This Privacy Policy explains how InoQlate Inc. (“InoQlate”, “we”, “us”, or “our”) collects, uses, and shares information when you visit our website, sign up for updates, or otherwise communicate with us (collectively, the “Services”). InoQlate Inc. is a Canadian not-for-profit corporation and is the organization responsible for (the “controller” of) the personal information described here. When you sign up, we ask for your consent to receive news and fraud-prevention updates; you can withdraw that consent at any time. InoQlate’s updates are intended for business recipients, and the contact details we collect are business contact details you provide in a professional capacity on behalf of your organization.
01Information We Collect
Information you give us
- Contact details: your name (optional), company name, email address, and mobile phone number (if you choose text or WhatsApp updates).
- Consent records: to honour your choices and meet our legal obligations (including under Canada’s Anti-Spam Legislation), we record the date and time of your opt-in, the page you submitted from, your IP address and browser/device, the channels you selected, and the version of the consent language and policies you were shown.
Information collected automatically
- Limited usage and device data: for example IP address and browser type through cookies that are necessary to operate the site and remember your preferences. We do not currently use analytics or advertising cookies. If that changes, we will update this Policy.
02How We Use Your Information and Our Legal Bases
We use your information to send you the launch news and fraud-prevention updates you asked to receive (through the channels you selected); to record and manage your consent and communication preferences; to share your details with our licensed providers where you opt in, so they can contact you about the product (see Section 5); to operate, secure, and improve the Services and prevent fraud or abuse; and to comply with applicable laws and respond to lawful requests.
Where the EU or UK GDPR applies to you, we rely on the following legal bases. We do not rely on consent alone for every activity, so that, for example, we can still keep the records we need to prove you opted in even after you withdraw your consent:
| What we do | Legal basis (EU/UK GDPR) |
|---|---|
| Send you the launch news and updates you asked to receive (email, SMS, WhatsApp) | Your consent (Article 6(1)(a)) |
| Share your details with our licensed providers where you opt in | Your consent (Article 6(1)(a)) |
| Record and manage your consent and communication preferences, and keep opt-out and consent records to demonstrate compliance | Legal obligation (Article 6(1)(c)) — e.g. CASL record-keeping — and our legitimate interest in evidencing compliance (Article 6(1)(f)) |
| Operate, secure, and improve the Services and prevent fraud or abuse | Our legitimate interests in running a secure, functioning website (Article 6(1)(f)) |
| Comply with applicable laws and respond to lawful requests | Legal obligation (Article 6(1)(c)) |
For users in China, we process your personal information on the basis of your consent under the Personal Information Protection Law (PIPL), including separate consent for sharing your details with our licensed providers and for any transfer of your information outside China. For users in Brazil, we rely on your consent and, where applicable, our legitimate interests under the LGPD. You can withdraw your consent at any time (see Section 3); withdrawal does not affect communications already sent or processing already carried out, or records we must keep by law.
03Your Communication Choices
You choose which channels you hear from us on, and you can change or withdraw your choices at any time.
Every email identifies InoQlate as the sender, includes our contact details, and includes a clear unsubscribe link. We will give effect to an unsubscribe request within 10 business days, as required by Canada’s Anti-Spam Legislation (CASL).
Text messages (SMS)
If you opt in to SMS, you agree to receive automated text messages with launch news and updates at the number you provided. Message frequency varies; message and data rates may apply. Reply STOP to unsubscribe at any time, or HELP for help.
If you opt in to WhatsApp, you agree to receive launch news and updates from us on WhatsApp at the number you provided. You can opt out at any time by replying or using the opt-out option in any message. WhatsApp messages are also subject to WhatsApp’s and Meta’s own terms and privacy practices.
04Cookies
We currently use only cookies that are necessary to operate the site and remember your preferences. You can control cookies through your browser settings; disabling them may affect how the site functions. If we add analytics or other non-essential cookies in future, we will update this Policy and, where required by law, request your consent before setting them.
05How We Share Information
We do not sell your personal information. We share it only with:
- Service providers that act on our behalf, for example, email, SMS and messaging (WhatsApp/Meta), website hosting, and similar vendors, under contracts that limit their use of your data to providing services to us;
- Our licensed providers, the companies that are licensed to commercialise InoQlate’s technology. Where you opt in, we share your contact details with them so they can contact you about the product, including for marketing, through the channels you selected. Each licensed provider is responsible for its own messages, and its own privacy policy applies to them;
- Legal and safety recipients, where required to comply with law, enforce our terms, or protect our rights, users, or the public;
- Business transfers, in connection with a merger, acquisition, reorganisation, or sale of assets, where your information may be transferred subject to this Policy.
06International Data Transfers & Storage
InoQlate is based in Canada and operates globally. We and our service providers may process and store your information in countries other than your own. Where you have agreed a specific storage location with us, we store your information accordingly where feasible.
Where the law requires it, we put appropriate safeguards in place for cross-border transfers, for example, the European Commission’s Standard Contractual Clauses for personal data from the EEA, the UK Addendum (or UK International Data Transfer Agreement) for personal data from the UK, and a recognised transfer mechanism (together with any separate consent) for personal information from China under the PIPL and from Brazil under the LGPD. You can request a copy of the relevant safeguards using the contact details in Section 12. By using the Services and giving your consent, you understand your information may be transferred to and processed in those locations.
The product itself, and any personal information processed through it, is controlled by the licensed provider you deal with, under that provider’s own privacy policy and data-residency arrangements. For users in China, the product and its data are handled by a China-based provider and kept in China.
07Our EU and UK Representatives
Because we offer the Services to people in the European Economic Area and the United Kingdom from outside those regions, we are required to appoint local representatives under Article 27 of the EU GDPR and the UK GDPR. These representatives act as a point of contact for individuals and supervisory authorities on questions about how we handle personal data.
EU Representative: [Name, address, and contact email — to be appointed]
UK Representative: [Name, address, and contact email — to be appointed]
08Data Retention
We keep your contact details and preferences for as long as you remain subscribed or as needed for the purposes above. We retain consent and opt-out records for at least three years after you unsubscribe to demonstrate compliance, then delete or anonymise information when it is no longer needed.
09Your Privacy Rights
Depending on where you live, you have different rights over your personal information. We will not discriminate against you for exercising your rights.
How to make a request
To exercise any right, contact us at privacy@inoqlate.com. So we can respond securely, we may ask you to confirm your identity and the details of your request, for example, the email or phone number you signed up with. We will not use that information for any purpose other than handling your request. You may use an authorised agent where your local law allows it. There is no charge for a reasonable request, and you will not be penalised for making one.
How quickly we respond
We aim to acknowledge requests promptly and to respond within the timeframe required by your local law. If we need more time or more information, we will tell you. Indicative timeframes are:
| Region | Target response time |
|---|---|
| EU / UK (GDPR) | Within 1 month, extendable by 2 further months for complex requests |
| California (CCPA/CPRA) | Within 45 days, extendable by a further 45 days |
| Brazil (LGPD) | Without undue delay, and within 15 days for confirmation/access requests |
| Canada (PIPEDA) and elsewhere | Within 30 days, or as required by your local law |
Canada
Under Canada’s federal privacy law (PIPEDA) and similar provincial laws, you may request access to and correction of your personal information and may withdraw your consent at any time. If you have a concern we cannot resolve, you may contact the Office of the Privacy Commissioner of Canada.
European Union & United Kingdom
Under the GDPR / UK GDPR you may request access, rectification, erasure, restriction, or portability of your personal data, object to certain processing, and withdraw consent. You may also lodge a complaint with your local supervisory authority (or the UK Information Commissioner’s Office). You can also contact our representatives (see Section 7).
China
Under the Personal Information Protection Law (PIPL), we process your personal information on the basis of your consent, and we obtain separate consent where required, including before sharing your details with our licensed providers and before transferring your information outside China. You may access, correct, or delete your information, withdraw consent, request portability, and ask us to explain how we handle your personal information.
Brazil
Under the Lei Geral de Proteção de Dados (LGPD), you may confirm whether we process your data and request access, correction, anonymisation, blocking, deletion, portability, and information about with whom we share your data, and you may withdraw consent. You may also contact our Data Protection Officer at privacy@inoqlate.com and, if needed, the Brazilian data protection authority (ANPD).
United States (California)
California residents have rights under the CCPA/CPRA, including the right to know, delete, and correct personal information, and to opt out of its “sale” or “sharing” for cross-context behavioural advertising. We do not sell or share personal information for cross-context behavioural advertising.
Australia
Under the Privacy Act and the Australian Privacy Principles, you may request access to and correction of your personal information and may complain to us and, if unsatisfied, to the Office of the Australian Information Commissioner (OAIC).
Other countries
Many countries have their own privacy laws. We aim to comply with the privacy laws that apply to you, and if your local law gives you additional rights, please contact us and we will do our best to honour them.
10Security
We use reasonable administrative, technical, and organizational measures to protect your information. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. If a data breach affects your rights, we will notify you and the relevant authorities where the law requires it.
11Children’s Privacy
The Services are not directed to children under 18, and we do not knowingly collect their personal information. If you believe a child has provided us information, contact us at privacy@inoqlate.com and we will delete it.
12Changes to This Policy
We may update this Policy from time to time. We will post the revised version with a new “Last updated” date and, where appropriate, notify you. Continued use of the Services after changes take effect means you accept the updated Policy.
13Contact Us
Questions about this Policy or your information? Contact: