Privacy Policy

Last updated: [DATE]

ImplementIQ Ltd., operating the Qairo service, ("Qairo", "we", "us") respects your privacy. This policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have. It is written to align with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

1. Who this policy covers

This policy applies to three groups of people:

Website visitors — anyone who visits our website or submits a form.
Prospective and current clients — the businesses we contact or work with, and the individuals who represent them.
Our clients' customers — people who post public reviews about businesses we work for. We handle this information on our clients' behalf, and section 7 explains that relationship.

2. What we collect

Information you give us

Name, business name, job role, work email address, and phone number
Details about your business, including number of locations, province, industry, and how reviews are handled today
Links to your public business listings
Anything you write in a free-text field or send us by email
Whether you consented to receive email from us, and the date and method of that consent

Information we collect automatically

IP address, browser type, device type, referring page, and pages viewed
Cookies and similar technologies, as described in section 9

Information we collect from public sources

When we prepare an audit or contact a business, we may collect business contact details and public listing information that the business has published on its own website or public profile. We record the source and date for each contact we collect this way.

Information we handle for clients

When you become a client, we access the public reviews posted about your business, the names or display names attached to those reviews, and the content of your business profile. We access these through the permissions you grant us on the relevant platforms.

3. Why we collect it

To prepare and send the audit you requested
To respond to your enquiries and provide our services
To administer contracts, invoicing, and account records
To send you commercial email where you have consented or where we have a valid basis under Canada's Anti-Spam Legislation (CASL)
To improve our website and understand how it is used
To meet legal, tax, and regulatory obligations

We do not use your personal information for any purpose materially different from those listed without asking you first.

4. Consent

We collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise. By submitting a form on our website you consent to us using your details for the purpose stated on that form.

Consent to receive marketing email is separate and optional. You can withdraw it at any time using the unsubscribe link in any email we send, or by emailing hello@qairo.net. We process unsubscribe requests within ten business days. Withdrawing marketing consent does not affect service-related messages we need to send you as a client.

5. Who we share it with

We do not sell personal information. We do not rent or trade contact lists. We share personal information only with:

Service providers who help us operate, such as email and hosting providers, form processing, accounting software, and payment processors. They may access personal information only to perform work for us and are bound by confidentiality obligations.
Review and listing platforms, where publishing a response on your behalf necessarily discloses that response publicly.
Legal and regulatory authorities, where required by law, court order, or lawful request.
A successor, if our business is sold or reorganised, subject to equivalent privacy protections.

Our current service providers are listed at [LINK TO SUBPROCESSOR LIST], and we will name them in your contract before work begins.

6. Where your information is stored

Information may be stored and processed outside Canada. Our team and some of our service providers operate outside Canada, including in [LIST COUNTRIES]. While your information is in another country it may be accessible to courts, law enforcement, and government authorities in that country under the laws that apply there.

We take reasonable steps, including contractual protections with everyone who handles your information, to ensure it receives a comparable level of protection wherever it is processed. If you would like more detail about our practices in a specific country, contact us at hello@qairo.net.

7. Information about your customers

When we respond to reviews for a client, we act as a service provider processing that information on the client's behalf and under the client's instructions. The client remains accountable for that information under PIPEDA. We use it only to deliver the agreed services, we do not use it for our own purposes, and we do not retain it after the engagement ends except where a record is required by law.

8. How we protect it

Access is limited to people who need it to do their work
Everyone who works on client accounts signs a confidentiality agreement
Accounts require multi-factor authentication where the platform supports it
Credentials are stored in a managed password system, never in shared documents or messages
Access is revoked promptly when someone leaves or an engagement ends

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we will notify affected individuals and the Office of the Privacy Commissioner of Canada where a breach creates a real risk of significant harm, as required by law.

9. Cookies and analytics

Our website uses cookies to make the site work and to understand how it is used. [DESCRIBE WHICH TOOLS YOU USE, E.G. GOOGLE ANALYTICS.] You can set your browser to refuse cookies, though parts of the site may not work as intended. We do not use cookies to build advertising profiles.

10. How long we keep it

Audit requests that do not become clients: [X] months, then deleted
Consent records: for as long as we rely on the consent, plus [X] years, because we must be able to prove consent under CASL
Client records: for the term of the engagement plus [X] years, for tax and legal purposes
Unsubscribe records: indefinitely, so that we do not contact you again

11. Your rights

You can ask us to:

Tell you what personal information we hold about you and how it has been used
Correct information that is inaccurate or incomplete
Delete information, where we are not required to keep it
Withdraw consent, subject to legal or contractual restrictions

Write to hello@qairo.net. We respond within 30 days. We may ask you to verify your identity before we act on a request. There is no fee for a reasonable request.

12. Complaints

Our Privacy Officer is [NAME], reachable at hello@qairo.net. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca or 1-800-282-1376.

13. Changes to this policy

We may update this policy. The date at the top shows when it last changed. If a change is significant we will tell current clients directly.

14. Contact us

ImplementIQ Ltd.
hello@qairo.net · [PHONE]