How to File a GST/HST Return in Canada: NETFILE Walkthrough, Access Code & Deadlines

Filing your GST/HST return in Canada? A 2026 walkthrough: GST/HST NETFILE step-by-step, the 4-digit access code (and how to get a new one), exact filing deadlines by frequency — including the October 31 quarterly deadline — input tax credits, and the mistakes that trigger penalties.

Applies in: across Canada

The short answer

File with GST/HST NETFILE — it is free, needs no CRA login, and takes about fifteen minutes. You need three things: your business number, the 4-digit access code the CRA printed on your return package (or shows in your CRA account), and the reporting period's from/to dates. Enter your amounts, review, check the certification box, submit, and keep the 6-digit confirmation number. You must file every period even when you owe nothing, and filing is separate from paying.

When your GST/HST return is due

Your next deadline depends on your reporting period. Monthly and quarterly filers file and pay one month after the period ends. Annual filers follow the table below. Confirm your expected returns and due dates in CRA My Business Account — the CRA's reporting requirements and deadlines page sets out the same deadlines by frequency. That list is the final word when it disagrees with your memory. When a due date lands on a weekend or public holiday, the CRA treats payment as on time if it arrives the next business day. The nil-return rule still applies. If a period was zero, file the nil return rather than skipping the period. Bank-initiated payments need their own transit time, so start the payment a few business days before the due date rather than on the day.

How often you file

The CRA assigns your reporting period from your annual taxable supplies, rechecked against the previous fiscal year:

Annual taxable suppliesYou fileOptional
$1,500,000 or lessAnnuallyCan elect quarterly or monthly
Over $1.5M to $6MQuarterlyCan elect monthly
Over $6MMonthlyNone

Elections go through the CRA's File an election service or Form GST20. New registrants pick based on estimated supplies. One honest reason to file more often than assigned: refund timing. ITC claimants who spend more tax than they collect get their money back at the frequency they file — monthly filing returns a $5,000/month refund position across the year instead of one cheque twelve months later.

Your filing and payment deadlines

FrequencyFile byPay by
Monthly1 month after the period ends (January period → February 28)Same day
Quarterly1 month after the quarter ends (Q1 Jan–Mar → April 30)Same day
Annual (corporations and others)3 months after fiscal year-end (Dec 31 year-end → March 31)Same day
Annual (individuals with a Dec 31 year-end and business income for the year)June 15April 30

The individual exception mirrors income tax: sole proprietors with business income for the year get extra time to file, not extra time to pay. With no business income for the year, an individual filer's deadline is three months after year-end for both filing and payment. Interest starts on any unpaid balance May 1 even though your return is not due until June 15. When a due date lands on a weekend or public holiday, the CRA treats payment as on time if it arrives the next business day.

How to change your GST filing frequency

Your filing frequency is your reporting period, and the CRA assigns it from your annual taxable supplies. At $1,500,000 or less you file annually. Over $1,500,000 and up to $6,000,000 you file quarterly. Over $6,000,000 you file monthly. Charities and listed financial institutions file annually. The count behind those thresholds is taxable supplies made in Canada in your previous fiscal year, including zero-rated supplies and the supplies of your associates. It leaves out supplies made outside Canada, zero-rated exports, zero-rated financial services, exempt supplies, sales of capital real property, and goodwill.

An assigned period is a floor, not a lock. You can elect to file more often than assigned. An annual filer can move to quarterly or monthly reporting. A quarterly filer can move to monthly. Monthly filers have no shorter period to move to. The usual reason to file more often is a refund position. If you pay more GST/HST on purchases than you collect on sales, a monthly return brings that money back twelve times a year instead of once.

To make the change, file an election with the CRA. Online, sign in to CRA My Business Account, or Represent a Client if an accountant files for you, and use the File an election service to submit the GST20 election. On paper, complete Form GST20, Election for GST/HST Reporting Period, and mail it to your tax centre. Keep a copy of the submission with your tax records. Once the CRA processes the election, your account shows the new reporting periods and their due dates, so check the expected-returns list before your next filing date rather than assuming the old calendar still applies.

Going the other way is harder. You cannot simply decide to file less often because a year was slow. A monthly or quarterly filer can elect a less frequent period only after 12 months, and only if taxable supplies have fallen below the threshold for the assigned period. Nothing adjusts on its own. If your sales fall below a threshold and you file no election, the CRA keeps your existing reporting period in place. Plan a change around a period boundary, file the election first, and file every return that falls due under the old period until the new one starts.

Use the CRA's working copy before you file

The CRA's Instructions for preparing a GST/HST return page publishes a printer-friendly working copy of the GST/HST return (PDF, 116 KB) for exactly this: do the line-by-line math on paper first, check it, then key the numbers into NETFILE. The working copy is a calculation aid, not a form you send — the CRA says not to mail it back. Why it matters for NETFILE filers: NETFILE sessions expire after 35 minutes of inactivity and nothing is saved until you certify, so walking in with completed line totals (total sales on line 101, tax collected on line 103, adjustments on line 104) turns the online session into a copy-and-submit job instead of a scratch-paper scramble. Quebec-administered accounts: the working-copy shortcut still helps, but you file with Revenu Québec, not NETFILE.

The three ways to file online

1. GST/HST NETFILE — the direct form. Free, no CRA account needed. The CRA's own filing walkthrough runs: enter your business number, access code, and reporting period from/to dates → select options (including the nil-return checkbox and email-notification opt-in) → enter amounts → review → check the certification box → submit. The session expires after 35 minutes of inactivity and nothing is saved if you walk away before certifying. The 6-digit confirmation number after submit means the return is accepted for processing.

You cannot use NETFILE when: you do not have an access code, you need to file an election with the return, your account is administered by Revenu Québec, or the rebate you are claiming is outside the short approved list (GST66, GST189 — Ontario First Nations point-of-sale relief, reason code 23 only — and GST190). File through My Business Account or on paper instead.

2. CRA My Business Account. Once you have the login, this is the most convenient route: the "File a return" link files without an access code, and the same portal holds your balance, payment history, direct-deposit enrolment, pre-authorized debit, and return adjustments (through "Adjust a return" in My Business Account, or by letter to your tax centre).

3. Accounting software / EDI. Cloud accounting platforms (QuickBooks Online, Xero) prepare the return from your books and generate the CRA submission; accountants file through the Represent a Client portal. Useful once the return has more than a handful of lines — and it means your province-level rate split (the place-of-supply numbers) reconciles before you submit, not after.

Paper is the exception, not a fourth way. For reporting periods beginning on or after January 1, 2024, all GST/HST registrants other than charities and selected listed financial institutions must file electronically. Filing on paper when the mandate applies draws a penalty; a registrant who genuinely cannot file electronically can ask the CRA for an exemption in writing.

The access code

The 4-digit GST/HST access code is printed on the electronic filing information package (Form GST34-3) or the personalized return (Form GST34-2) the CRA mailed you, and it has been shown under your GST/HST details in your CRA account since October 2025. Lost it? Change it online at Get a GST/HST access code (works if you filed a return in the last 3 years) or call CRA business enquiries at 1-800-959-5525. Treat it like a password — anyone with your business number, access code, and period dates can file in your name.

Input tax credits on the return

ITCs are the return's reward side: the GST/HST you paid on business purchases reduces what you remit, or comes back as a refund. Three discipline rules from the CRA's own playbook:

  • Documents on file. The CRA's input tax credits page sets documentary requirements by purchase size: under $100 needs the supplier name, date, and total; $100 or more adds the GST/HST charged — or a statement that the total includes it at the applicable rate — the supplier's registration number, and, where an invoice mixes taxable and exempt supplies, an indication of each supply's status; $500 or more adds your name, a description, and payment terms. The single biggest ITC error is a missing supplier GST/HST number on invoices of $100 or more — the CRA can deny the ITC for it. You do not send receipts with an electronic return; you keep them for six years from the end of the year they relate to.
  • Claim window. Most registrants have four years from the period the credit could first be claimed. Listed financial institutions get two years, and so do businesses whose threshold amounts exceed $6 million in both the current and the previous fiscal year — unless at least 90% of their supplies other than financial services were taxable in either of the two preceding years, which restores four. Inside the window, claim forgotten ITCs on a later return — outside it, they are gone.
  • Watch the specials. Meals and entertainment get only 50% of the GST/HST paid; passenger-vehicle ITCs are capped at the tax on the prescribed cost ceiling; club dues are out. Quick Method filers claim ITCs on almost nothing — that is the method's trade-off.

Quarterly instalments (annual filers)

If you file annually and your net tax was at least $3,000 last year and is estimated at $3,000 or more this year, you pay quarterly instalments: due one month after each fiscal quarter end (a fiscal quarter ending June 30 pays by July 31). Instalments are usually one quarter of last year's net tax each; you can base them on a lower current-year estimate, with instalment interest charged on any shortfall — Guide RC4022 sets out the test and the calculation. The $3,000 threshold mirrors income tax's instalment trigger. Instalments are payments only, not returns — the return still comes once a year. Miss the trigger or miss an instalment and interest accrues; the instalment payments net against the final balance.

If you file late

The penalty formula: 1% of the amount owing, plus 0.25% for each full month the return is late, up to 12 months — plus interest on the unpaid balance. Three points the CRA's GST/HST filing penalties page makes plain:

  1. Owe nothing, owe no penalty. A $0 balance or a refund position carries no late-filing penalty — but a late refund return still delays your money.
  2. File even when you cannot pay. An on-time return with an unpaid balance skips the penalty entirely; only interest runs. The deadline that bites is the filing deadline, never the payment.
  3. The penalty is per month, so early correction matters. One month late costs 1.25%; six months costs 2.5%. Fixing a missed return this week is always cheaper than next month.

For the full picture — worked cost examples, the $250 demand-to-file penalty, and the recovery sequence — see What Happens If You File Your GST/HST Return Late in Canada.

Quebec is different

If your GST/HST account is administered by Revenu Québec, you do not file with the CRA at all — your returns (GST/HST and QST) go through Revenu Québec (clicSÉQUR). NETFILE's eligibility list explicitly excludes Quebec-administered accounts, and Guide RC4022 states the underlying rule: in Quebec, Revenu Québec generally administers the GST/HST, and a business physically located in Quebec files its returns with Revenu Québec using its forms, unless it is a selected listed financial institution. Registering with the CRA when you carry on business in Quebec is the mistake our registration guide warns about: it leaves the QST half undone.

Five mistakes that cost real money

Treating the return and the payment as one act. Filing without paying is legal and penalty-free; paying without filing leaves an overdue return. Do both, but never skip the return because the cash is tight.

Forgetting the nil return. Zero-balance periods still need filing. NETFILE's nil checkbox takes seconds; a missed nil return creates a gap the CRA chases.

Claiming ITCs without the paperwork. The receipt does not travel with the return — but if the CRA asks and you do not have the supplier's GST/HST number on a $100+ invoice, the ITC is denied. Rebuild the document file every quarter, not every audit.

Forgetting that ITCs expire. Four years feels generous until the supplier closes or the receipt lives in a box from 2022. Unclaimed credits from old periods are money left on the table; claim them on the next return.

Re-filing instead of adjusting. A second return for the same period does not fix the first — it creates a conflict. Adjust through My Business Account ("Adjust a return") or by mailing a signed letter to your tax centre.

Related guides

Filing your GST/HST return, in six steps

  1. Know your reporting periodThe CRA assigns your frequency from your taxable supplies: $1.5M or less files annually, $1.5M–$6M quarterly, over $6M monthly. You can choose to file more often (via the File an election service or Form GST20) but not less.
  2. Total the tax you collectedAdd up the GST/HST you charged customers during the period, at the right rate for each customer's province — the place-of-supply rules decide the rate, not your address.
  3. Total your input tax creditsAdd up the GST/HST you paid on business purchases for the same period. You need the supplier's invoices on file; you do not send receipts with the return, but the CRA can ask for them.
  4. Open GST/HST NETFILEFree on the CRA's site. You need your business number, the 4-digit access code the CRA issued with your return package, and the reporting period's from/to dates. Inside CRA My Business Account you file without the access code.
  5. Enter, review, certify, submitEnter your amounts, review the return, check the certification box, and submit. You get a 6-digit confirmation number — accepted for processing means filed. Keep that number with your records.
  6. Pay any balance by the deadlineFiling and paying are separate acts. Pay through CRA My Payment, online banking, or pre-authorized debit by the due date for your frequency — one month after period end for monthly/quarterly filers.

GST/HST filing frequency and deadlines (2026)

Monthly filer — over $6M annual taxable suppliesFile and pay 1 month after each period ends
Quarterly filer — $1.5M to $6MFile and pay 1 month after each quarter ends
Annual filer — corporation / otherFile and pay 3 months after fiscal year-end
Annual filer — individual with Dec 31 year-endPay April 30, file by June 15
Annual filer + net tax ≥ $3,000Quarterly instalments: 1 month after each fiscal quarter end
Deadline on a weekend or public holidayRolls to the next business day

Frequency is assigned from the previous fiscal year's taxable supplies. File more often if you like (Form GST20 election); you cannot file less often than assigned. Net tax ≥ $3,000 for annual filers triggers quarterly instalments.

Questions people ask

Do I have to file a GST/HST return if I collected no tax this period?

Yes. You must file every return for every reporting period, even when every field is zero. NETFILE has an explicit 'I am filing a nil return (all fields are $0)' checkbox to speed that up. Skipping periods you owe nothing on is still late filing, and it creates gaps in your account the CRA will chase.

Can I file my GST/HST return without the access code?

Yes, two ways: file through CRA My Business Account (the 'File a return' link files without a code), or get a new code — it is shown under your GST/HST details in your CRA account, you can change it online if you filed a return in the last 3 years, or call the CRA at 1-800-959-5525. The standalone NETFILE form needs the 4-digit code; your account login substitutes for it inside My Business Account.

When is my GST/HST return due?

Monthly and quarterly filers: one month after the period ends. Annual filers: three months after fiscal year-end — except individuals (sole proprietors) with a December 31 year-end who had business income for the year, who pay by April 30 and file by June 15 — with no business income for the year, the three-month deadline applies instead. A deadline that lands on a weekend or public holiday rolls to the next business day.

What happens if I file my GST/HST return late?

If you owe a balance: a penalty of 1% of the amount owing plus 0.25% for each full month late, up to 12 months, plus interest on the unpaid balance. If you owe $0 or are due a refund there is no penalty, but a late refund return delays your money. File on time even when you cannot pay in full — an on-time return with an unpaid balance skips the late-filing penalty entirely and you only carry interest until you settle up.

Can I change how often I file?

Yes, to a shorter period. Use the CRA's File an election service or Form GST20 to move from annual to quarterly or monthly, or from quarterly to monthly. Why would you? Refund claimers file more often to get their money back sooner — a business owed $5,000 in ITC refunds a month gets $60,000 back across a year on monthly filing instead of one year-end cheque.

How to change your GST filing frequency from annual to quarterly or monthly?

File an election. In CRA My Business Account or Represent a Client, use the File an election service and pick GST20, Election for GST/HST Reporting Period. On paper, fill out Form GST20 and mail it to your tax centre. An annual filer can elect quarterly or monthly reporting, and a quarterly filer can elect monthly. The new period takes effect at the start of a reporting period, and the CRA shows your updated filing obligations in your account once the election is processed.

Can I switch back to filing less often if my sales drop?

Only in narrow cases, and never automatically. If you were assigned monthly or quarterly filing, you can elect a less frequent period only after 12 months and only if your taxable supplies have fallen below the threshold for your assigned period. If your sales drop and you file no election, you keep the period you already have. Electing to file more often is the easy direction. Coming back down takes the 12-month wait plus the lower sales to support it.

I made a mistake on a filed return. How do I fix it?

Confirm or change it rather than re-filing. In My Business Account use the 'Adjust a return' option, or mail a signed letter to your tax centre with the corrected amounts. Do not file a second return for the same period — an adjustment request changes the original.

How long do I have to claim input tax credits?

Most registrants have four years — the deadline is the due date of the return for the last reporting period ending within four years after the period the credit could first be claimed. Listed financial institutions get two years, and so do businesses whose threshold amounts exceed $6 million in both the current and the previous fiscal years, subject to a 90%-taxable-supplies exception (charities keep four). Missed ITCs are not lost if you are inside the window: claim them on a later return. Outside it, they are gone.

Do Quebec businesses file with the CRA?

No. If your account is administered by Revenu Québec, you file your GST/HST (and QST) returns with Revenu Québec — GST/HST NETFILE explicitly excludes Quebec-administered accounts. You also cannot use NETFILE when you need to file an election with the return, or when the rebate you are claiming is not on NETFILE's short approved list (only GST66, GST189 (Ontario First Nations point-of-sale relief, reason code 23 only), and GST190 can be claimed during filing).

Do I need to pay when I file, or are they separate?

They are separate acts, with the same deadline. Filing tells the CRA what you owe; paying is its own step — CRA My Payment, online banking bill payment, pre-authorized debit in your CRA account, or in person at your financial institution with a remittance voucher. Filing without paying is legal and avoids the late-filing penalty; paying without filing leaves the return overdue.

October 31, 2026 is my GST/HST deadline — what does the weekend rule change?

Only the calendar date. October 31, 2026 falls on a Saturday, so the CRA's weekend rule rolls your filing and payment deadlines to Monday, November 2, 2026 — the same nil-return, frequency, and penalty rules apply to the rolled date. Treat the roll as breathing room for the payment to clear, not as an extension: initiate bank payments a few business days before November 2 rather than on the day itself.

I am an e-commerce seller with buyers in several provinces. Anything special?

The filing mechanics are the same, but the numbers you enter are harder: you charged different rates by customer province under the place-of-supply rules, so your return totals blend 5%, 13%, 14%, and 15% lines. Keep province-level sales records so the return is a summary, not a reconstruction. If you are registered under the simplified GST/HST regime, you file the simplified return using GST/HST NETFILE.

What must a GST/HST invoice show?

The tiers run on the invoice total, and they exist so your customer can claim input tax credits: under $100, your business or trading name, the date, and the total; at $100 or more, add the GST/HST charged — or a statement that the total includes it — and your GST/HST registration number; at $500 or more, add the buyer's name, a description of each supply, and the payment terms. Show HST as one combined line, never split into federal and provincial parts. The worked version, including the Quebec difference, is in [How to Charge GST/HST in Canada](/guides/how-to-charge-gst-hst-in-canada/).

Sources

  • CRA, Using the online GST/HST NETFILE form — what to have ready (business number, 4-digit access code, reporting period from and to dates); the nil-return checkbox ("I am filing a nil return (all fields are $0)"); the session expires after 35 minutes of inactivity and nothing is saved if you end the session before confirming; certification and submit are the last steps; a 6-digit confirmation number means the return was accepted for processing; and what the form cannot do — file without an access code, file elections, file for an account administered by Revenu Québec, or claim a rebate that is not on its list. The only rebates that can be claimed with the return are GST66, GST189 (Ontario First Nations point-of-sale relief, reason code 23 only), and GST190.
  • CRA, Get a GST/HST access code — the 4-digit code stays the same for every filing period unless you change it; no code is needed when filing in a CRA account, through a participating Canadian financial institution, or by mail; a code is needed for the NETFILE form outside an account, for Internet File Transfer, and for TELEFILE; since October 2025 owners can find the code in their CRA account (business account only, through GST/HST and the View return details button; representatives cannot see it); the code can be changed online if a return was filed for a reporting period ending within the last 3 years; and the phone route is 1-800-959-5525.
  • CRA, GST/HST Memorandum 7-5, Electronic Filing and Payment — May 2025; mandatory electronic filing for reporting periods beginning on or after January 1, 2024, for all registrants other than selected listed financial institutions and charities; and paragraph 18 — the access code is printed on the electronic filing information package (Form GST34-3) or the personalized return (Form GST34-2 or Form RC7200), and no code is needed when filing through "File a return" in My Business Account.
  • CRA, Excise and GST/HST News No. 119 — April 2025; the mandatory electronic filing change, and the CRA's statement that there are many free and accessible ways to file electronically, including GST/HST NETFILE and My Business Account.
  • CRA, Reporting requirements and deadlines — monthly and quarterly deadlines are one month after the period ends; annual deadlines are three months after fiscal year-end; the individual exception (sole proprietor, December 31 year-end, and business income for the year) pays by April 30 and files by June 15, and an individual with no business income uses the three-month deadline; listed financial institutions file and pay six months after year-end unless they are listed only because of a section 150 election; a due date on a Saturday, Sunday, or CRA-recognized public holiday is on time if received the next business day; a return is due for every reporting period, even with no business activity; and mandatory electronic filing, with a penalty for paper filing and a written exemption request route.
  • CRA, Make changes to your GST/HST account — assigned reporting periods rest on annual taxable supplies made in Canada in the preceding fiscal year ($1,500,000 or less files annually, over $1,500,000 to $6,000,000 quarterly, over $6,000,000 monthly; charities and listed financial institutions file annually); the count includes zero-rated supplies and associates' supplies and leaves out supplies made outside Canada, zero-rated exports and financial services, exempt supplies, sales of capital real property, and goodwill; a Form GST20 election can move a filer to a more frequent period; a less frequent period can be elected only after 12 months when taxable supplies have fallen below the assigned threshold; and the period never adjusts on its own.
  • CRA, Form GST20, Election for GST/HST Reporting Period — use this form if you want to change the reporting period for your GST/HST return.
  • CRA, Instructions for preparing a GST/HST return — the printer-friendly working copy of the return (PDF, 116 KB) and the warning not to mail it; line 101 is total sales and other revenues, line 103 is GST/HST collected or collectible, line 104 is adjustments to be added to the net tax, line 105 is the total, and line 109 is net tax.
  • CRA, Input tax credits — the documentary tiers: every tier needs the supplier's business or trading name, the invoice date (or the date the tax is paid or payable), and the total; $100 or more adds an indication of the GST/HST charged or that the total includes it at the applicable rate, the status of each supply on a mixed taxable-and-exempt invoice, and the supplier's registration number; $500 or more adds the buyer's name, a brief description, and the payment terms. The same page gives the claim windows (four years for most registrants and charities; two years for listed financial institutions and for persons over the $6 million threshold in both years, with a 90%-taxable-supplies exception) and the Quick Method rule (no ITCs on operating expenses, but ITCs may be claimed on capital purchases such as land, computers, and vehicles). The $100 and $500 thresholds replaced $30 and $150 on April 20, 2021, per CRA, Excise and GST/HST News No. 118; the 2012 Memorandum 8.4 still prints the former tiers and is not the source for the current figures.
  • CRA, GST/HST filing penalties — the late-filing penalty formula, 1% of the amount owing plus 25% of that 1% for each complete month overdue, to a maximum of 12 months; no late-filing penalty when $0 is owing or a refund is due; interest on overdue balances and late or insufficient instalments; the $100 and $250 failure-to-file-electronically penalties; the $250 demand-to-file penalty; and the 5% to 10% inaccurate-electronic-reporting penalty.
  • CRA, Guide RC4022, General Information for GST/HST Registrants — the instalment test (an annual filer whose net tax was $3,000 or more for the previous fiscal year and is $3,000 or more for the current fiscal year makes quarterly instalment payments, due within one month after each fiscal quarter, usually one quarter of the previous year's net tax, with a current-year estimate allowed and instalment interest on a shortfall); the Quebec administration rule (Revenu Québec generally administers the GST/HST in Quebec, and a business physically located in Quebec files with Revenu Québec on its forms unless it is a selected listed financial institution); and Form GST189, reason code 23, submitted electronically with the return on line 111.
  • CRA, What happens after you file — do not file a new return to fix a mistake; adjust through "Adjust a return" in My Business Account or Represent a Client, or send a signed letter to the tax centre with the business number and RT extension, the period, the corrected amount for each line, and a contact name and phone number; and most returns and refunds are processed within four weeks.
  • Revenu Québec, Claiming ITCs and ITRs — Quebec registrants claim input tax credits and input tax refunds when they file their GST/HST and QST returns for the period of the purchase; the general claim period is four years, two years for listed financial institutions and for persons with more than $6 million in taxable sales in each of the two preceding fiscal years; and Quick Method users generally cannot claim ITCs or ITRs on most purchases.
  • CRA, Form GST66, Application for GST/HST Public Service Bodies' Rebate and GST Self-Government Refund — use this form to claim the Public Service Bodies' rebate or the Self-government refund. The title is the CRA's own wording on the form page.
  • CRA, Form GST189, General Application for GST/HST Rebates — fill out this form to apply for a GST/HST rebate for one of the reasons listed in Part B of the form.
  • CRA, Form GST190, GST/HST New Housing Rebate Application for Houses Purchased from a Builder — the new housing rebate claim for a house, condominium unit, duplex, or co-operative housing share bought from a builder, where the house is the primary place of residence of the buyer or a relation and is not intended as a rental property.

Get new guides by email

One short email when a new Canadian startup guide publishes. No spam — unsubscribe anytime.

We use your address only for the newsletter. Privacy policy.