Privacy Policy

Introduction

Incubatr (operated by François Desruisseaux) is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with:

• PIPEDA (Personal Information Protection and Electronic Documents Act) - Federal law applicable across Canada 🍁
• Bill 25 (Law 25) - Quebec's modernized privacy law ⚜️
• GDPR (General Data Protection Regulation) - For European clients 🌍

1. What Information We Collect

Personal Information You Provide

When you contact us or use our services, we may collect:

• Contact information: Name, email address, phone number
• Business information: Company name, industry sector, number of employees
• Project details: Service requirements, budget, timeline, business challenges
• Financial information: For grant applications only (tax returns, financial statements)
• Communication records: Emails, call notes, meeting summaries

Information Collected Automatically

• Website usage: Pages visited, time spent, referral sources (via Google Analytics)
• Device information: Browser type, operating system, IP address
• Cookies: Essential cookies for website functionality (see Cookies section below)

2. How We Use Your Information

We use your information for the following purposes:

• Service delivery: To provide consulting, website development, automation, and grant application services
• Communication: To respond to inquiries, schedule consultations, send proposals and project updates
• Grant applications: To prepare and submit applications to government programs (ESSOR, CanExport, PCAN, etc.)
• Billing: To process payments and maintain financial records
• Website improvement: To analyze usage patterns and improve user experience
• Legal compliance: To comply with legal obligations under PIPEDA, Bill 25, and tax laws

3. Legal Basis for Processing (GDPR)

For clients in the European Union, we process your data based on:

• Consent: When you provide explicit consent (e.g., contact forms, newsletter)
• Contractual necessity: To fulfill our service agreement with you
• Legitimate interests: To improve our services and communicate relevant updates
• Legal obligation: To comply with tax and business laws

4. How We Share Your Information

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

• Government agencies: When submitting grant applications (Investissement Québec, Global Affairs Canada, provincial programs) 🍁⚜️
• Service providers:
  • Google Analytics (website analytics - anonymized data)
  • Calendly (appointment scheduling)
  • Email providers (Formspree, Google Workspace)
• Professional advisors: Lawyers, accountants (under confidentiality agreements)
• Legal requirements: When required by law, court order, or government request

All third-party providers are bound by contractual obligations to protect your data and use it only for specified purposes.

5. Your Privacy Rights

Under PIPEDA (All of Canada) 🍁

• Right to access: Request a copy of your personal information
• Right to correction: Request corrections to inaccurate data
• Right to withdraw consent: Withdraw consent for processing (with exceptions for legal obligations)
• Right to complain: File a complaint with the Privacy Commissioner of Canada

Under Bill 25 (Quebec) ⚜️

• Right to deletion: Request deletion of your data (subject to legal retention requirements)
• Right to portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing for direct marketing
• Right to de-indexing: Request removal from search engines (under certain conditions)
• Response time: We respond to requests within 30 days

Under GDPR (EU Clients) 🌍

• All rights listed above, plus:
• Right to restriction: Limit how we process your data
• Right to lodge complaints: With your local EU data protection authority

6. Data Security

We implement industry-standard security measures:

• Encryption: SSL/TLS encryption for data transmission (HTTPS)
• Access controls: Limited access to personal data (need-to-know basis)
• Password protection: Strong passwords and two-factor authentication
• Regular backups: Encrypted backups stored securely
• Vendor security: All third-party providers meet PIPEDA/GDPR standards

7. Data Retention

We retain your information for as long as necessary to:

• Provide services to you
• Comply with legal obligations (tax records: 7 years)
• Resolve disputes and enforce agreements

Retention periods:

• Client files: 7 years after project completion (tax compliance)
• Grant applications: 7 years (government audit requirements)
• Email communications: 3 years
• Website analytics: 26 months (Google Analytics default)
• Marketing contacts: Until you unsubscribe or request deletion

8. Cookies & Tracking Technologies

We use cookies to improve your experience:

Essential Cookies (Always Active)

• Session management
• Cookie consent preferences
• Security features

Analytics Cookies (With Consent)

• Google Analytics 4 (anonymized IP addresses)
• Page views, session duration, bounce rates

You can manage cookie preferences via our cookie banner or your browser settings. Disabling cookies may limit website functionality.

9. Children's Privacy

Our services are intended for businesses and individuals aged 18+. We do not knowingly collect information from children under 18. If you believe we have collected such information, please contact us immediately.

10. International Data Transfers

Your data is primarily stored in Canada. Some service providers (e.g., Google Analytics, Calendly) may store data in the United States under adequate safeguards:

• Standard contractual clauses (approved by EU Commission)
• Privacy Shield successor frameworks
• PIPEDA adequacy determinations

11. Changes to This Privacy Policy

We may update this policy periodically. Changes will be posted on this page with an updated "Last updated" date. For significant changes, we will notify you via email or prominent website notice.

12. Contact Us

For privacy questions, data requests, or complaints: