Privacy Policy

1. Who We Are

The Cash Flow Whisperer
A division of 0795163 B.C. Ltd.

Privacy Contact: Dagmar L.
Email: [email protected]
Location: British Columbia, Canada

The Privacy Contact is responsible for privacy matters and for responding to requests concerning personal information held by The Cash Flow Whisperer.

2. What Is Personal Information?

Personal information is information about an identifiable individual.

Depending on how you interact with us, this may include:

your name;

email address;

telephone number;

business or mailing address;

company name and professional information;

information provided when booking a Right Fit Chat or consultation;

information provided through questionnaires, assessments or forms;

business and financial information that you voluntarily provide for an assessment or advisory engagement;

information contained in correspondence with us;

information about your use of our website, including certain technical information; and

information collected through cookies or similar technologies, where applicable.

We do not ask you to provide passwords, banking login credentials, credit card numbers, government identification numbers or other information that is not reasonably necessary for the service you are requesting.

3. Information Collected Through Questionnaires and Financial Assessments

Some of our questionnaires, lead-generation forms and Financial Assessment processes may ask for information about your business.

This may include:

revenue and sales information;

expenses and profitability information;

cash flow information;

accounts receivable or payment information;

information about business operations;

information about sales, inventory or other cash-flow drivers; and

other information you choose to provide to help us understand your business.

Because financial and business information can be sensitive, we encourage you to provide only the information reasonably necessary for the particular purpose.

Information submitted through a questionnaire or assessment will not be publicly displayed, sold or rented, or used to identify you in marketing materials without your consent, unless disclosure is required or permitted by law.

4. How We Collect Information

We may collect personal information:

directly from you when you complete a form or questionnaire;

when you book or request a consultation;

when you contact us by email, telephone or another communication method;

when you voluntarily provide information during a Financial Assessment or advisory engagement;

when you subscribe to communications from us;

automatically through our website or digital services, including cookies and similar technologies; and

from service providers that process information on our behalf.

When we collect information directly from you, we will make reasonable efforts to explain why the information is being collected and how it will be used.

5. Why We Collect and Use Personal Information

We collect and use personal information for purposes that a reasonable person would consider appropriate in the circumstances, including to:

respond to inquiries;

determine whether our services may be appropriate for you;

schedule and conduct Right Fit Chats and other consultations;

conduct Financial Assessments;

provide consulting and advisory services;

communicate with clients and prospective clients;

provide resources or information you have requested;

administer our business and client relationships;

improve our website, questionnaires, services and client experience;

understand how visitors use our website and digital services;

send requested or permitted communications;

send marketing communications where we have the appropriate consent or another lawful basis to do so;

protect our business, systems and users from fraud, misuse or security threats;

comply with legal, regulatory, accounting or insurance requirements; and

establish, exercise or defend legal claims.

We will not use personal information for a new purpose that is materially different from the purpose for which it was collected without obtaining additional consent where required by law.

6. Consent

Where consent is required by applicable privacy law, we will seek meaningful consent for the collection, use or disclosure of personal information.

The type of consent required may depend on the nature and sensitivity of the information and the circumstances in which it is collected.

Where information is sensitive, including certain financial information, we may request express consent.

You may withdraw consent to the collection, use or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawing consent may affect our ability to provide a service where the information is reasonably necessary to provide that service.

Withdrawal of consent for marketing communications will not affect your ability to receive services you have requested.

7. Marketing Communications

If you choose to receive newsletters, educational material, invitations or other commercial electronic communications from us, we will use your contact information for that purpose in accordance with applicable Canadian anti-spam requirements.

Marketing communications will include an unsubscribe mechanism where required.

You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us at [email protected].

Unsubscribing from marketing communications does not necessarily remove your information from our client or business records where we have a legitimate reason or legal obligation to retain it.

8. Cookies and Website Technologies

Our website, landing pages and funnels may use cookies, pixels, analytics tools and similar technologies.

These technologies may be used to:

make the website function properly;

remember preferences;

understand website traffic and usage;

improve website performance;

measure the effectiveness of marketing campaigns; and

support certain advertising or remarketing functions, where applicable.

Some cookies or similar technologies may be provided by third-party service providers.

You can manage or restrict cookies through your browser settings. Disabling certain cookies may affect website functionality.

Where applicable law requires consent for particular tracking technologies, we will seek that consent.

9. Third-Party Service Providers

We use a combination of internally managed systems and carefully selected third-party service providers to operate our business and provide services.

Depending on the service involved, these providers may include providers of:

website and funnel technology;

customer relationship management systems;

appointment scheduling;

email delivery;

form and questionnaire processing;

analytics;

payment processing;

communications; and

other business-support services.

Third-party service providers may process personal information on our behalf and may be located in Canada or other countries.

We take reasonable steps to select service providers that provide appropriate privacy and security protections and, where appropriate, require them by contract to protect personal information and use it only for authorized purposes.

10. Secure Document Transfer and Client Documents

Where clients need to provide documents or other files to The Cash Flow Whisperer, we may provide access to a privately managed Nextcloud environment for secure document transfer and collaboration.

Our Nextcloud environment is self-hosted. It is not a public cloud storage service operated by Nextcloud on our behalf. The hosting arrangement and security configuration of our particular environment are managed separately from Nextcloud's hosted services.

Access to client documents is restricted according to the requirements of the engagement.

Where appropriate, Nextcloud may also be used to facilitate secure virtual meetings or other client communications.

We may update the technical and security controls used with our document-transfer environment as technology, security practices and business requirements evolve.

11. Access to Accounting Systems

The Cash Flow Whisperer does not routinely require direct access to a client's accounting system.

Where practical, we work from information and reports provided by the client's existing bookkeeping or accounting professionals. Our role is to build on their work, not to replace it.

Where direct access to an accounting system, such as QuickBooks Online, is necessary for a particular engagement and is specifically authorized by the client, access will be limited to what is reasonably required for that engagement.

12. Information Processed Outside Canada

Some third-party service providers we use may store or process information outside Canada.

As a result, personal information may be subject to the laws of the country in which it is stored or processed and may be accessible to courts, law enforcement or regulatory authorities in that jurisdiction.

We take reasonable steps to ensure that personal information transferred to service providers is handled with appropriate safeguards.

13. Disclosure of Personal Information

We do not sell or rent personal information.

We may disclose personal information when reasonably necessary for the purposes described in this Privacy Policy, including to:

service providers acting on our behalf;

professional advisors, such as lawyers, accountants, insurers or other advisors, where reasonably necessary;

payment processors or financial institutions where necessary to complete a transaction;

parties involved in a business transaction, such as a sale, restructuring, merger or acquisition, subject to applicable privacy requirements; or

government authorities, courts, regulators or law enforcement where required or permitted by law.

We will not disclose personal information for an unrelated purpose without appropriate consent unless the disclosure is otherwise authorized or required by law.

14. Confidentiality of Business and Financial Information

Information you provide to The Cash Flow Whisperer in connection with a consultation, Financial Assessment or advisory engagement may include confidential business information.

We treat such information as confidential and use it only for the purposes for which it was provided, subject to this Privacy Policy and applicable law.

We do not publish client financial information or use identifiable client information as a case study, testimonial or marketing example without appropriate permission.

15. Security

We use reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the personal information we hold.

These safeguards may include:

access controls;

authentication measures;

restricted access to personal information;

secure document-transfer systems;

secure communication systems;

appropriate security configurations;

secure disposal practices; and

procedures for responding to privacy and security incidents.

No method of transmitting or storing information electronically can be guaranteed to be completely secure. However, we take reasonable measures to reduce the risk of loss, unauthorized access, disclosure, copying, use or modification.

16. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to provide services, to maintain appropriate business and financial records, to resolve disputes, to enforce agreements, or to satisfy legal, regulatory, insurance or accounting requirements.

Different categories of information may therefore be retained for different periods.

When personal information is no longer reasonably required, we will take reasonable steps to securely destroy, delete or anonymize it, subject to applicable legal or regulatory requirements.

17. Accessing and Correcting Your Personal Information

Subject to applicable law, you may request access to personal information we hold about you.

You may also request correction of information that is inaccurate or incomplete.

A request should be made in writing to [email protected] and should provide enough information for us to identify the information being requested.

We may need to verify your identity before responding to a request.

We will respond within the time required by applicable privacy law, subject to permitted extensions or exceptions.

18. Withdrawal of Consent

Where we rely on your consent to collect, use or disclose personal information, you may withdraw that consent by contacting us at [email protected].

The withdrawal of consent does not affect the lawfulness of processing that occurred before consent was withdrawn.

There may be circumstances in which we are required or permitted by law to retain or use certain information despite a withdrawal of consent.

19. Privacy Complaints

If you have a concern about how we have collected, used, disclosed or protected your personal information, please contact us first so that we can investigate and attempt to resolve the concern.

Privacy Contact: Dagmar L.
Email: [email protected]

If you are not satisfied with our response, you may have the right to make a complaint to the applicable privacy regulator.

For individuals in British Columbia, this may include the Office of the Information and Privacy Commissioner for British Columbia.

For matters subject to federal privacy legislation, this may include the Office of the Privacy Commissioner of Canada.

20. Privacy Breaches

We maintain procedures for responding to suspected privacy and security incidents.

Where applicable privacy law requires notification or reporting of a breach, we will take the required steps.

21. Children's Privacy

Our services are intended for adults and business owners and are not directed toward children.

We do not knowingly collect personal information from children where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to us, please contact us so that we can review the circumstances and take appropriate action.

22. Privacy Rights for Individuals in the European Economic Area and United Kingdom

The Cash Flow Whisperer is based in Canada and primarily provides services to businesses in Canada.

However, European privacy laws, including the General Data Protection Regulation (GDPR), may apply in certain circumstances, including where we intentionally offer services to individuals located in the European Economic Area or otherwise become subject to those laws.

Where GDPR applies, we will process personal data in accordance with applicable GDPR requirements.

Depending on the circumstances, individuals may have rights including:

the right to be informed about the collection and use of personal data;

the right of access;

the right to rectification;

the right to erasure;

the right to restriction of processing;

the right to data portability;

the right to object to certain processing; and

rights relating to certain automated decision-making and profiling.

The availability of these rights depends on the circumstances and applicable law and is subject to applicable exceptions and limitations.

Where GDPR requires a specific legal basis for processing, the applicable legal basis will depend on the particular processing activity. This may include consent, performance of a contract or steps requested before entering into a contract, compliance with a legal obligation, or another lawful basis recognized by GDPR.

Where personal data is transferred outside the European Economic Area, we will use a transfer mechanism permitted by applicable law where required.

Individuals who believe GDPR applies to the processing of their personal data may contact us using the privacy contact information provided in this Privacy Policy.

23. Third-Party Websites

Our website, emails or other communications may contain links to websites or services operated by third parties.

We are not responsible for the privacy practices, security or content of third-party websites.

We encourage you to review the privacy policies of those websites before providing personal information.

24. Changes to This Privacy Policy

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

The current version will be identified by its Effective Date and will be made available through our website.

If we make a material change to the way we collect, use or disclose personal information, we will take reasonable steps to provide notice where required by law.

25. Contact Us

If you have questions about this Privacy Policy, wish to request access to or correction of your personal information, wish to withdraw consent, or have a privacy concern, please contact:

The Cash Flow Whisperer
A division of 0795163 B.C. Ltd.

Privacy Contact: Dagmar L.
Email: [email protected]
Location: British Columbia, Canada

Effective Date: September 18, 2026