Privacy Policy
Effective Date: 2 March, 2026
At Fileasure, a Canadian SaaS provider based in Canada serving the financial services sector, we are committed to protecting the privacy and security of our users' personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws. This Privacy Policy outlines the types of personal information we collect, how we use, disclose, safeguard, and retain it when you access or use our SaaS platform, website, and related services (collectively, the "Services"). By using our Services, you acknowledge that you have read and understood this Policy and consent to the collection, use, and disclosure of your personal information as described herein, subject to your rights under PIPEDA.
We designate a Privacy Officer who is accountable for our compliance with this Policy and PIPEDA. You can contact our Privacy Officer at info@momentuum.com for any privacy-related inquiries, complaints, or requests.
Personal Information We Collect
Personal information means any information about an identifiable individual, excluding business contact information used solely for communicating in relation to the individual's employment, business, or profession.
We collect personal information only for identified purposes and with your knowledge and consent, limiting collection to what is necessary. Categories of personal information we may collect include:
a. Account and Contact Information: When you register for an account, subscribe to our Services, or interact with us, we may collect your name, email address, phone number, mailing address, organization name, job title, and payment information (such as credit card details processed through secure third-party payment processors).
b. Financial and Service-Related Data: Given our focus on financial services, we may collect sensitive information such as financial account details, transaction history, or other data you upload or input into our platform to enable features like document management, compliance tracking, or financial reporting. We treat this information with heightened safeguards due to its sensitivity.
c. Usage and Technical Data: We automatically collect information about your interactions with our Services, including IP address, browser type, device identifiers, operating system, pages viewed, time and date of access, and usage patterns. This helps us monitor performance, detect issues, and improve our Services.
d. Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to enhance functionality, analyze trends, and provide personalized experiences. Essential cookies are required for core operations, while others (e.g., for analytics or marketing) require your consent. You can manage preferences via your browser settings or our cookie consent tool.
We do not collect personal information from children under 13, and our Services are not directed to them.
How We Use Your Personal Information
We use your personal information only for the purposes identified at the time of collection or for compatible purposes, and only as permitted by law. These include:
a. Providing and Improving Services: To deliver our SaaS features, process transactions, respond to support requests, customize your experience, and enhance platform functionality, security, and performance.
b. Communications: To send service-related notifications, updates, security alerts, and, with your consent, marketing materials or newsletters about our Services. You may opt out of marketing communications at any time by clicking "unsubscribe" in emails or contacting us.
c. Analytics and Optimization: To analyze usage data for insights into user behavior, service improvements, and trend identification, ensuring our platform meets the needs of financial services users.
d. Compliance and Legal Obligations: To comply with legal requirements, prevent fraud, enforce our terms of service, respond to regulatory requests, or protect our rights, users, or the public.
e. Research and Development: In de-identified or aggregated form, for internal research to develop new features tailored to financial services.
We retain personal information only as long as necessary to fulfill the identified purposes, comply with legal obligations (e.g., tax or financial reporting requirements), or resolve disputes. For example, account data may be retained for up to 7 years post-termination to meet Canadian tax laws. After this period, we securely delete or anonymize it.
Consent
Your consent is required for the collection, use, or disclosure of your personal information, except where permitted or required by law (e.g., for legal compliance).
Consent may be express (e.g., via checkbox during registration) or implied (e.g., by using our Services after notice). We provide clear information about purposes before seeking consent and ensure it is meaningful and informed.
You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting us. Withdrawal may limit our ability to provide certain Services.
Sharing and Disclosure of Personal Information
We do not sell your personal information. We may disclose it only as follows, with appropriate safeguards:
a. Service Providers: To trusted third-party vendors (e.g., cloud hosting, payment processors, analytics tools, or customer support platforms) who assist us in operating our Services. These providers are contractually bound to use the information only for the specified purposes, maintain confidentiality, and comply with PIPEDA-equivalent standards. Some may be located outside Canada (e.g., in the US or EU), where data protection laws may differ. We use contractual measures to ensure comparable protection and will disclose such transfers upon request.
b. Business Transfers: In connection with a merger, acquisition, reorganization, or asset sale, your information may be transferred to the new entity, subject to this Policy.
c. Legal and Safety Reasons: If required by law, court order, or government authority; to prevent harm, fraud, or illegal activities; or to protect our rights or those of others.
d. With Your Consent: For any other purpose with your explicit approval.
Safeguarding Your Personal Information
We implement appropriate physical, organizational, and technical safeguards to protect personal information against loss, theft, unauthorized access, disclosure, alteration, or destruction. Measures include encryption (e.g., TLS for data in transit, AES for data at rest), access controls, regular security audits, employee training, and incident response plans. Given the sensitivity of financial data, we apply enhanced protections such as multi-factor authentication and compliance with industry standards like SOC 2.
Despite these measures, no system is infallible. In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA, and take steps to mitigate harm.
Your Rights and Choices
Under PIPEDA, you have rights regarding your personal information:
a. Access and Correction: You may request access to your personal information we hold, including details on its use and disclosure. We will provide this within 30 days, subject to exceptions (e.g., legal privileges). You can correct inaccuracies by logging into your account or contacting us.
b. Withdrawal of Consent and Opt-Out: As noted above, withdraw consent or opt out of non-essential uses like marketing.
c. Deletion: Request deletion of your personal information when no longer needed, subject to legal retention requirements. Upon account closure, we will delete or anonymize data accordingly.
d. Complaints: If you believe we have mishandled your information, contact our Privacy Officer first. You may also complain to the Office of the Privacy Commissioner of Canada.
To exercise these rights, email info@momentuum.com with verification details (e.g., account info) to protect your privacy.
Changes to This Privacy Policy
We may update this Policy to reflect changes in our practices, legal requirements, or Services. Updates will be posted here with the revised effective date. Material changes will be notified via email or in-app notice. Continued use of our Services after changes constitutes acceptance. We encourage periodic review.
Effective Date: March 2, 2026
Contact Us
For questions, concerns, or to exercise your rights, contact our Privacy Officer at:
Email: info@momentuum.com
Address: Fileasure Privacy Officer, 100 King St W 56th Floor, Toronto, Ontario, Canada
We respond to all inquiries within 30 days.