Privacy Policy

Northstar Pulse respects your privacy. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, and the choices and rights you have. We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial law, and we provide additional notices for residents of the United States and the European Economic Area.

01Who we are

This website and the services offered through it are operated by 10128256 Manitoba Ltd., a corporation incorporated in Manitoba, Canada, operating as Northstar Pulse ("Northstar Pulse", "we", "us", or "our"). Our registered address is 10 Nipigon Rd, Winnipeg, MB, R2J 1Y6, Canada. For any privacy question, contact us at [email protected].

For the purposes of Canadian privacy law, our privacy contact acts as our accountability point for personal information under our control.

02Scope of this policy

This policy applies to personal information we collect through northstarpulse.com and any related pages, forms, and communications (the "Site"), and to personal information we collect when we provide lead generation, AI outreach, voice and chat agent, SEO, web design, and custom AI implementation services (the "Services").

Where we process personal information on behalf of a business client as part of the Services, that client is generally responsible for the information they instruct us to process. The "Client data we process" section below explains how those roles are divided.

03Information we collect

We collect only the personal information we need for the purposes described in this policy. Depending on how you interact with us, that may include:

• Contact and identity details you give us, such as your name, business name, email address, phone number, and role, when you book a call, email us, or become a client.
• Communications you send us, including the contents of emails, form submissions, call notes, and messages.
• Business and project information you share so we can scope and deliver the Services, such as your target market, offers, existing tools, and goals.
• Billing information needed to invoice and collect payment. Card payments are handled by our payment processor; we do not store full card numbers on our own systems.
• Technical and usage data collected automatically when you visit the Site, such as IP address, browser type, device type, pages viewed, referring pages, and timestamps. Some of this is collected through cookies and similar technologies as described below.

You are not required to give us personal information, but if you do not, we may be unable to respond to your inquiry or provide the Services.

04How we use information

We use personal information to:

• respond to inquiries, schedule and hold calls, and provide quotes;
• deliver, manage, and improve the Services and the Site;
• set up, configure, and operate the lead generation, outreach, agent, SEO, and AI systems you engage us to build;
• process payments, keep records, and manage our accounts;
• send service messages, updates, and, where permitted, marketing that you can opt out of at any time;
• maintain the security and integrity of our systems and prevent fraud and misuse; and
• comply with legal obligations and enforce our agreements.

05Consent and legal bases

In Canada, we collect, use, and disclose personal information with your consent, except where the law permits or requires us to act without it. Your consent may be express or implied depending on the sensitivity of the information and the purpose. By providing personal information to us, or by using the Site and Services, you consent to the practices described in this policy.

You may withdraw consent at any time, subject to legal or contractual limits and reasonable notice, by contacting us. Withdrawing consent may mean we can no longer provide part or all of the Services. Where the General Data Protection Regulation applies, we rely on the legal bases described in the "EEA and UK residents" section.

06Cookies and tracking

The Site uses cookies and similar technologies to function, to remember your consent choices, and, where you allow it, for analytics and marketing. You can review and change your choices at any time using the cookie banner or the "Cookie Settings" link in our footer. Our Cookie Policy describes each category in detail.

07Sharing and service providers

We do not sell your personal information. We share personal information only as described here:

• Service providers. We use trusted third parties to host the Site, send email and messages, process payments, provide analytics, and run parts of the Services. They may access personal information only to perform work for us and are bound by confidentiality and data protection obligations.
• Professional advisors. We may disclose information to our accountants, lawyers, and insurers where reasonably necessary.
• Legal and safety. We may disclose information where required by law, to respond to lawful requests, to protect our rights, property, or safety, or that of others, and to investigate or prevent fraud or misuse.
• Business transfers. If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to this policy.

08Client data we process on your behalf

When we deliver the Services to a business client, we may process personal information about that client's own leads, prospects, and customers ("Client Data"). In that relationship, the client generally acts as the party responsible for the information (the controller), and we act as a service provider or processor that handles Client Data on the client's documented instructions.

As a service provider, we agree to: process Client Data only to provide the Services or as the law requires; apply reasonable technical and organizational safeguards; use sub-processors that are bound by comparable obligations; assist the client with data subject requests where practical; and return or delete Client Data at the end of the engagement, unless retention is required by law. Clients are responsible for having a lawful basis and any required consents for the Client Data they instruct us to process, and for complying with anti-spam and telemarketing laws as described in our Acceptable Use Policy. A separate data processing addendum is available to clients on request.

09Data retention

We keep personal information only as long as needed for the purposes described in this policy, to provide the Services, to meet legal, tax, and accounting requirements, and to resolve disputes and enforce agreements. When information is no longer needed, we take reasonable steps to delete it or render it anonymous.

10How we protect information

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, and unauthorized access, use, or disclosure. These include access controls, encryption in transit, and limiting access to those who need it. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. You are responsible for keeping any credentials we share with you confidential.

11Your rights in Canada

Subject to legal exceptions, you may ask us to confirm what personal information we hold about you, to give you access to it, and to correct information that is inaccurate or incomplete. To make a request, contact us using the details below. We may need to verify your identity before acting. We will respond within the time required by law. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.

12Notice for United States residents

If you live in a United States state with a consumer privacy law, such as California under the California Consumer Privacy Act as amended by the California Privacy Rights Act, you may have rights to know what personal information we collect, to request access to or deletion of your personal information, to correct it, and to opt out of the sale or sharing of personal information and certain targeted advertising. We do not sell personal information and do not share it for cross-context behavioral advertising as those terms are defined by California law. We will not discriminate against you for exercising these rights. To make a request, contact us at [email protected], and we will verify and respond as the applicable law requires. An authorized agent may submit a request on your behalf with proof of authorization.

13Notice for EEA and UK residents

Where the General Data Protection Regulation or the UK GDPR applies, our legal bases for processing are: your consent; performance of a contract with you; compliance with a legal obligation; and our legitimate interests in operating and promoting our business, provided those interests are not overridden by your rights. You have the right to access, rectify, erase, restrict, and port your personal information, to object to processing based on legitimate interests or direct marketing, and to withdraw consent. You may also lodge a complaint with your local supervisory authority. To exercise these rights, contact us using the details below.

14International data transfers

We are based in Canada, and our service providers may be located in Canada, the United States, or other countries. When personal information is transferred to or accessed from another country, it may be subject to the laws of that country. We take steps to ensure that personal information continues to receive an appropriate level of protection, including through contractual safeguards with our service providers.

15Children's privacy

The Site and Services are intended for businesses and adults. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us and we will take reasonable steps to delete it.

16Third-party links and services

The Site may link to third-party websites and services that we do not control. This policy does not apply to those third parties. We encourage you to review the privacy policies of any site or service you visit through a link from ours.

17Changes to this policy

We may update this policy from time to time. When we do, we will change the "Last updated" date above and, where appropriate, provide additional notice. Your continued use of the Site or Services after an update means you accept the revised policy.

18How to contact us