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Numerly
Draft Document — This is a working draft pending review by qualified legal counsel. It is not a substitute for professional legal advice. Do not rely on this document until it has been reviewed and approved by a lawyer licensed in British Columbia.

Privacy Policy

Effective Date: [TO BE CONFIRMED BY COUNSEL]  |  Applies to: numerly.ca

[YOUR INCORPORATED ENTITY NAME] ("Numerly", "we", "us", or "our") is committed to protecting the privacy of our clients and their employees. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the British Columbia Personal Information Protection Act (PIPA).

1. What Information We Collect

CategoryExamplesHow Collected
Account informationName, email address, business name, phone numberProvided by you at signup
Financial dataTransaction records, invoices, bank statements, payroll data, GST/HST filingsUploaded or entered by you
Employee informationEmployee names, SINs, pay rates, TD1 data (for payroll clients)Uploaded or entered by you
Document filesReceipt images, PDFs, CSV filesUploaded by you
Usage dataLogin timestamps, IP addresses, pages visitedAutomatically collected
CommunicationsSupport emails, document requestsProvided by you

2. How We Use Your Information

We use the information we collect to:

3. Artificial Intelligence Processing

Important: When you upload receipts, invoices, or other documents, those files may be transmitted to the Anthropic Claude API for automated data extraction (e.g., vendor name, amount, GST). This processing occurs on Anthropic's servers, which are located outside Canada. By using the document upload feature, you consent to this cross-border data processing.

We have reviewed Anthropic's usage policies and do not use their API on a plan that permits your data to be used for model training. Documents are processed and the results returned; files are not stored by Anthropic beyond the duration of the API call.

AI-extracted data is always subject to human review by your accountant before any financial record is finalized.

4. Disclosure of Personal Information

We do not sell, rent, or trade your personal information. We may share information with:

5. Third-Party Service Providers

ProviderPurposeData Shared
Anthropic (Claude API)AI document extractionDocument images and text
DigitalOceanCloud hosting (Canadian region preferred)All data stored on platform
Namecheap / Private EmailEmail deliveryEmail address, message content

6. Data Security

We implement industry-standard security measures including:

No system is 100% secure. In the event of a data breach affecting your personal information, we will notify you and the applicable privacy regulator as required by law.

7. Data Retention

We retain your data for as long as your account is active and for 90 days following termination, after which it is permanently deleted from production systems. Backups are retained for 14 days. Financial records may be retained longer if required by CRA or other legal obligations (typically 7 years for business records).

8. Your Rights

Under PIPEDA and PIPA, you have the right to:

To exercise any of these rights, contact us at support@numerly.ca.

9. Cookies and Tracking

Numerly uses only essential session cookies required for authentication. We do not use advertising cookies, tracking pixels, or analytics services that share data with third parties.

10. Children's Privacy

The Service is intended for business use by adults (18+). We do not knowingly collect personal information from individuals under 18 years of age.

11. Cross-Border Data Transfers

Our primary servers are hosted in Canada. AI processing via the Anthropic API occurs on servers outside Canada (United States). By using the AI features of the Service, you consent to this transfer. We take steps to ensure that your data is protected to a standard comparable to Canadian privacy law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email at least 14 days before the change takes effect. The current version is always available at numerly.ca/privacy.

13. Contact Our Privacy Officer

For any privacy-related questions, access requests, or complaints:

Privacy Officer
[YOUR INCORPORATED ENTITY NAME]
[YOUR BUSINESS ADDRESS]
support@numerly.ca