Effective Date: September 8, 2026

Count Smart Inc. (“Count Smart,” “we,” “us,” or “our”) is committed to protecting the privacy and personal information of visitors to our website (countsmart.ca) and of the clients we serve as part of our Disability Tax Credit (DTC) application service. This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and the rights you have under the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private-sector privacy law.

This policy applies to countsmart.ca and to the DTC application services Count Smart provides.

1. Who We Are

Count Smart Inc. is an independent, private accounting practice specializing in helping Canadians apply for the federal Disability Tax Credit program. Count Smart is not affiliated with, endorsed by, or acting on behalf of the Canada Revenue Agency (CRA) or any government body.

Privacy Officer: Barbara Mentus

Contact for privacy questions or requests:

  • Email: info@countsmart.ca
  • Toll-free: 1-844-832-1777
  • Local: 613-832-1777
  • Mailing address: 6164 Vineyard Dr., Ottawa, ON K1C 2N6

2. What Personal Information We Collect

We collect personal information from a few distinct sources. We only collect what is reasonably necessary for the purposes described below.

a) Information collected through our website contact form

When you submit our online “Contact Us” form, we collect:

  • First and last name
  • Email address
  • Phone number
  • Province of residence
  • The message/details you choose to provide

Our contact form is protected by a third-party bot-verification service (Cloudflare Turnstile), which may process limited technical data (such as your IP address and browser signals) to confirm you are not an automated submission. See Cloudflare’s own privacy policy for details on that specific safeguard.

b) Information collected once you become a client

Because the Disability Tax Credit application process is administered by the CRA and requires communication with your medical practitioner, once you engage Count Smart for DTC application assistance, we may collect additional, more sensitive information directly from you, your medical practitioner, or the CRA, which can include:

  • Health and medical condition information relevant to your DTC eligibility (Form T2201 and supporting medical documentation)
  • Social Insurance Number (SIN), where required to identify your file with the CRA
  • Tax and financial information relevant to assessing and calculating your potential refund
  • Communications with your physician or other medical practitioner, made with your consent

This sensitive information is collected directly from you by telephone (landline) or by mail — we do not collect this category of information through the website contact form or by email.

c) Information collected automatically through website analytics and advertising tools

When you visit countsmart.ca, we and our service providers automatically collect certain technical and usage information through the following tools:

  • Google Analytics (GA4), via Google Tag Manager, to understand how visitors use our site (pages viewed, time on site, general location, device/browser type)
  • Google Ads, to measure the effectiveness of our online advertising and track conversions (e.g., form submissions, phone calls) resulting from ad clicks
  • CallRail, a call-tracking service that assigns tracking phone numbers to our advertising campaigns so we can measure which marketing efforts generate calls. If you call one of these tracking numbers, CallRail may record and transcribe the call, and the number you dialed from, call duration, and call outcome may be logged and shared with Google Ads and GA4 for marketing measurement.

This category of information is generally non-identifying on its own (device and usage data) but may be combined with other data (such as your phone number, if you call a tracked number) in a way that identifies you.

3. Why We Collect Your Information (Purposes)

We collect and use personal information only for the following purposes:

  • To respond to your inquiry and provide a free eligibility consultation
  • To prepare, submit, and follow up on your Disability Tax Credit application with the CRA, including communicating with your medical practitioner on your behalf, with your consent
  • To calculate and pursue any refund or retroactive benefit you may be entitled to
  • To provide other accounting services you have requested
  • To measure and improve the performance of our website and advertising campaigns
  • To comply with legal, regulatory, and professional obligations

We do not sell personal information to third parties, and we do not use your health or medical information for any purpose beyond your DTC application and related accounting services.

4. Our Lawful Basis / Consent

Under PIPEDA, we collect, use, and disclose personal information only with your knowledge and consent, except where the law permits or requires otherwise.

  • Contact form submissions: by submitting the form, you consent to us contacting you about our services.
  • DTC application data (health, SIN, financial): collected only once you engage us as a client, based on your express consent, because it is necessary to perform the DTC application service you have requested (contractual necessity) and to communicate with the CRA and your medical practitioner on your behalf.
  • Website analytics and advertising cookies: based on implied consent for standard analytics/advertising cookies, consistent with what a reasonable person would expect from visiting a business website; you can withdraw this consent at any time by adjusting your browser settings or using available opt-out tools (see Section 8).

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent partway through an active DTC application may limit or delay our ability to continue acting on your behalf.

5. Who We Share Your Information With

We share personal information only with the following categories of recipients, and only as necessary for the purposes above:

Recipient What is shared Why
Canada Revenue Agency (CRA) DTC application (Form T2201), supporting medical and financial information, SIN Required to submit and process your DTC application
Your medical practitioner Confirmation of details relevant to your application To complete required medical certification
Google (Google Ads, Google Analytics/GA4, Google Tag Manager) Website usage data, ad-click/conversion data To measure marketing performance and website usage
CallRail Call metadata, call recordings/transcripts (if enabled) from tracked phone numbers To measure which marketing campaigns generate phone inquiries
Cloudflare (Turnstile) Limited technical/browser data at time of form submission Bot/spam protection on our contact form

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

6. Cross-Border Data Transfer

Google and CallRail are U.S.-based service providers. As a result, some personal information described above (in particular, website analytics data, advertising/conversion data, and call-tracking data) may be processed or stored on servers located in the United States or other jurisdictions outside Canada, and may therefore be subject to the laws of those jurisdictions, including potential access by foreign authorities under local law.

We only work with established providers (Google, CallRail, Cloudflare) that maintain their own privacy and security commitments, and we limit what is shared with them to what is necessary for the purposes described in this policy. Sensitive DTC application information (medical details, SIN, financial data) is handled through our direct client service process, described in Section 2(b), separately from these third-party marketing tools.

7. How Long We Keep Your Information

  • Client files (DTC applications, medical/financial/tax records): retained for 7 years, consistent with CRA recordkeeping requirements and professional/regulatory obligations for accounting records, and securely destroyed afterward.
  • Contact form inquiries that do not become active clients: retained only as long as reasonably necessary to respond to the inquiry, then deleted or anonymized.
  • Website analytics and advertising data: retained according to the default retention settings of Google Analytics, Google Ads, and CallRail, consistent with those platforms’ standard retention periods.

8. Your Rights Under PIPEDA

You have the right to:

  • Access the personal information we hold about you
  • Correct inaccurate or incomplete personal information
  • Withdraw consent for the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions
  • Request deletion of personal information we no longer need for the purposes it was collected for, subject to our legal recordkeeping obligations
  • Ask questions or file a complaint about how we handle your personal information

To exercise any of these rights, contact us at info@countsmart.ca or 1-844-832-1777. We will respond within a reasonable time and in accordance with PIPEDA’s requirements.

If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC):

  • Website: priv.gc.ca
  • Toll-free: 1-800-282-1376

Opting out of website tracking: you can limit Google Analytics/Google Ads tracking using your browser’s cookie settings, the Google Analytics Opt-out Browser Add-on, or Google’s Ads Settings page. You can decline microphone/analytics permissions where prompted by your browser.

9. How We Safeguard Your Information

We take reasonable administrative, physical, and technical measures to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification, appropriate to the sensitivity of the information. This includes limiting access to client files to staff who need it to perform their work, and secure handling of documents containing medical, financial, or SIN information.

10. Accuracy

We rely on you to provide accurate and complete information, and we make reasonable efforts to ensure the information in your file is accurate and up to date for the purposes for which it is used, particularly before submitting your application to the CRA.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The “Effective Date” at the top of this page will indicate when it was last updated. Material changes will be posted on this page.

12. Contact Us

Count Smart Inc.
Privacy Officer: Barbara Mentus
Email: info@countsmart.ca
Toll-free: 1-844-832-1777
Local: 613-832-1777
Fax: 613-834-3777
Mailing address: 6164 Vineyard Dr., Ottawa, ON K1C 2N6

For a plain-language overview of how we protect your information, see our Confidentiality page.