How we protect your personal information

1. Introduction

CogniPulse Inc. ("CogniPulse," "we," "us," or "our") is committed to protecting the privacy and security of personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. This Privacy Policy explains how we collect, use, disclose, retain and safeguard personal information when you visit cognipulse.life, use our real-time AI inference platform, enrol in programmes, engage our professional services or otherwise interact with CogniPulse Inc. We review this policy periodically to reflect changes in our practices and applicable law.

Our registered office is located at 55 Algoma Street South, Suite 302, Thunder Bay, ON P7B 3C2, Canada. For privacy-related enquiries, contact our Privacy Officer at [email protected].

2. Scope

This policy applies to personal information collected through our website, contact forms, platform onboarding processes, programme enrolment, professional service engagements and customer support channels. It does not apply to third-party websites or services linked from our platform, which are governed by their own privacy policies.

Where CogniPulse processes personal information on behalf of enterprise clients as a service provider, the terms of the applicable data processing agreement between CogniPulse and the client govern processing activities. This policy supplements but does not override such agreements.

3. Information we collect

3.1 Information you provide directly

We collect personal information that you voluntarily provide, including:

• Contact details: full name, email address, telephone number, organisation name and job title
• Enquiry content: messages submitted through our contact form, including subject type and free-text descriptions of your inference architecture requirements
• Programme enrolment data: billing information, team member details and prerequisite documentation
• Consent records: timestamps and scope of PIPEDA consent provided through web forms
• Support communications: correspondence with our platform engineering and customer success teams

3.2 Information collected automatically

When you visit our website, we may automatically collect certain technical information, including:

• IP address and approximate geographic location derived from IP
• Browser type, operating system and device identifiers
• Pages visited, referral URLs and time spent on pages
• Cookie identifiers and similar tracking technologies as described in our Cookie Policy

3.3 Platform usage data

Enterprise clients using the CogniPulse inference platform may generate operational data including model serving metrics, signal routing logs and pulse analytics. Such data may contain personal information if client workloads process personal data. Processing of client workload data is governed by the applicable enterprise agreement and data processing addendum.

4. How we use personal information

We use personal information for the following purposes, relying on consent, contractual necessity or legitimate business interests as appropriate under PIPEDA:

• Responding to enquiries, pulse briefing requests and pilot programme consultations
• Delivering programmes, professional services and platform access
• Processing transactions and managing billing relationships
• Providing customer support and platform success reviews
• Improving our website, platform capabilities and service offerings
• Sending service-related communications about programme schedules, platform updates and governance notifications
• Complying with legal obligations, regulatory requests and dispute resolution
• Protecting the security and integrity of our platform and preventing fraud

We do not use personal information for purposes materially different from those described without obtaining additional consent.

5. Legal basis and consent

Under PIPEDA, we obtain meaningful consent before collecting, using or disclosing personal information, except where permitted or required by law. Consent may be express (e.g., checking the PIPEDA consent box on our contact form) or implied where the purpose is obvious and you voluntarily provide information.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may limit our ability to provide certain services. To withdraw consent, contact [email protected].

6. Disclosure of personal information

We do not sell personal information. We may disclose personal information to:

• Service providers who assist with hosting, email delivery, payment processing and analytics, bound by confidentiality and data protection obligations
• Professional advisors including legal counsel and accountants under privilege
• Law enforcement or regulatory authorities when required by law or to protect rights and safety
• Successors in the event of a merger, acquisition or asset sale, with notice to affected individuals where required
• Enterprise client administrators where you access the platform under a client account

Cross-border transfers of personal information to service providers in the United States or other jurisdictions are conducted with appropriate safeguards including contractual clauses requiring PIPEDA-equivalent protection.

7. Data retention

We retain personal information only as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes and enforce agreements. Contact form submissions are retained for twenty-four months unless a business relationship is established, in which case records are retained for the duration of the relationship plus seven years for regulatory compliance. Platform usage logs follow configurable retention policies agreed with enterprise clients.

8. Security measures

CogniPulse implements administrative, technical and physical safeguards appropriate to the sensitivity of personal information, including encryption in transit and at rest, access controls, audit logging, vulnerability assessments and employee privacy training. No method of transmission or storage is completely secure; we cannot guarantee absolute security but continuously improve our controls.

9. Your rights under PIPEDA

You have the right to:

• Access personal information we hold about you and receive an account of its use and disclosure
• Request correction of inaccurate or incomplete personal information
• Challenge our compliance with PIPEDA by contacting our Privacy Officer
• File a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated

Access requests may be subject to a nominal fee where permitted by law. We respond within thirty days unless an extension is required.

10. Children's privacy

Our platform and services are directed at business professionals and enterprise clients. We do not knowingly collect personal information from individuals under eighteen years of age. If we become aware of such collection, we will delete the information promptly.

11. Inference workload data

When enterprise clients deploy models through CogniPulse that process personal data, the client acts as the data controller and CogniPulse acts as a data processor. Clients are responsible for ensuring lawful basis for processing and configuring governance policies. CogniPulse provides tools for audit trails, data residency configuration and ephemeral processing modes but does not independently determine the purposes of client workload processing.

12. Automated decision-making

CogniPulse platform features may include automated inference routing and model selection based on configured policies. These automated processes operate on technical parameters such as latency budgets and node capacity — not on personal characteristics. Where client workloads involve automated decisions affecting individuals, clients are responsible for providing appropriate notice and recourse mechanisms under applicable law. CogniPulse supplies audit trails and explainability exports to support client compliance obligations.

13. Marketing communications

With your consent, we may send informational communications about programmes, platform updates and industry insights relevant to real-time AI inference. You may opt out of marketing communications at any time by clicking the unsubscribe link in any email or contacting [email protected]. Service-related communications necessary for programme delivery or platform operation are not marketing and cannot be opted out of while you maintain an active engagement.

14. Data breach notification

In the event of a breach of security safeguards involving personal information that poses a real risk of significant harm, CogniPulse will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA. Notifications will describe the nature of the breach, the personal information involved, steps taken to mitigate harm and contact information for further enquiries. We maintain an incident response plan reviewed annually by our Privacy Officer and tested through tabletop exercises with our platform engineering team.

15. Changes to this policy

We may update this Privacy Policy to reflect changes in our practices, technology or legal requirements. Material changes will be posted on this page with an updated "Last updated" date. Continued use of our services after changes constitutes acceptance of the revised policy where permitted by law.

16. Contact

Privacy Officer
CogniPulse Inc.
55 Algoma Street South, Suite 302
Thunder Bay, ON P7B 3C2, Canada
Email: [email protected]
Telephone: +1 (807) 555-3619