DRAFT v1.0 — FOR LEGAL REVIEW — NOT YET IN FORCE
This document is a working draft prepared for review by legal counsel. It has not been adopted and creates no obligations until published as final. Bracketed items [like this] are placeholders to be completed before publication.
Effective date: [●]
Last updated: [●]
1. Who we are
LeadQor is a business software platform — CRM, scheduling, financial tools, review management, SMS/voice/email communications, payments, and website building — operated by:
LeadQor Canada Inc. (incorporation pending — confirm final legal name and corporation number before publication)
[Street address]
[City], Ontario, Canada [Postal code]
Email: [privacy@leadqor.com]
Throughout this policy, "LeadQor," "we," "us," and "our" mean LeadQor Canada Inc.
2. Scope of this policy
A few things to know up front:
- LeadQor is a business-to-business (B2B) service. Our customers are businesses ("tenants"), and the platform is intended for business use only. We do not offer accounts to consumers or to anyone under 18.
- LeadQor is offered in English only and is available to businesses in Canada and the United States.
- LeadQor is not offered in the Province of Quebec. We do not market to, onboard, or serve businesses established in Quebec, and this policy is not intended to address Quebec's Law 25 requirements. (If this changes, this policy and our compliance program must be updated first.)
This policy is designed around Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and takes into account U.S. state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA), for our U.S. tenants.
3. The two roles we play (please read this — it matters)
LeadQor handles personal information in two very different capacities, and your rights depend on which one applies:
(a) LeadQor as a controller — your account data
When a business signs up for LeadQor, we collect and decide how to use certain information about that business and its authorized users: names, work email addresses, login credentials, billing details, support conversations, and how the platform is used. For this data, we are the organization responsible (the "controller"), and this policy governs directly.
(b) LeadQor as a processor / service provider — your business's data about its customers
Tenants use LeadQor to store and manage records about their own customers, leads, contacts, appointments, invoices, and communications ("Tenant Data"). For Tenant Data:
- The tenant — not LeadQor — decides what is collected, why, and how long it is kept. The tenant is the controller of that information.
- We process Tenant Data only on the tenant's documented instructions, under our Data Processing Addendum (DPA) and Terms of Service. We do not use Tenant Data for our own purposes, and we do not sell it — ever.
- If you are a customer, lead, or contact of a business that uses LeadQor, please direct any privacy request (access, correction, deletion, unsubscribe) to that business. It controls your information, and in most cases we are not able to identify or act on your record without its instruction. If you contact us instead, we will forward your request to the relevant business where we reasonably can, or tell you how to reach them.
The rest of this policy mostly describes role (a). Where role (b) is relevant, we say so explicitly.
4. What we collect as a controller, and why
| Category | Examples | Why we collect it |
|---|---|---|
| Account and profile data | Name, work email, phone number, job role, company name, password (hashed) | Creating and securing your account; authenticating logins; role-based access within your company |
| Billing data | Plan, billing contact, billing address, transaction history. Card and bank details go directly to Stripe — we never see or store full card numbers. | Charging subscription fees; invoicing; tax compliance |
| Usage and telemetry data | Features used, pages viewed, actions taken, timestamps, error logs, performance metrics | Operating and improving the platform; troubleshooting; capacity planning; detecting abuse |
| Device and connection data | IP address, browser type, operating system, device identifiers, approximate location derived from IP | Security (e.g., detecting suspicious logins), session management, compatibility |
| Communications metadata | Records of SMS, voice, and email sent through the platform (numbers, addresses, timestamps, delivery status) | Delivering communications features; billing usage; complying with telecom and anti-spam rules |
| Support communications | Emails, chat messages, call notes with our team | Answering your questions; improving support and documentation |
| Marketing data | Consent records, email engagement (opens/clicks) on our marketing messages | Sending marketing you've agreed to receive; proving consent under CASL |
Purposes and legal bases. We collect, use, and disclose this information only for the purposes above and closely related purposes a reasonable person would consider appropriate: providing the service under our contract with your business, securing the platform, billing, legal compliance, and (with express consent) marketing. We do not use it for purposes incompatible with these without telling you first.
We do not sell personal information. Not account data, not Tenant Data, not to anyone, not in exchange for money or anything else of value. We also do not "share" personal information for cross-context behavioural advertising as defined by the CCPA.
5. Payments
Subscription payments and (where a tenant enables it) tenant-side payment collection are processed by Stripe. Payment card numbers and bank account details are transmitted directly to Stripe and are never stored on LeadQor's systems. Stripe's handling of that data is governed by Stripe's privacy policy. We retain only what we need for billing records: transaction amounts, dates, status, and truncated identifiers (e.g., last four digits).
6. Where your data is stored — U.S. hosting disclosure
Your data is stored and processed primarily in the United States. Our core infrastructure providers — including our database, authentication, file storage, and hosting platforms — operate from U.S. data centers, and backups are stored with a U.S.-based provider.
Under PIPEDA's accountability model, LeadQor remains responsible for personal information transferred to service providers, wherever they are located. We use contractual safeguards (data processing agreements, confidentiality and security obligations) with every provider that handles personal information on our behalf.
Please be aware: while your information is stored or processed in the United States (or any other foreign jurisdiction), it is subject to the laws of that jurisdiction, and courts, law enforcement, and national security authorities there may be able to obtain access to it under lawful process. If you have questions about our transfer practices, contact our Privacy Officer (Section 15).
7. Service providers and subprocessors
We use a small set of carefully chosen providers to run LeadQor. The current list, with locations and roles, is maintained at [leadqor.com/subprocessors] — that page is the authoritative list and we update it when providers change. By category:
| Category | Provider(s) | What they do |
|---|---|---|
| Database, authentication, file storage | Supabase | Hosts the platform database and stored files (US) |
| Application hosting | Vercel | Serves the LeadQor application (US) |
| Payments | Stripe | Processes all payments; stores card/bank details |
| SMS and voice | RingCentral | Carries text messages and calls sent through the platform |
| Security and backups | Cloudflare | Network security, content delivery, encrypted off-site backups (R2) |
| Transactional email delivery | [Brevo / Resend — confirm final provider] | Delivers system and platform emails |
| Review management | Google (Business Profile APIs) | Retrieves and posts business reviews on tenants' behalf, with tenant authorization |
| Lead intake | Meta (lead ads APIs) | Retrieves ad-generated leads on tenants' behalf, with tenant authorization |
| AI features | [Model provider(s) — e.g., Anthropic / OpenAI — confirm] | Processes text you submit to AI-assisted features (see Section 8) |
Each provider is bound by contract to protect personal information, use it only to provide services to us, and meet security requirements. Where a provider processes Tenant Data, it acts as a subprocessor under our DPA, and tenants are entitled to notice of subprocessor changes as the DPA describes.
8. AI features
Some LeadQor features use artificial intelligence (for example, drafting replies or summarizing records). When a tenant uses these features, the relevant business data is sent to a third-party AI model provider for processing. Our agreements with AI providers [require that submitted data is not used to train their general-purpose models — counsel/vendor to confirm before publication]. AI features are optional; tenants control whether and how they are used within their account. Do not submit data to AI features that your business is not permitted to disclose to a service provider.
9. How long we keep information
| Data | Retention |
|---|---|
| Active accounts | For as long as your account is active and as needed to provide the service |
| Cancelled accounts | Your data becomes read-only for 60 days after cancellation so you can export it. After the 60-day window, live data is deleted. Copies in encrypted backups age out on our backup rotation and are purged by approximately day 90 after cancellation. |
| Consent and suppression records (marketing consent, unsubscribes, do-not-contact flags) | Retained for at least 3 years after they last apply, as required by Canada's Anti-Spam Legislation (CASL) — even after account deletion, so we can prove consent and honour opt-outs |
| Financial and tax records (invoices, payment records) | Retained for 7 years as required by Canadian tax law |
| Security and audit logs | [●] months, then deleted or anonymized |
Deleted data may persist briefly in caches and logs before those systems cycle; we do not restore deleted data from backups except to recover from a system failure.
10. Marketing communications (CASL)
- We send marketing email only to people who have given express consent — an unchecked, affirmative opt-in checkbox at the point of collection. We keep a record of when and how you consented.
- Every marketing email includes a working unsubscribe link. Unsubscribes are honoured immediately in our systems (and in any case within the timelines CASL requires).
- Unsubscribing from marketing does not stop transactional and account messages — invoices, security alerts, service notices, password resets — which we must send to operate your account.
- Messages that tenants send through LeadQor to their contacts are the tenant's responsibility under CASL, TCPA, CAN-SPAM, and similar laws; LeadQor provides the tooling (consent capture, suppression lists, unsubscribe handling) but the tenant is the sender.
CASL identification: Commercial electronic messages from LeadQor are sent by LeadQor Canada Inc., [street address, city, Ontario, postal code, Canada], [privacy@leadqor.com]. You can unsubscribe using the link in any marketing message or by emailing us at that address.
11. Security
We protect personal information with safeguards appropriate to its sensitivity, including:
- Encryption in transit (TLS) for all connections and encryption at rest for stored data and backups;
- Tenant isolation — every record is scoped to a tenant, enforced at the database layer with row-level security so one business can never read another's data;
- Access controls — role-based permissions within tenant accounts, and least-privilege access for LeadQor staff, limited to what their job requires;
- Audit logging of significant actions on the platform;
- Encrypted off-site backups on a rotation, stored with a separate provider from the primary database;
- Vendor security review and contractual security obligations for all subprocessors.
No system is perfectly secure, and we cannot guarantee absolute security — but we treat protecting your data as a core product requirement, not a checkbox.
12. If something goes wrong (breach commitment)
If we become aware of a breach of security safeguards affecting personal information:
- We will investigate, contain, and remediate it promptly;
- We will notify affected tenants without undue delay, with enough detail for them to assess the impact and meet their own legal obligations to their customers;
- Where the breach creates a real risk of significant harm to individuals, we will report to the Office of the Privacy Commissioner of Canada and notify affected individuals as PIPEDA requires, and keep the records PIPEDA mandates;
- For Tenant Data, we will support tenants (as controllers) in meeting their own breach notification duties under applicable law.
13. Your rights
If you are a tenant user (account holder): you may request access to the personal information we hold about you, ask us to correct it if it's inaccurate, or ask us to delete it (subject to the retention obligations in Section 9 — e.g., tax and CASL records we're legally required to keep). To exercise these rights, email our Privacy Officer (Section 15). We will respond within the time limits set by applicable law (generally 30 days under PIPEDA), and we may need to verify your identity first. There is no charge for reasonable requests. If you're unsatisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or, for U.S. residents, your state Attorney General or applicable regulator.
If you are an end-customer of a business that uses LeadQor: your information is controlled by that business — please direct your request to them (see Section 3(b)). We will assist that business in fulfilling your request as their processor.
California residents: we act as a "service provider" with respect to Tenant Data and do not sell or share personal information. Tenant users may exercise CCPA rights (know, delete, correct, non-discrimination) through the contact in Section 15.
14. A few final points
- No children. LeadQor is a business tool for adults. We do not knowingly collect information from anyone under 18, and accounts may only be created for business use. If you believe a minor has provided us information, contact us and we will delete it.
- Do Not Track. Some browsers send "Do Not Track" signals. There is no common standard for interpreting them, and LeadQor does not respond to DNT signals at this time. We do not track users across third-party websites in any event.
- Changes to this policy. We may update this policy from time to time. For material changes, we will give tenants advance notice by email or in-app notice before the change takes effect. The "Last updated" date at the top always reflects the current version, and prior versions are available on request.
15. Privacy Officer — contact us
Questions, requests, and complaints about privacy at LeadQor go to our Privacy Officer, who is accountable for our compliance with this policy and applicable law:
Privacy Officer — [Name to be designated]
LeadQor Canada Inc.
[Street address]
[City], Ontario, Canada [Postal code]
Email: [privacy@leadqor.com]
Phone: [●]