Privacy Policy

This Privacy Policy explains how [COMPANY_LEGAL_NAME] ("we", "us") handles personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec's Act respecting the protection of personal information in the private sector (Law 25 / Bill 64).

1. Accountability

We are accountable for personal information under our custody or control. Our Privacy Officer is responsible for our compliance with this Policy and PIPEDA. Contact: [DPO_EMAIL].

2. Information We Collect

• Account information: name, email address, province of residence, password hash.
• Payment information: transaction reference and last-four card digits (full card data is processed by our PCI-DSS-compliant payment provider).
• Usage information: channels and content viewed, connection times, and device type.
• Communications: WhatsApp and email correspondence.
• Technical information: IP address, browser type, operating system.

3. Purposes of Collection

We collect personal information only for the following purposes:

• Providing and administering your Subscription;
• Processing payments and detecting fraud;
• Responding to support inquiries;
• Sending service communications (renewal notices, outage alerts);
• Sending commercial electronic messages (with consent, in compliance with CASL);
• Complying with legal obligations;
• Improving the Service through aggregated analytics.

4. Consent

We obtain express or implied consent before collecting, using, or disclosing personal information, except where permitted or required by law. Consent is obtained at account registration. You may withdraw consent at any time (subject to legal and contractual restrictions) by contacting [DPO_EMAIL]. Withdrawal of consent may result in the inability to provide the Service.

5. Disclosure of Information

We do not sell personal information. We disclose it only to:

• Payment processors under written contractual obligations;
• Cloud infrastructure providers under data processing agreements;
• Law enforcement where required by Canadian law;
• Professional advisers under confidentiality obligations.

Where personal information is transferred outside Canada, we ensure comparable protection is provided as required by PIPEDA Principle 4.1.3.

6. Retention

We retain personal information only as long as necessary to fulfil the identified purposes or as required by law. Account data is kept for the duration of your Subscription plus 7 years. Payment records are kept 7 years for tax compliance. Usage logs are retained 13 months.

7. Your Rights

Under PIPEDA, you have the right to:

• Access the personal information we hold about you;
• Challenge the accuracy and completeness of your information and request correction;
• Withdraw consent to collection, use, or disclosure (subject to legal limitations);
• Complain to the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca.

Quebec residents also have additional rights under Law 25, including the right to data portability and to request de-indexation. Submit requests to [DPO_EMAIL]; we will respond within 30 days.

8. Safeguards

We use technical and organisational safeguards including TLS encryption, access controls, data minimisation, and regular security assessments to protect personal information against loss, theft, and unauthorised access. In the event of a material breach, we will notify the OPC and affected individuals as required by PIPEDA's mandatory breach reporting requirements.

9. CASL and Commercial Electronic Messages

We send commercial electronic messages (CEMs) only with your express or implied consent, in compliance with Canada's Anti-Spam Legislation (CASL). Each CEM includes a functional unsubscribe mechanism. To unsubscribe at any time, click the unsubscribe link in any email or contact [CUSTOMER_SERVICE_EMAIL]. Unsubscribe requests are processed within 10 business days.

10. Contact

For privacy inquiries or to exercise your rights, contact our Privacy Officer at [DPO_EMAIL] or write to [COMPANY_ADDRESS]. If you are not satisfied with our response, you may file a complaint with the OPC at priv.gc.ca/en/report-a-concern, 1-800-282-1376.