Privacy Policy

01 · Who we are

This Privacy Policy explains how epono corp, operating as epono ("epono", "we", "us"), collects, uses, discloses and protects personal information when you use epono.ca, the epono application and our services (the "Services"). It applies to Customers, to Loved Ones (Recipients), to visitors of our website, and to anyone who contacts us.

epono is responsible for the personal information described here. LumosTech B.V., a Netherlands company, develops and operates parts of our technology on our behalf as a service provider bound by a data processing agreement.

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where they apply, provincial privacy laws including British Columbia's Personal Information Protection Act and Quebec's Act respecting the protection of personal information in the private sector. Where the EU or UK General Data Protection Regulation applies to you, Section 16 also applies.

02 · Our Privacy Officer

We have designated a Privacy Officer who is accountable for our compliance with this Policy. You can reach the Privacy Officer at privacy@epono.ca.

03 · What we collect

About you (the Customer)

• Identity and contact details: full name, email address, phone number, preferred language, and the sign-in method you use (an email address and password, Google or Apple sign-in, or a Canadian mobile number and a one-time code we send to it).
• Payment details: a reference to your payment method, its brand, last four digits and expiry date. Your full card number is held by our payment processor, never by us.
• Order details: your Requests, Briefs, approvals, Orders, messages with your Coordinator, problem reports, reviews and your epono Pro membership history.
• Photos you add: photos you add to the AI assistant conversation in your account, to a problem report or to a support ticket. We do not analyse them, and our staff can open them only where they can see the Request, report or ticket they belong to; each time a member of our staff opens one is recorded.
• Compliance records: your checkout declarations (with the time and network address from which they were made) and the results of our compliance checks.
• Technical data: IP address, device and browser information, approximate location derived from your IP address, and security logs.

About your Loved One

• What you give us: name, relationship to you, phone number, preferred language, address and preferred notification channels, and, if you mark it, where the address is on a map.
• What the service needs: the details of the task — for example the time and place of an appointment, a shopping list, a description of a repair.
• Health-related information: some services, such as accompaniment to a medical appointment, may reveal information about a person's health. We treat this as sensitive information.
• If your Loved One uses their own access: their sign-in sessions and the requests and confirmations they make, including a mark on the map that they place, move or confirm for their address. If they use their device's location to place it, we keep only the mark.

From the AI assistant

The text of your conversation with the AI assistant and the Brief it produces, and any photos you add to the conversation in your account. If you open a support ticket from the assistant in your account and choose to attach the conversation, we keep that conversation with the ticket.

If a partner referred you

If you arrive through a link or a code from one of our sales partners, or with a Local Partner's link to an Order or its free-month code, we record that partner against your account when you sign up, with the page you arrived on and any campaign tags in the link. This record does not change afterwards, except that in exceptional cases, such as a sign-up through the wrong link that the partners concerned confirm, a senior member of our team may correct it; the correction, its reason and who made it are recorded.

When you follow a partner's link or scan its QR code, we count the visit before taking you on to our website, whether or not you then sign up: the time, whether it was a link or a QR code, the kind of device, the website the link was on and your country. We set no cookie for this and do not keep your IP address. To count a visitor once a day, we keep a code made from your connection, your browser and the date, which changes every day and cannot be turned back into either. The partner sees only the totals.

If a Local Partner prepared an Order for you

A Local Partner that prepares an Order for you sends us the service, its description and price, and the delivery details of the person who receives it: their name, phone number and address, their relationship to you if given, and the date and time of delivery. It does not send us your name or your contact details, and we refuse them if it tries. When you load the Order, you confirm those details and that you have the receiving person's permission to give them to us, and they are saved in your account like a Loved One's address. A free-month code a Local Partner gives us may carry its own reference number for you, never your name or contact details.

From Local Providers

Evidence that a service was completed, such as photographs, receipts and short reports. We ask Local Providers not to photograph people unless it is necessary and agreed.

We do not knowingly collect information about children under 16 except as a Loved One where you have arranged a service for a family member and given us only what that service requires.

04 · Why we use it

We use personal information only for the purposes we explain here, or that a reasonable person would consider appropriate in the circumstances:

• to create and secure your account and verify your identity;
• to prepare, price, carry out and report on Requests and Orders;
• to take payments, issue refunds and manage epono Pro and epono Credit;
• to give a Local Partner's customers the Orders and the free months of epono Pro it arranged for them, and to pay our partners what we owe them;
• to meet our obligations under Canadian sanctions law and to detect fraud, abuse and unusual ordering patterns;
• to communicate with you and your Loved One about Orders, including essential payment and service messages;
• to handle problems, complaints and reviews;
• to keep the records required by law and to cooperate with lawful requests from authorities;
• to protect the security of our Services, our staff and our users;
• to improve our Services, using aggregated or de-identified information wherever possible;
• to understand what our customers order and respond to, so that the offers we make are ones they want, within limits we set ourselves;
• to send you news and offers: with your consent, or by email for two years after an Order, as Canadian law allows, until you unsubscribe.

05 · Your consent

By creating an account and accepting our Terms of Service, you consent to the collection, use and disclosure of your personal information as described in this Policy. Where we handle sensitive information — such as health-related details — or transfer information outside Canada, we ask for your express consent.

When you give us information about your Loved One, you confirm that you have told them about epono and this Policy and that you have their permission to share it, including any health-related information. If you cannot obtain that permission, do not share the information.

We send news and offers by text message or WhatsApp only if you tick the box for that channel in Settings, and by email only if you tick its box or have placed an Order in the last two years, as Canada's Anti-Spam Legislation allows. We record when and how you agreed. Every such message says it is from epono, gives our mailing address and includes a way to stop: the link in every email, or replying STOP to a text or WhatsApp message. Stopping takes effect at once and does not affect messages about your own Orders. You can withdraw your consent to other uses at any time, subject to legal or contractual restrictions; we will explain the consequences — for example, we cannot arrange a service without the information it requires.

06 · Sanctions laws

Canadian law requires us not to deal with listed persons, and our banking and payment partners require us to show that we do not. We use the information described in this Policy, including your checkout declarations, to meet those obligations. A concern may result in an Order being held, reviewed by a person, or refused. We keep these records as set out in Section 10.

We do not carry out identity verification ("KYC") on Loved Ones and have no account or commercial relationship with them.

07 · Who we share it with

We do not sell personal information. We share it only as follows, and only to the extent needed:

• Local Providers in the destination country receive your Loved One's name, phone number and address (with its mark on a map, if there is one), and the details of the task, only once they have accepted the job. They never receive your identity, your contact details, your payment information or the price you paid.
• Your Coordinator and our authorised staff, on a need-to-know basis tied to their role. Coordinators see your Loved One's contact details only once your Request is assigned to them. Our sales staff see your name, email address, the partner or channel you came through and how far you have gone (signed up, ordered), and nothing about your Requests or your Loved Ones. Staff access to sensitive records is logged.
• Sales partners who referred you to us. We pay them a fixed amount for paid orders, and they receive a statement listing each order by a reference, its date and the amount owed to them. They never receive your name, your contact details, your Loved One's details or what you ordered.
• Local Partners who prepared an Order for you or gave you a free-month code. They already hold the details they sent us. For an Order, they see whether and when it was loaded, where it stands (for example priced, paid, under way, completed or cancelled), its price and their share of it, and, when they carry it out, what a Local Provider receives (above). For a code, they see whether and when it was used, until when the free month runs and whether you kept epono Pro after it. They never receive your name, your contact details, your payment details or anything about your other Orders.
• Service providers who host, secure and operate the Services on our behalf, listed in Section 9.
• Payment processors, to take payments and refunds.
• Professional advisers, such as lawyers, accountants and auditors, under a duty of confidentiality.
• Authorities, where we are required or permitted by law — for example in response to a court order or a lawful request from a regulator or law-enforcement body.
• A successor business, if epono is reorganised, merged or sold, subject to equivalent protections.

08 · Where your information is stored and processed

Your information is processed in Canada and in other countries, including the United States (where our main database and application hosting are located) and the Netherlands (where our technology team works). Information about your Loved One and the task is also processed in the country where the service is carried out, by the Local Provider.

When information is processed outside Canada, it is subject to the laws of that country and may be accessible to its courts, law-enforcement and national-security authorities. The legal protections for personal information in some destination countries are weaker than in Canada. We reduce this risk by giving Local Providers only the minimum information needed, only when they need it, and by contractual commitments; but we cannot fully eliminate it. If you are in Quebec, we assess each such transfer before it takes place as Quebec law requires.

09 · Our service providers

We use the following service providers (sub-processors). We will keep this list current and update it before adding a new provider that handles personal information.

• Vercel — application hosting, website analytics and page-speed measurement (United States)
• Neon — database (United States)
• Cloudflare — security, content delivery, file storage and backups (global network)
• Stripe — payment processing (Canada, United States and other locations)
• Apple — sign-in with Apple, where we offer it (United States)
• Google — sign-in with Google, and the AI model that powers the AI assistant, including, when you ask the assistant in your account about your account, the account information needed to answer (United States and other locations)
• Resend — transactional email, and our news and offers by email if you receive them (United States)
• Twilio — text messages: the one-time codes for signing in with a mobile number and for confirming a phone number, notifications by text message, and our news and offers by text message or WhatsApp if you agreed to them (United States)
• Meta — WhatsApp, through Twilio, for our news and offers if you agreed to receive them there; and, if you may receive our emails, a scrambled copy of your email address and phone number for our advertising (Section 10) (United States and other locations)
• Anthropic — the AI model that suggests offers to our sales team, from figures about your account that never include your name or contact details (United States)
• Apify — searches of public business listings and public social media pages for businesses and organisations that could work with us; it receives no information about our customers (United States and European Union)
• Telegram — notifications, if you connect your Telegram account to epono (data centres in several countries)
• Titan — business email
• LumosTech B.V. — software development and technical operations (Netherlands)

Notifications go by text message or Telegram according to the choices in your account. News and offers go by email, text message or WhatsApp according to your choices in Settings.

We are preparing a map on which you and your Loved One can mark where an address is. The map images will come from a provider that receives the area of the map being viewed and the viewer's IP address, never a name or an address. We will name that provider here before the map is turned on.

10 · How long we keep it

We keep account, order, payment, communication (including AI assistant conversations), declaration, compliance and audit records for as long as we need them to provide the Services and to meet our tax, financial and sanctions-law obligations, or as our legitimate need to defend legal claims justifies. We do not delete them automatically on a fixed date. Technical and security logs are kept for shorter periods unless needed for an investigation. Photos you add to the AI assistant conversation are deleted after a day if you do not approve a Brief; once you approve it, they are kept with your Request on the same basis as the rest of it. The details a Local Partner sends us for an Order that nobody loads, including the name, phone number and address of the person who would receive it, are erased 30 days after the Order expires, is withdrawn or is refused; we keep only its reference, its price and what happened to it.

If you ask us to delete your account (Section 14), we anonymise your personal information: your name, email address, phone number and addresses, and your Loved Ones' names, phone numbers and addresses, are removed or replaced, and the account can no longer be signed in to. We keep the financial, compliance and audit records themselves, identified only by reference numbers, because the obligations above still apply to them. We can do this once nothing is still open on your account, such as a Request or an Order in progress, a refund on its way or epono Credit that comes from your own money. Promotional credit, from a promotional code or credit we grant you, ends with the deletion. Removing a Loved One from your account deactivates their record; the record is then kept on the same basis and is not used for any other purpose.

Compliance files. When an Order raises a concern under sanctions law (Section 6), we open a compliance file for it. It holds the Order's reference, the information we relied on, the checks a member of our team made, the decision and the reasons for it, and any correspondence with authorities or our payment partners about it. Only supervisors and our finance team can open a compliance file, every opening is recorded in our audit log, and the file is encrypted separately from the rest of your account (Section 11). A deletion request (Section 14) anonymises the file as described above; it does not remove it, because the obligations above apply to it for as long as they last.

11 · How we protect it

We use safeguards appropriate to the sensitivity of the information, including encryption in transit and at rest, separate encryption of case files, role-based access, immutable audit logs of access to sensitive records, encrypted backups, and confidentiality obligations for staff and contractors. Request content that may include health information is treated as restricted data and is not written to general logs.

No system is perfectly secure. If a breach of security creates a real risk of significant harm to you, we will notify you and the Privacy Commissioner of Canada (and any other authority where required) as soon as feasible.

12 · Automated processing and the AI assistant

The AI assistant drafts a Brief from your conversation. It does not make decisions about you: a person reviews every Request, sets every price and decides whether to accept every Order. Compliance concerns are reviewed by a person: a member of our team decides before an Order is refused for compliance reasons. You may ask us how a decision about you was made and submit observations to a member of our team.

The assistant is provided by Google. Your conversation is sent to Google for processing under terms that prohibit it from using that content to train its models. Please share only what your Request needs.

Offers. Our sales team may ask an AI model, provided by Anthropic, to suggest an offer for a customer. It receives figures about the account, such as how many Orders, their amounts, the services and their ratings, and how long since the last one, and never a name, an email address, a phone number or an address. A member of our team decides whether to make any offer; the AI decides nothing. Offers are epono Credit, never a change to a price you were quoted.

Advertising. If you may receive our emails, we may give Google and Meta a scrambled (hashed) copy of your email address and phone number, so that our advertising reaches people like our customers, or is not shown to people who are already customers. They match it against their own users and do not use it for anything else. Unsubscribing from our emails takes you out of it. We use no advertising cookies.

When you are signed in, the assistant also answers questions about your own account. To do so, and only when your question needs it, it reads your own records: your membership and its renewal date, your Requests and Orders and where they stand, your refunds, your epono Credit and its movements, and your support tickets. That information is sent to Google with your question, under the same terms. The assistant only reads: it cannot change, cancel, pay or refund anything. It never receives your full payment card details, other customers' information, or what we pay Local Providers.

A conversation on our website, before you sign in, stays in your own browser for 24 hours after your last message, so that you can continue it; it is not sent to us for storage unless you approve a Brief. A conversation in your account is not kept by us unless you attach it to a support ticket. An attached conversation is kept with the ticket, can be read only by the Coordinator handling it or a supervisor, and every time it is opened is recorded. Photos you add to a conversation are never sent to Google or to any AI model; they are kept as Section 10 explains.

13 · Cookies

We use essential cookies to keep you signed in and to secure the Services. On our website, we ask on your first visit whether you accept optional cookies and analytics. Only if you do, our analytics (Vercel Web Analytics and Vercel Speed Insights) runs, without cookies and without identifying you, and one cookie remembers which sales partner referred you, if you followed a partner's link. See our Cookie Policy.

14 · Your rights

Subject to legal exceptions, you have the right to:

• ask whether we hold personal information about you and obtain access to it;
• ask us to correct information that is inaccurate or incomplete;
• withdraw your consent, as explained in Section 5;
• ask us to delete your account, which we do by anonymising your personal information as explained in Section 10;
• in Quebec, ask for your information in a structured, commonly used technological format, and ask us to stop disseminating it or to de-index it where the law allows;
• complain to us and to a privacy regulator.

Loved Ones have the same rights over their own information and can contact us directly. From the profile in your account, you can download a copy of your information and ask us to delete your account yourself, and we act on it immediately. You can also write to privacy@epono.ca: we respond as soon as we can, and in any case within 30 days, and may need to verify your identity first. Access requests are free of charge.

15 · Complaints

If you are not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca), the Commission d'accès à l'information du Québec (cai.gouv.qc.ca), or the privacy regulator where you live.

16 · If you are in the European Union or the United Kingdom

If the GDPR or UK GDPR applies to you, epono is the controller. Our legal bases are: performance of our contract with you; our legitimate interests in operating, securing and improving the Services and in complying with sanctions laws; compliance with legal obligations; and your explicit consent for health-related information and marketing. Transfers outside the EEA/UK rely on adequacy decisions (including for Canada) or standard contractual clauses. In addition to the rights above, you may object to processing based on legitimate interests, ask us to restrict processing, and complain to your local supervisory authority.

17 · Changes to this Policy

We will update this Policy when our practices change. If a change is significant, we will tell you by email or in your account before it takes effect. The "Last updated" date at the top shows the current version.

18 · Contact

Privacy Officer — epono corp (registration in progress), trading as epono
privacy@epono.ca