Privacy Policy

1. Person in charge of the protection of personal information

Friendealer Inc. is responsible for the personal information it holds. The Person in charge of the protection of personal information, Friendealer Inc. can be reached at privacy@friendealer.com (subject: “Privacy”).

2. Our principle: the minimum

You can browse the Site without an account, without cookies and without advertising tools. We only collect information if you choose to join the waitlist, and only what we truly need.

3. Information we collect

If you join the waitlist:

• your email address (required);
• your city and interests, if you choose to provide them;
• the language of the page and the page you signed up from;
• proof of your consent: ticked box, wording displayed, date and time.

To protect the form against abuse: an irreversible fingerprint (salted SHA-256 hash) of your IP address, kept with your sign-up, and a temporary attempt counter (about one hour). We never store your IP address itself.

Technical logs: like any website, our host processes technical data (IP address, browser type, pages requested) to deliver pages and protect the Site against attacks.

Cookieless audience measurement: we may use Cloudflare Web Analytics, which counts visits in aggregate, without cookies, without device fingerprinting and without cross-site tracking.

We do not collect your name, postal address, phone number, precise location or payment data.

4. How we use it

• to email you about the launch of our apps and our activity marketplace, if you consented;
• to decide where and how to start, using the cities and interests provided (as aggregate statistics);
• to run the Site, keep it secure and prevent abuse;
• to meet our legal obligations.

We do not sell or rent your personal information, and we do not use it to profile you for advertising.

5. Consent and Canada’s Anti-Spam Legislation

Signing up requires ticking a separate consent box, never pre-ticked. In line with Canada’s Anti-Spam Legislation (CASL), every email we send will identify us, tell you how to reach us and include a working unsubscribe link. You can withdraw your consent at any time, through that link or by writing to privacy@friendealer.com.

6. Service providers (processors)

We entrust some processing to providers bound by contract to confidentiality and security obligations:

• Cloudflare, Inc.: hosting of the Site (Cloudflare Pages), running the form, storing the waitlist (Workers KV, in Cloudflare’s global network), protection against attacks and cookieless audience measurement. Policy: cloudflare.com/privacypolicy (opens in a new tab).
• An email-sending platform, if we use one for launch announcements; its name will be listed here before any email is sent.

We may also disclose information where required by law, to protect our rights or the safety of others, or as part of a business reorganisation or sale, subject to confidentiality commitments.

7. Transfers outside Québec

Cloudflare operates a global network: your information may be processed or stored outside Québec and Canada, including in the United States. Before entrusting information outside Québec, we assess whether it will be adequately protected (section 17 of the Québec Act) and we govern these transfers by contract. Transferred information may be accessible to the authorities of the country concerned under its laws.

8. Retention

• Waitlist: until you unsubscribe or, at the latest, 24 months after the marketplace launches, then deleted or anonymised.
• Anti-abuse counter: about one hour.
• Host technical logs: for the short periods set by Cloudflare.
• Correspondence about your requests and the incident register: as long as the law requires.

9. Security

We apply reasonable measures suited to the sensitivity of the information: encrypted connections (HTTPS, HSTS), strict security headers, access limited to authorised people, pseudonymisation (sign-ups are stored under a fingerprint of the address, IP addresses are never kept). No method is foolproof, so we cannot guarantee absolute security.

10. Confidentiality incidents

If a confidentiality incident occurs, we promptly take steps to reduce the risk of harm. If it presents a risk of serious injury, we diligently notify the Commission d’accès à l’information du Québec, the Office of the Privacy Commissioner of Canada where required, and the people concerned. Every incident is recorded in a register.

11. Your rights

At any time, you can request:

• access to the information about you;
• its correction if it is inaccurate or incomplete;
• its deletion, or de-indexing where the law provides for it;
• a copy in a structured, commonly used technological format (portability);
• the withdrawal of your consent.

Write to privacy@friendealer.com from the address concerned. We may verify your identity and will reply within 30 days.

12. Children

The waitlist is for people aged 14 and over. In Québec, information about a minor under 14 may only be collected with the consent of the person having parental authority. If we learn that a sign-up comes from a child under 14, we delete it. Parents and guardians: privacy@friendealer.com.

13. Cookies and local storage

The Site uses no cookies: there is no banner to accept. It only saves, in your browser’s local storage, the language you chose (key “fd-lang”), to show it to you next time. You can clear it at any time in your browser settings.

14. Changes

We may update this policy. The date of the last update is shown at the top of the page; for significant changes, we will announce them on the Site and, where the law requires, ask for your consent again.

15. Questions and complaints

Please write to us first at privacy@friendealer.com: we will do our best to resolve the situation. You may also contact the Commission d’accès à l’information du Québec (opens in a new tab) or the Office of the Privacy Commissioner of Canada (opens in a new tab).