Privacy Policy

Last updated: 2026-08-29

1. Who We Are

Initiative Avantage ("we," "us," "our") is a nonprofit based in Montreal, Quebec. We are setting up a free, virtual tax preparation service (our "Tax Clinic"), which we plan to operate under the Canada Revenue Agency's Community Volunteer Income Tax Program, offered in Quebec as the Income Tax Assistance – Volunteer Program (ITAVP), a joint program between the CRA and Revenu Québec. This policy explains how we currently handle personal information through our website, our Quick Eligibility Check, and our appointment booking system, and how we plan to handle information once the Tax Clinic launches.

2. Person Responsible for the Protection of Personal Information

Asley Lopez Robleto, director and the organization's privacy officer, reachable at asleyrobleto@gmail.com, is responsible for ensuring compliance with this policy and with applicable privacy law. Questions, concerns, or complaints about how we handle personal information can be directed to this person.

3. What Information We Collect

Quick Eligibility Check

The eligibility check (household situation, dependants, income, and tax-situation questions) runs entirely in your browser. We do not store, transmit to our servers, or retain your answers. Once you close or leave the page, this information is gone.

Appointment Booking

If you proceed to book an appointment, you'll be asked to provide information such as your name, email address, and preferred appointment time. This is collected and stored by our scheduling provider, Cal.com (see Section 4).

Tax Clinic Services (Planned — Not Yet Active)

Our Tax Clinic has not launched yet. This section describes how we plan to handle your information once it does, and will be reviewed and confirmed before the program goes live.

Our Tax Clinic will be entirely virtual. When it launches, here is our plan:

• What we'll ask about: to prepare your federal and Quebec income tax and benefit returns, a volunteer will need identifying information (full name, date of birth, address, marital and family status, your Social Insurance Number), and details from your income slips, receipts, and dependants, if applicable.
• How we plan to collect it: before your appointment, you'll upload your tax documents through a secure, restricted-access folder in Google Drive, using our Google Workspace for Nonprofits account, with a separate folder per client and an expiring link. We'll ask that documents be uploaded at least 48 hours before your appointment, so your volunteer can review everything beforehand. Please do not email your documents to us directly — email is not a secure channel for this kind of information.
• Your appointment: appointments are held over Google Meet. We do not record these calls.
• Banking information: if you'd like your refund direct-deposited, this is entered directly into the tax software during your appointment, or drawn from information the CRA already has on file, rather than collected and stored separately by us.
• Before your return is filed: your volunteer will review the completed return with you so you can confirm the information is correct before it's submitted.
• Consent: before we prepare your return, you will be asked to sign the CRA's official Taxpayer Authorization form (electronically, given our virtual format), which authorizes a specific, named volunteer to prepare and file your return under the CVITP/ITAVP and confirms your consent to that filing. We will also ask you to acknowledge this Privacy Policy beforehand, separately from that federal form, given the sensitivity of the information involved.
• Software: we plan to use UFile CVITP, the software the CRA provides free to registered CVITP/ITAVP volunteers each tax season. It is password-protected.
• Who can access this information: access is limited to the volunteer assigned to your file and, as part of our quality-review process, one additional trained volunteer or coordinator who reviews your return before it is filed. All volunteers are registered with the CVITP/ITAVP and have signed the program's Volunteer Agreement, which includes confidentiality commitments. Any volunteer using the CRA's Auto-fill my return service will also have provided our Organization with a valid police record check, per CRA requirements.

3A. Cookies and Similar Technologies

We use cookies and similar technologies for these purposes:

• Essential (necessary) cookies: to enable our appointment booking (Cal.com embed) and to store necessary technical preferences so booking functions correctly.
• Bot protection: Google reCAPTCHA runs only on our appointment booking page and our contact page — it is not used elsewhere on the site.
• Consent preferences cookie: to record your cookie consent choices for this website (so we do not ask you repeatedly).
• Analytics (optional): we use Ahrefs Web Analytics to understand overall site traffic and improve the website. This specific product does not use cookies, but it does collect your IP address (used to derive an approximate location), the pages you view, and your device/browser type — this is still personal information under Quebec law, so it only runs once you've given consent, the same as a cookie-based analytics tool would require.

We do not use cookies or tracking technologies for advertising purposes.

4. Third-Party Service Providers

We rely on the following third parties to operate our booking system and website, and, once our Tax Clinic launches, to prepare tax returns and host virtual appointments. Each operates under its own privacy policy, and each may process information outside Quebec or Canada:

Because some of these providers may store or process information outside Quebec, your information may be subject to the laws of other jurisdictions, which may differ from Quebec's privacy laws. Before relying on any provider to process personal information outside Quebec, we assess whether they offer a level of protection for personal information that is equivalent to what is required under Quebec law, taking into account the sensitivity of the information, the purposes for which it is used, and the protective measures in place.

5. Why We Collect This Information

We use, or plan to use, the information described above solely to:

• Determine, at your discretion and in your own browser, whether you may be eligible for our free tax clinic services;
• Schedule and manage appointments for tax clinic services;
• Understand overall website traffic and improve the site;
• Prevent automated or fraudulent use of our booking and contact forms;
• Prepare and electronically file income tax and benefit returns for eligible individuals under the CVITP/ITAVP, once launched, at your request and with your signed authorization.

We do not sell personal information, use it for advertising, or share it with anyone beyond the service providers listed above and the CRA/Revenu Québec, as required to file your return.

6. Data Retention and Destruction

• Eligibility check answers: never stored, it exist only in your browser session.
• Booking information: retained by Cal.com according to their retention practices, and by us only for as long as needed to provide the appointment. After that period, we delete any records we hold.
• Website analytics: retained by Ahrefs according to their own retention practices; we do not separately store this data ourselves.
• Tax clinic information (planned): documents you upload before your appointment, and the information entered into UFile CVITP to prepare your return, will be deleted within 48 hours after your return has been transmitted and accepted by the CRA and Revenu Québec. Once accepted, the CRA and Revenu Québec hold the official record, so we do not need to keep a separate copy.

7. Your Rights

Under Quebec privacy law, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate information;
• Withdraw consent to the collection or use of your information, subject to legal or contractual restrictions;
• Request that we cease disseminating your information or de-index it, in certain circumstances;
• Request portability of your information, in certain circumstances.

To exercise any of these rights, contact our privacy officer, asleyrobleto@gmail.com. We will respond within the time required by law.

8. Data Breach Notification

If we become aware of a confidentiality incident that creates a risk of serious injury to you, we will notify you and the Commission d'accès à l'information (CAI) as required by law.

9. Complaints

If you're not satisfied with how we've handled your personal information, you may contact our privacy officer, asleyrobleto@gmail.com, or file a complaint with the Commission d'accès à l'information du Québec: https://www.cai.gouv.qc.ca/

10. Changes to This Policy

We may update this policy from time to time, including before our Tax Clinic launches, to confirm the details currently marked "planned" or "still to confirm" above. The "Last updated" date at the top reflects the most recent revision.