand for production;
where the information is already publicly available, such as in a court record or public registry;
where necessary to investigate a breach of an agreement or a contravention of law; or
where otherwise permitted or required by applicable legislation.

6. Sharing of Personal Information

We may share personal information with:

third parties engaged in an engagement, such as auditors, other professional advisors, or client personnel, as necessary to complete the engagement;
third-party service providers who assist us in operating our practice, such as bookkeeping, information technology support, document storage, and file transfer providers, under arrangements that require them to protect the confidentiality of the information;
regulators, law enforcement, or other lawful authorities, where required by law; and
a purchaser or successor, in the event of a sale, merger, or other transfer of all or part of our practice.

We do not sell personal information.

7. Cross-Border Storage and Processing of Personal Information

Some of the service providers we rely on, including providers of cloud storage, email, and software tools, may store or process personal information in Canada or in other jurisdictions, including the United States. Where personal information is held outside Canada, it becomes subject to the laws of that jurisdiction, which may permit access by courts, law enforcement, or national security authorities there.

We retain personal information only as long as necessary to fulfil the purposes for which it was collected, and thereafter in accordance with our standard record-retention practices and applicable limitation periods.

8. Safeguards

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information in our custody, to protect it against unauthorized access, use, disclosure, loss, or modification.

9. Recordings

We may record calls or virtual meetings, or use a transcription or note-taking tool during them, only with the knowledge of every participant, obtained before the call or meeting begins. Recordings and transcripts are used only to keep an accurate record of the engagement and are subject to the same confidentiality obligations and safeguards as our other records.

10. Automated Systems

We may use automated systems and technologies, including artificial intelligence, in the course of providing our services and administering our practice. These tools may be used for tasks such as research, document review and drafting, and correspondence, and may process personal information in doing so, including transcription or summarization of calls and meetings recorded or attended under Section 9.

Use of these tools does not replace our professional judgment, and we do not rely on an automated system to make a decision that produces a legal or similarly significant effect on an individual without meaningful human involvement. Personal information processed using these tools remains subject to the confidentiality obligations and safeguards described elsewhere in this Policy.

We will update this Policy if our use of automated systems materially changes.

11. Our Website

When you visit our website, we may automatically collect technical information, such as your IP address, browser type, and the pages you visit, to help us understand and improve use of the website. Our website may use cookies or similar technology for this purpose. You may adjust your browser settings to limit or block cookies, though doing so may affect the site's functionality.

We may use a third-party analytics service, such as Google Analytics, to help us understand website activity. We do not use website data for behavioural or interest-based advertising.

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing them with personal information.

12. Your Choices

You may withdraw your consent to receive newsletters or other marketing communications from us at any time, using the unsubscribe link included in the communication or by contacting us using the information in Section 15. This does not affect communications necessary to the delivery of our services or the administration of an existing engagement.

13. Your Rights

Subject to limited exceptions permitted by law, you may:

request access to the personal information we hold about you;
request that we correct inaccurate or incomplete personal information; and
withdraw your consent to our collection, use, or disclosure of your personal information, subject to legal and contractual restrictions.

These requests may be subject to exceptions under applicable privacy legislation, including where the information was generated in the course of a formal dispute resolution process, would reveal confidential information about another individual, or where we are otherwise required or permitted by law to withhold it.

To exercise these rights, contact our Privacy Officer using the information in Section 15.

14. Updates to This Policy

We may update this Policy periodically to reflect changes in our practices or in applicable law. The effective date of the current version appears at the top of this Policy.

15. Contact Us

Questions, concerns, or complaints about this Policy, or about our handling of personal information, and requests to exercise the rights described in Section 13, may be directed to:

Privacy Officer