Privacy Policy

At Clemento (16390544 Canada Inc.), we take the protection of your personal information seriously. This policy describes how we collect, use, disclose and protect your information in accordance with applicable Canadian laws, in particular:

• Personal Information Protection and Electronic Documents Act (PIPEDA; in French, "Loi sur la protection des renseignements personnels et les documents électroniques" — LPRPDE)
• Loi 25 (Quebec's Law 25 — Act to modernize legislative provisions as regards the protection of personal information)
• "Loi sur la protection des renseignements personnels dans le secteur privé" (Act respecting the protection of personal information in the private sector) (Quebec)
• Freedom of Information and Protection of Privacy Act ("Loi sur l'accès à l'information et la protection de la vie privée") (Ontario)
• Canada's Anti-Spam Legislation (CASL; in French, "Loi anti-pourriel du Canada" — LCAP)

1. Person in charge of the protection of personal information

In accordance with Quebec's Loi 25 (Law 25), we have designated a person in charge of the protection of personal information:

2. Information we collect

As a VoIP service provider, we may collect the following types of information:

a) Personal identification information

• Full name, address, phone number, email address
• Banking or credit card details for payment processing
• Business number and proof of identity for verification

b) VoIP service data

• Call metadata (numbers dialed, duration, time)
• Call recordings (if this service is enabled)
• IP addresses and information about connected devices
• Configuration and troubleshooting logs

c) Technical information

• IP address, browser type, operating system
• Cookie data and similar technologies
• History of interactions with our website

3. Purposes of processing

We use your personal information for the following purposes:

• Providing and billing our VoIP services
• Complying with our legal obligations relating to telecommunications
• Troubleshooting and improving service quality
• Preventing fraud and ensuring network security
• Communicating with you about your account
• Sending marketing communications (with your consent)
• Responding to legal and regulatory requests

4. Legal bases for processing

In accordance with Canadian and Quebec laws, we process your data on the following bases:

• Performance of a contract: Necessary to provide our VoIP services
• Legal obligation: Compliance with telecommunications laws
• Consent: For marketing and certain cookies (you may withdraw your consent at any time)
• Legitimate interest: Network security, fraud prevention, service improvement

5. Sharing of information

We may share your information in the following circumstances:

a) Service providers

We engage third parties to help us provide our services (hosting, payment processing, technical support). These parties are contractually required to protect your data.

b) Legal requirements

We may disclose information when required by law, including to:

• Respond to a subpoena or court order
• Cooperate with law enforcement investigations
• Comply with CRTC reporting obligations
• Exercise or defend our legal rights

c) Business transfers

In the event of a merger, acquisition or sale of assets, your information may be transferred, subject to this policy.

6. Data retention

We retain your personal data only as long as necessary for the purposes described:

• Billing data: 7 years (Canadian tax requirement)
• Call metadata: 12 months (CRTC compliance)
• Call recordings: Until you delete them or for 6 months after the end of the contract (whichever comes first)
• Account information: Up to 2 years after account deactivation

Anonymized data may be retained indefinitely for statistical purposes.

7. Data security

We implement appropriate technical and organizational measures to protect your data:

• AES-256 encryption for VoIP communications and data in transit
• TLS protocols for web communications
• Strict access controls and two-factor authentication
• Regular security audits
• Staff training on data protection

Despite these measures, no method of electronic transmission or storage is completely secure.

8. Your rights

In accordance with Canadian and Quebec laws, you have the following rights:

a) Right of access

You may request a copy of the personal data we hold about you.

b) Right to rectification

You may request the correction of inaccurate or incomplete data.

c) Right to withdraw consent

For processing based on consent (e.g. marketing), you may withdraw your consent at any time.

d) Right to deletion

In certain circumstances, you may request the deletion of your data, subject to legal retention obligations.

e) Right to lodge a complaint

If you believe we are violating your rights, you may file a complaint with:

To exercise your rights, contact our data protection officer at the contact details provided in section 1.

9. Cookies and similar technologies

We use cookies and similar technologies for:

• Essential functionality (authentication, preferences)
• Audience analytics (Google Analytics)
• Targeted advertising (with your consent)

You can manage your preferences through your browser settings.

10. Children's privacy

Our services are not directed at persons under 14 years of age. We do not knowingly collect personal information from children without the verifiable consent of a parent or guardian.

11. Changes to this policy

We may update this policy from time to time. We will inform you of significant changes by email or through a notice on our website. The date of the last update appears at the top of this page.

12. Contact

For any questions or concerns regarding this policy or our privacy practices, please contact us: