DRAFT - pending professional review. This is a draft template and is not legal, tax, or financial advice. It should be reviewed by a licensed Ontario lawyer before it is relied on. Bracketed items are placeholders to be confirmed.
This Privacy Policy explains how Two Birds Innovation ("Two Birds", "we", "us", "our") handles information in connection with our websites and free digital products, including the Digital Confidence Centre (a free digital-literacy and scam-safety web tool), our job-search tool, and other static web tools we publish (together, the "Products").
We built these Products to be minimal-data by design. In plain terms: we try to collect as little information as possible, and most of our Products collect no personal information about you at all. This policy is written to be consistent with Canada's federal Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario law.
Summary (the short version):
Across the Digital Confidence Centre and our other static web tools, we do not:
Where a specific Product does collect something (for example, an optional email address you choose to provide - see Section 5), that collection is described in this policy, and you are told about it at the point where you provide it.
We keep the categories of information we handle deliberately small:
| Category | What it is | Why we handle it |
|---|---|---|
| Aggregate usage data | Non-identifying counts and trends via privacy-respecting analytics. | To understand which tools are useful and to improve them. |
| Technical / server data | Standard information your browser and our hosting/CDN provider exchange to serve a page (for example, IP address at the network layer, timestamp, requested file). | To deliver the site, keep it available, and protect it from abuse. |
| Optional email address | Only if you choose to submit it through an opt-in form on a Product. | To send you the specific thing you asked for. |
| On-device data (local storage) | Progress, answers, or preferences a tool saves in your own browser. Stays on your device and is not transmitted to us. | So a tool can remember where you were or what you set. |
We do not combine these categories to identify you, and we do not attempt to re-identify aggregate analytics data.
To understand whether our free Products are actually helping people, we use privacy-respecting, aggregate analytics. These tools are configured to measure trends in the aggregate, not to build a profile of you as an individual. We do not use them to sell data or to serve targeted ads. If and when we add, remove, or change an analytics tool, we will update this section. If you want to see exactly what is in use on a given day, contact us (Section 12).
Some Products may include an optional form where you can choose to give us your email address - for example, to receive a specific resource, an update, or a notification you requested. If you use one of these forms:
If a Product does not show an email form, then that Product does not collect your email.
Under PIPEDA, we rely on consent appropriate to the sensitivity of the information: express (opt-in) consent for anything you actively submit, such as an optional email address (Section 5); and implied consent for low-risk, non-identifying aggregate analytics and the standard technical data needed to serve a web page.
You can withdraw consent at any time (subject to legal or contractual limits), for example by unsubscribing, asking us to delete an optional email, or clearing your browser's local storage. Withdrawing consent will not affect the lawfulness of anything done before you withdrew it. We do not require you to consent to collection, use, or disclosure beyond what is needed to provide a Product, as a condition of using that Product.
We use the limited information described above only to: deliver, host, and secure the Products; understand, in the aggregate, how the Products are used, so we can improve them; respond to you and provide anything you specifically requested; and comply with legal obligations. We do not use information for automated decision-making that produces legal or similarly significant effects about you.
We do not sell your information and we do not disclose it for anyone else's independent marketing. We rely on a small number of reputable service providers ("processors") to operate the Products - hosting / static site delivery, content delivery and security, analytics, and (only where an optional form exists) email/form handling. Each provider only handles the information needed to perform its function. We may also disclose information if required by law, or to protect the rights, safety, or property of Two Birds, our users, or the public.
Storage outside Canada. Some providers may store or process data outside Canada (for example, in the United States or other countries). When data is handled outside Canada, it may be subject to the laws of that country. We choose providers we consider reputable and, where practical, prefer providers or configurations that keep data in Canada.
Our static Products aim to be cookie-light. Where our privacy-respecting analytics can work without cookies, we prefer that configuration. Some tools use browser local storage on your own device to remember your progress, answers, or preferences; this stays on your device and is not transmitted to us. You can clear it any time through your browser settings. Blocking cookies will not stop our core static tools from working, though it may affect features that rely on remembering your on-device preferences.
Aggregate analytics are retained only in non-identifying, aggregate form. Standard server/CDN logs are retained by our hosting/CDN provider for a limited period for security and operations, then discarded. Optional email addresses are retained only until you unsubscribe or ask us to delete them, or until they are no longer needed. On-device local storage is retained on your device until you clear it. We do not keep personal information longer than necessary for the purpose it was collected for, or as required by law.
We take reasonable steps to protect information appropriate to its sensitivity, including serving Products over encrypted connections (HTTPS), minimizing what we collect in the first place, relying on reputable providers with their own safeguards, and limiting who can access any optional email data we hold. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we ever become aware of a privacy breach that creates a real risk of significant harm, we will respond in accordance with our obligations under PIPEDA, which may include notifying affected individuals and the Office of the Privacy Commissioner of Canada.
Subject to legal limits, you have the right to ask what personal information we hold about you (in most cases, for our static tools, the answer is "none"); to access it; to correct it if it is inaccurate; to withdraw consent or ask us to delete an optional email you provided; and to ask how your information has been used or disclosed. To make a request, contact our privacy contact:
Aaron Patzalek, Two Birds Innovation · Contact form · Ontario, Canada
We will respond within the timeframe required by PIPEDA (generally 30 days). If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or the Information and Privacy Commissioner of Ontario (www.ipc.on.ca).
The Digital Confidence Centre is designed to be safe for a wide audience, including seniors and youth. For youth users of our free tools, we do not collect personal information, do not create accounts, and do not run targeted advertising. We do not knowingly collect personal information from children. If a Product ever offers an optional email form, it is not directed at children. If you believe a child has provided us personal information and you would like it removed, contact us (Section 12) and we will delete it.
Two Birds Innovation is based in Ontario, Canada, and operates under Canadian federal and Ontario provincial law. Our handling of personal information in the course of commercial activity is governed primarily by Canada's PIPEDA. Depending on the activity, other laws may apply, such as Canada's Anti-Spam Legislation (CASL) for any commercial electronic messages. If you access our Products from outside Canada, you understand your information will be handled as described in this policy and under Canadian law.
We may update this Privacy Policy from time to time. When we do, we will change the "Last updated" date at the top. Material changes will be highlighted on the affected Product where practical. Your continued use of a Product after an update means you accept the revised policy.
Two Birds Innovation
Attn: Aaron Patzalek, Privacy Contact
Contact: contact form
Ontario, Canada