⚠️ DRAFT TEMPLATE — NOT A LEGAL DOCUMENT. This draft must be reviewed and finalized by a
privacy lawyer licensed by the Law Society of Alberta. Compliance with PIPA, PIPEDA, and any sector-specific
requirements must be confirmed. Estimated legal cost: $300 CAD.
- Effective Date
- [DATE]
- Organization
- Opcelerate Neural Inc. ("Company", "we", "our", "us")
- Privacy Officer
- [NAME], [EMAIL]
- Jurisdiction
- Province of Alberta, Canada
1 Introduction
Opcelerate Neural Inc. ("Company") is committed to protecting the personal information of our clients,
users, employees, and partners. This Privacy Policy describes how we collect, use, disclose, and protect
personal information in compliance with the Personal Information Protection Act (PIPA), S.A.
2003, c. P-6.5 and, where applicable, the Personal Information Protection and Electronic Documents
Act (PIPEDA), S.C. 2000, c. 5.
This Policy applies to: (a) our website at [URL]; (b) all Opcelerate Neural
software products and SaaS platforms; (c) our business operations, including client, employee, and
contractor relationships.
2 Definitions
- "Personal Information" means information about an identifiable individual, as
defined in Section 1(1)(k) of PIPA, excluding business contact information used for business
purposes (Section 1(1)(a) of PIPA).
- "Consent" means voluntary agreement to the collection, use, or disclosure of
personal information for a stated purpose.
- "Client Data" means data uploaded to or processed through our Services by clients,
which may include personal information.
- "Services" means all software products, platforms, and related services provided
by the Company.
3 Information We Collect
3.1 Information You Provide
- Contact information (name, email address, phone number, business address)
- Account registration details (username, password hash)
- Billing information (company name, billing address, payment method details)
- Communications (support tickets, emails, meeting notes)
- Employment/contractor application information (resume, qualifications, references)
3.2 Information Collected Automatically
- Device information (browser type, operating system, IP address)
- Usage data (pages visited, features used, time spent, click patterns)
- Log data (access times, error logs, API call records)
- Cookies and similar tracking technologies (see Section 8)
3.3 Information from Third Parties
- Business information from publicly available sources
- Reference information from designated referees during recruitment
- Integration data from connected third-party platforms (with client authorization)
3.4 Client Data
Our clients may upload data to our Services that contains personal information of third parties (e.g.,
employee safety records, procurement contacts). We process this data as a service provider on behalf
of the client. The client remains the data controller and is responsible for ensuring lawful
collection and consent.
4 How We Use Personal Information
We use personal information for the following purposes, as permitted under PIPA Section 16:
- Service delivery — to provide, maintain, and improve our software products and
platforms
- Account management — to create and manage your account, authenticate users, and
process subscriptions
- Billing — to process payments, issue invoices, and manage accounts receivable
- Communications — to respond to inquiries, provide technical support, and send
service-related notifications
- AI/ML training — to improve our artificial intelligence models and algorithms
using aggregated and de-identified data only (never Client Data without explicit consent)
- Security — to detect, prevent, and address fraud, abuse, and security threats
- Compliance — to comply with legal obligations, enforce our terms of service, and
protect our legal rights
- Business operations — to manage employment and contractor relationships, including
payroll, benefits, and tax reporting
- Analytics — to understand usage patterns and improve user experience using
aggregated, non-identifiable data
5 Consent
5.1 Obtaining Consent
We obtain consent before or at the time of collecting personal information. Consent may be express
(written, oral, or electronic) or implied (from your conduct), depending on the sensitivity of the
information and the reasonable expectations of the individual (PIPA, Section 8).
5.2 Deemed Consent
Consent is deemed given for: (a) personal information collected as part of an employment or contractor
relationship; (b) business contact information used for business purposes; and (c) information
necessary for the completion of a transaction you initiated.
5.3 Withdrawal of Consent
You may withdraw consent at any time by contacting our Privacy Officer (Section 13), subject to legal
or contractual obligations. Withdrawal of consent may limit our ability to provide certain Services.
We will inform you of the consequences of withdrawal.
6 Disclosure of Personal Information
6.1 Authorized Disclosures
We may disclose personal information to:
- Service providers — third-party vendors who assist in service delivery (cloud
hosting, payment processing, email services), subject to contractual confidentiality and data
protection obligations
- Professional advisors — lawyers, accountants, and auditors, as necessary
- Business transfers — in connection with a merger, acquisition, or sale of assets,
with prior notice to affected individuals
- Legal requirements — when required by law, court order, or regulatory authority
(PIPA, Section 20)
6.2 No Sale of Personal Information
We do not sell, rent, or trade personal information to third parties for marketing
or advertising purposes.
6.3 International Transfers
Personal information may be transferred to service providers located outside Alberta or Canada. We
ensure comparable levels of protection through contractual safeguards. Currently, our primary
service providers are located in Canada.
7 Data Retention
7.1 Retention Periods
- Client account data: duration of the business relationship + 3
years
- Client Data: 30 days after account termination (data export available)
- Billing records: 7 years (per Income Tax Act
requirements)
- Employment records: duration of employment + 3 years
- Website analytics: 26 months (aggregated/anonymized)
- Support communications: 2 years from resolution
7.2 Destruction
When personal information is no longer required, we securely destroy or de-identify it using
industry-standard methods (secure deletion, cryptographic erasure, or physical destruction as
appropriate).
8 Cookies & Tracking Technologies
8.1 Types of Cookies
- Essential cookies: Required for platform functionality (session management,
authentication, security). Cannot be disabled.
- Analytics cookies: Help us understand usage patterns (page views, feature
adoption). Can be disabled.
- Preference cookies: Remember your settings (theme, language, dashboard layout).
Can be disabled.
8.2 Managing Cookies
You can manage cookie preferences through your browser settings. Disabling certain cookies may affect
the functionality of the Services.
9 Security Safeguards
We implement appropriate technical and organizational safeguards to protect personal information
against unauthorized access, disclosure, alteration, or destruction (PIPA, Section 34). These
include:
- Encryption at rest (AES-256) and in transit (TLS 1.2+)
- Role-based access controls with principle of least privilege
- Multi-factor authentication for administrative access
- Regular security assessments and vulnerability scanning
- Secure development practices and code review
- Employee security awareness training
- Incident response procedures
- Regular data backups with encryption
10 Your Rights
Under PIPA, you have the right to:
- Access — request access to your personal information held by us (PIPA, Section 24)
- Correction — request correction of inaccurate or incomplete personal information
(PIPA, Section 25)
- Withdrawal — withdraw your consent, subject to legal or contractual restrictions
- Complaint — file a complaint with our Privacy Officer or the Office of the
Information and Privacy Commissioner of Alberta (OIPC)
Access requests must be submitted in writing and will be responded to within 45 days
(PIPA, Section 28). We may charge a reasonable fee for access requests that are manifestly unfounded
or excessive.
11 AI & Automated Decision-Making
11.1 Use of AI
Our Services incorporate artificial intelligence and machine learning for: procurement analysis,
safety prediction, data integration, and document processing. AI systems process Client Data
solely to generate outputs requested by the client.
11.2 Human Oversight
AI-generated outputs are provided as recommendations, not autonomous decisions. All significant
business decisions remain under human control. We do not use fully automated decision-making
that produces legal or similarly significant effects on individuals without human review.
11.3 Model Training
We do not use individual Client Data to train our AI models without explicit written
consent. Model improvements are derived from aggregated, anonymized, and de-identified data sets.
12 Children's Privacy
Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal
information from children. If we become aware that we have inadvertently collected such information,
we will promptly delete it.
13 Contact & Complaints
13.1 Privacy Officer
For questions, access requests, or complaints regarding this Privacy Policy, contact:
Privacy Officer
Opcelerate Neural Inc.
[ADDRESS], Alberta, Canada
Email: [privacy@opcelerate.com]
Phone: [PHONE]
13.2 OIPC Complaints
If you are unsatisfied with our response, you may file a complaint with the:
Office of the Information and Privacy Commissioner of Alberta
#410, 9925 – 109 Street NW
Edmonton, Alberta T5K 2J8
Phone: 780-422-6860
Toll-free: 1-888-878-4044
Website: www.oipc.ab.ca
14 Changes to This Policy
We may update this Privacy Policy from time to time. The revised policy will be posted on our website
with an updated "Effective Date." Material changes will be communicated via email to registered users
and clients not less than 30 days before taking effect. Continued use of the
Services constitutes acceptance of the revised policy.