Privacy Policy
Effective Date: January 19, 2025
At Dead Unicorn Inc., protecting your personal data is our priority.
Whether you use the platform TurboAds (the "Platform") as our client (the "Client") and as part of the management of our contractual relations with our Client, we may collect personal data about you.
The purpose of this policy is to inform you about how we process your personal data in compliance with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), Alberta's Personal Information Protection Act ("PIPA"), and other applicable provincial and federal privacy legislation (together the "Applicable Regulations").
1. Who is the Data Controller?
The data controller is Dead Unicorn Inc., a corporation registered in the Province of Alberta under number 708608609, with its head office located at 105 Midcrest Crescent SE, Calgary, Alberta, Canada ("Us" or "We") when browsing on our Platform or when using your account on our Platform as our Client.
2. What Personal Data Do We Collect?
Personal data is data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.
We may collect the following personal data:
- Identification data (e.g., full name, email addresses);
- Data relating to your professional life (e.g., company name, position/function, company size, company website, logo);
- Data relating to your orders;
- Login data (e.g., logs, IP address);
- Third-party authentication data - If you choose to sign in using a third-party authentication service (e.g., Google or Microsoft), certain data such as your name and email may be collected from that service. By choosing this method, you agree that the service may share this information with us. We do not collect your third-party account password;
- Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID);
- Location data;
- Data related to recordings from communications with our customer care service (e.g., content of calls, dates of calls);
- Economic and financial data (e.g., bank details);
- Payment card data;
- Any information you wish to send us as part of your contact request.
We inform you, when collecting your personal data, whether some of these data are mandatory or optional.
3. On What Legal Basis, For What Purposes, and For How Long Do We Keep Your Personal Data?
The following table outlines our purposes for collecting personal data, the legal basis for each purpose, and how long we retain the data:
| Purpose | Legal Basis | Retention Period |
|---|---|---|
| To provide you with our services available on our Platform through your account | Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract | Duration of your account. Connection logs kept for 10 weeks. Inactive accounts deleted after 2 years. Data may be archived for 5 years for legal purposes. |
| To perform operations related to contracts, orders, invoices and customer relationship management | Performance of a contract to which you are party | Duration of business relationship. Transaction data (except banking data) archived for 5 years. Contract data stored for 7 years. Credit card data retained by Stripe (our payment processor). CVV codes are not stored. |
| To improve our services | Our legitimate business interest in improving our services | Call recordings: 6 months. Call analysis documents: 1 year. Other data: 6 months. |
| To manage your opinions on our products, services or content | Our legitimate business interest in collecting feedback | 2 years from publication of the opinion |
| To create a database of customers and prospects | Our legitimate business interest in developing and promoting our business | Customers: duration of business relationship. Prospects: 3 years from last contact. |
| To send newsletters, requests and direct marketing mailings | Your consent or our legitimate business interest in informing customers of our latest news | 3 years from last contact or until you unsubscribe |
| To answer your information requests and other inquiries | Our legitimate business interest in responding to your inquiries | 3 years from date of last contact |
| To comply with our legal and regulatory obligations | Legal and regulatory obligations | Invoices archived for 7 years. Transaction data archived for 5 years. Contract data stored for 7 years. |
| To elaborate analytics and improve the functionality of the Platform | Your consent (for non-essential cookies) | 25 months |
| To process data subjects' requests to exercise their rights | Our legitimate business interest in responding to your requests and keeping records | Identity verification documents retained only as long as necessary to verify identity, then deleted. |
4. Who Are the Recipients of Your Personal Data?
The following categories of recipients will have access to your personal data:
- (i) The staff of our company;
- (ii) Our service providers and processors, including: artificial intelligence service providers, lip-sync technology providers, generative voice AI providers, hosting service providers (AWS, Vercel), newsletter sending service providers, audience measurement and analysis service providers (Google Analytics), electronic messaging service providers, secure payment service providers (Stripe), invoicing tools, cookie management tools, and advertising platforms (Meta/Facebook);
- (iii) If applicable: public and private organizations, exclusively to comply with our legal obligations.
5. Are Your Personal Data Likely to Be Transferred Outside Canada?
Your personal data is hosted on servers located in the United States of America, provided by AWS and Vercel.
As part of the tools we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside Canada, primarily to the United States. When we transfer personal data outside Canada, we ensure that appropriate safeguards are in place to protect your data, including:
- Contractual clauses with our service providers that require them to protect personal data to a standard comparable to Canadian privacy law;
- Ensuring our service providers maintain appropriate security measures and privacy practices;
- Conducting assessments of the privacy laws and practices in the destination country where appropriate.
6. What Rights Can You Exercise Regarding Your Personal Data?
Under PIPEDA and applicable provincial privacy legislation, you have the following rights with regard to your personal data:
- Right to be informed: You have the right to know what personal information we collect about you and how we use it. This privacy policy serves to inform you of these practices.
- Right of access: You have the right to access your personal data held by us and to receive information about how it has been used and disclosed.
- Right to rectification: You have the right to request correction of your personal data if it is inaccurate, incomplete, or out of date.
- Right to withdraw consent: Where we rely on your consent to process personal data, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Such withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
- Right to file a complaint: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner if you believe your privacy rights have been violated.
You can exercise these rights by contacting us using the contact details below. We may ask you to provide additional information or documents to verify your identity before processing your request.
7. What Cookies Do We Use?
For more information on cookies management, please consult our Cookie Policy available at https://turboads.ai/cookie-policy.
8. Contact Information for Data Privacy Matters
Contact email: support@turboads.ai
9. Modifications
We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.