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BluOrbit

Privacy Policy

Draft pending legal review

DRAFT PENDING LEGAL REVIEW. Not legal advice. Not final. Items in [TO CONFIRM] brackets are facts the company must supply or confirm; nothing in brackets has been verified. Based on docs/persona/BluOrbit_Privacy_Policy_v1_0_DRAFT.md.

Last updated: [TO CONFIRM: date of publication]

1. Who we are

BluOrbit (bluorbit.ca) is operated by [TO CONFIRM: legal entity name, believed to be Implexus], [TO CONFIRM: registered address]. Privacy contact: [TO CONFIRM: name or title of the person responsible for privacy] at [TO CONFIRM: privacy email; hello@bluorbit.ca until set]. This policy follows Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial law, and Canada's Anti-Spam Legislation (CASL).

2. What we collect, and why

We collect the following. Each item has the purposes listed next to it. If we want to use something for a new purpose, we update this policy first.

InformationPurposes
Email address, name, company nameCreate and run your account; sign you in; send service messages; send marketing only with your consent
Profile answers you give Blu (entity type, province, industry, size, funding goals, grant history, revenue and headcount if you choose to share them)Match you to grants; draft applications using only facts you gave us; show your dashboard
Eligibility and demographic details you choose to shareMatch you to grants reserved for a group; stored only with your consent
Documents you uploadDraft and fill applications for you
Conversation content with BluAnswer you; remember the conversation; improve the service; investigate abuse and errors
Searches run, grants viewed and saved, pages visited, clicks and time on page ("behaviour")Operate the service; understand what is useful; improve matching and the product; plan features; measure marketing
IP addressSecurity and abuse prevention; rate limiting; estimate your approximate location; fraud checks
Approximate location (derived from IP address)Show relevant provincial and national grants; analytics
Device and browser type, operating system, screen size, languageMake the site work on your device; troubleshoot; analytics
Referrer (the page that sent you) and campaign tags in linksLearn which sources bring visitors; measure marketing
Cookies and session identifiersKeep you signed in; keep your conversation and free allowance; prevent abuse
Payment detailsHandled by Stripe. We receive your plan, payment status and the last digits of the card, not the full card number
Support messages and email delivery events (delivered, bounced, unsubscribed)Respond to you; keep our mailing list correct; meet CASL record-keeping
IP address and browser (user agent) at the moment you give or withdraw email consentKept as proof of consent under CASL
IP address of anonymous visitorsLimit how many free anonymous sessions one network can start per day (abuse prevention). [TO CONFIRM: retention period. Today the address is stored with the anonymous session record and is not deleted on a schedule.]

We collect all of the above that we are lawfully able to for these purposes, including for future platform uses that fit them. [TO CONFIRM WITH COUNSEL: whether broad "future uses" is acceptable under PIPEDA's purpose-limitation rule, and whether a cookie notice is needed.]

3. Consent

We ask for your consent in the chat before we analyse your conversation, and when you give your email. You can withdraw consent at any time; withdrawing does not undo processing already done. Declining some collection may limit features.

4. Who we share it with

We do not sell your personal information. We use these service providers (subprocessors) to run BluOrbit:

We also share when the law requires it, to protect rights and security, or in a business sale (subject to this policy). [TO CONFIRM: where each provider stores data; whether any data is outside Canada, and the PIPEDA transfer wording.]

5. Security and retention

We use encryption in transit, access controls and audit logging. Portal credentials are encrypted. No system is perfectly secure. We keep information only as long as needed for the purposes above or as the law requires; CASL consent records are generally kept three years. [TO CONFIRM: retention period for each item, including anonymous conversations and logs.]

6. Email (CASL)

We send marketing email only with your consent, and every such email has a working unsubscribe link and our identification and contact details. Service messages, such as receipts and trial-ending notices, are sent as part of the service. [TO CONFIRM: sender mailing address.]

7. Your rights

You may ask to see, correct or delete the personal information we hold about you, withdraw consent, and ask for an export. Write to the privacy contact above. You may also complain to the Office of the Privacy Commissioner of Canada. [TO CONFIRM: response time.]

8. Children

BluOrbit is not directed at children, and we do not knowingly collect their information. [TO CONFIRM: age.]

9. Changes

We will update this policy when our collection or purposes change, and tell you about material changes through the service or by email.