Privacy Policy

This Privacy Policy explains how Data Function Inc. ("Data Function", "we", "our" or "us"), a federally incorporated Canadian company based in Toronto, Ontario, collects, uses, discloses and protects personal information about our clients, prospective clients, website visitors and users of our software and services. It also explains your choices and how to contact us. Our SMS Opt-In & Messaging Policy and Terms & Conditions form part of how we handle information and should be read with this policy.

1. Who we are and how to reach us

• Legal name: Data Function Inc.
• Office: Legal Innovation Zone / Centre for Urban Innovation, 44 Gerrard St E, Toronto, ON M5B 1G3, Canada
• Mailing address: 105 Bond Street, CUI-317, Toronto Metropolitan University, Toronto, ON M5B 1Y3, Canada
• Email: info@datafunction.ca
• Phone: +1 416-319-3884

Our Privacy Officer is accountable for our compliance with this policy. You can reach the Privacy Officer at info@datafunction.ca (please include "Privacy" in the subject line) or by mail at our mailing address above.

2. Canadian privacy law

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, for electronic messages, Canada's Anti-Spam Legislation (CASL), as well as other privacy laws that apply to us. Where a provincial privacy law applies to a particular activity, we follow that law as well.

3. Information we collect

Information you give us

• Website forms and inquiries: your name, email address, phone number, company or organization, the topic of your inquiry and your message when you use our contact form, and your email address if you sign up for updates.
• Consultations and projects: your name, job title, business name and contact details, and information about your project, goals and existing systems that you share with us when you request a consultation, a quote or our services.
• Phone calls: the date, time and length of calls, notes our team makes about the conversation, and, where you have been told at the start of the call that it may be recorded, the call recording and a written transcript and summary of it.
• Text messages (SMS): your mobile phone number; whether and how you agreed to receive text messages (the date and time, the method, the wording you agreed to and who recorded it); the content of messages we send to you and receive from you; message delivery status; and any STOP, HELP or other opt-out requests.
• Billing information: details needed to invoice you and process payments, such as your billing name and address. Card payments are processed by our payment processor, Stripe. We do not store full credit card numbers on our servers.
• Client project data: when you engage us for a project, you may give us access to your organization's data (for example, customer or financial data needed for analytics or software development). We use it only to deliver that project, as set out in our agreement with you, and we treat it as confidential.

Information collected automatically

• Website analytics: where enabled, we use Google Analytics to understand how visitors use our website, such as pages viewed, approximate location, device and browser type, and how you arrived at our site. Advertising features and Google Signals are switched off.
• Spam protection: our contact and assessment forms use Cloudflare Turnstile, a hidden field and request-rate limits to tell people apart from automated programs. Turnstile checks technical signals from your browser and may set a cookie for that purpose; it does not ask you to solve puzzles, and the check is run by Cloudflare under its own privacy policy.
• Technical data: like most websites, our servers record technical information such as IP addresses, browser type and the pages requested, for security and to keep the site working. Contact-form submissions are stored with the sending IP address.

Information from other sources

We may collect business contact information that a business has published, for example on its website or in an online business listing, so that we can contact the business about services relevant to it.

4. How we use your information

• To respond to you: to answer inquiries, arrange and hold consultations, and provide quotes and estimates.
• To provide our services: to deliver the custom software, AI models, websites, hosting and data analytics services you request, and to provide customer support.
• To communicate with you: by email, phone and, if you have agreed, by text message about your consultation, appointments and projects.
• For billing and records: to invoice you, process payments and keep business and tax records.
• For marketing, with consent: to tell you about our services and products (such as Case Polaris and NeuraCap) where you have agreed or where the law otherwise permits. You can unsubscribe at any time.
• To improve our website and services: to understand how they are used and fix problems.
• For security and legal compliance: to protect our systems and users, prevent fraud and abuse, and meet our legal obligations.

We collect only the information we need for these purposes. If we want to use your information for a new purpose, we will tell you and, where required, ask for your consent first.

5. Consent and how to withdraw it

We ask for your consent to collect, use and disclose your personal information, except where the law allows otherwise. Depending on the situation, we ask for express consent (for example, ticking an optional checkbox or saying yes on a call) or rely on implied consent (for example, using the contact details you send us to answer your inquiry). We ask for express consent before using sensitive information or for uses you would not reasonably expect.

You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us at info@datafunction.ca. For text messages, reply STOP. For marketing emails, use the unsubscribe link in the email. We will explain the likely consequences of withdrawing consent, for example that we may not be able to provide a particular service.

6. Text messages (SMS) and your mobile number

We send text messages only to people who have agreed to receive them, as explained in our SMS Opt-In & Messaging Policy. Consent to text messages is optional and is not a condition of buying any service. Message frequency varies. Message and data rates may apply. You can reply STOP to opt out or HELP for help at any time.

We use your mobile number, SMS consent records and messaging history only to send and manage the messages you agreed to, to keep a record of your consent and opt-out choices, and to respond to you.

We do not sell, rent or share your SMS opt-in information, consent records or mobile phone number with third parties or affiliates for their marketing or promotional purposes. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

7. Service providers and other disclosures

We do not sell, trade or rent your personal information. We share it only as described below.

• Messaging and telephone providers, such as Twilio, which carry our text messages and phone calls.
• Google, for business email and documents (Google Workspace) and, where enabled, website analytics (Google Analytics).
• Hostinger, which provides the servers that host our website and our customer relationship management (CRM) system, which we operate ourselves.
• Stripe, which processes card payments.
• Transcription and AI service providers, which we use to transcribe and summarize recorded calls for our internal records.
• Cloud and data platforms agreed with you for a specific client project.
• Professional advisers, such as lawyers and accountants, where needed.
• Legal requirements: where required or permitted by law, for example in response to a valid request from a public authority, or to protect our rights, our users or the public.
• Business transfers: if we are involved in a merger, acquisition or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate confidentiality protections.

Our service providers may use your information only to provide services to us. We take reasonable steps, including through our agreements with them, to make sure they protect it.

All the above categories exclude text messaging originator opt-in data and consent; this information won't be shared with any third parties.

8. Where your information is stored and processed

Our website and CRM are hosted on servers located in the United States, and several of our service providers (including Twilio, Google and Stripe) process information in the United States and other countries. When your information is stored or processed outside Canada, it is subject to the laws of that country and may be accessed by its courts, law enforcement and national security authorities. For client projects that require it, we host in Canada.

9. How we protect your information

We use administrative, technical and physical safeguards that are appropriate to the sensitivity of the information. These include limiting access to personal information to team members and contractors who need it for their work, protecting our systems with account access controls, and using HTTPS on our website. Team members and contractors who handle client information are required to keep it confidential. For client project data, we agree on data-handling arrangements with you.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards involving your personal information creates a real risk of significant harm, we will notify you and report it to the Office of the Privacy Commissioner of Canada as required by law.

10. How long we keep information

We keep personal information only as long as we need it for the purposes described in this policy, or as long as the law requires. For example, we keep billing and financial records for the period required by Canadian tax law, and we keep SMS consent and opt-out records for as long as we need them to honour your choices and to show that we had your permission. When we no longer need personal information, we securely delete it or make it anonymous.

11. Your rights: access and correction

You can ask to see the personal information we hold about you, ask how we have used and disclosed it, and ask us to correct information that is inaccurate or incomplete. You can also ask us to delete information we no longer need. To make a request, contact our Privacy Officer at info@datafunction.ca. We may need to confirm your identity. We will respond within 30 days, or tell you within that time if we need more time as the law allows. If we cannot give you access to some information, we will explain why, unless the law prevents us from doing so.

12. Cookies and analytics

Our website uses only the cookies needed for it to work and, where analytics is enabled, Google Analytics cookies to understand how the site is used. You can block or delete cookies through your browser settings. You can also use Google's Google Analytics opt-out browser add-on.

13. Children

Our website and services are intended for businesses and adults. We do not knowingly collect personal information from children.

14. Questions and complaints

If you have a question or concern about how we handle your personal information, please contact our Privacy Officer at info@datafunction.ca or +1 416-319-3884. We will investigate and respond. If you are not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada.

15. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will change the "Last updated" date at the top of this page. If we make a significant change to how we use your personal information, we will tell you and ask for your consent where required.

16. Contact us

Data Function Inc., Attention: Privacy Officer
105 Bond Street, CUI-317, Toronto Metropolitan University, Toronto, ON M5B 1Y3, Canada
Email: info@datafunction.ca · Phone: +1 416-319-3884

Our office is at Legal Innovation Zone / Centre for Urban Innovation, 44 Gerrard St E, Toronto, ON M5B 1G3, Canada.