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, including:

• Personal Information Protection and Electronic Documents Act (PIPEDA)
• Quebec Law 25 (Act to Modernize the Provisions of the Legislations Relating to the Protection of Personal Information)
• Private Sector Personal Information Protection Act (Quebec)
• Access to Information and Protection of Privacy Act (Ontario)
• Canada's Anti-Spam Legislation (CASL)

1. Privacy Officer

In accordance with Quebec's Law 25, we have designated a privacy officer:

2. Information We Collect

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

a) Personal Identifying Information

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

b) VoIP Service Data

• Call metadata (numbers dialed, duration, time)
• Call recordings (if the 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:

• Provide and bill for our VoIP services
• Comply with our legal obligations in relation to telecommunications
• Troubleshoot and improve service quality
• Prevent fraud and ensure network security
• Communicate with you about your account
• Send marketing communications (with your consent)
• Respond to legal and regulatory requests

4. Legal Bases for Processing

Under Canadian and Quebec laws, we process your data on the following bases:

• Contract performance: 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 interests: 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 obligated to protect your data.

b) Legal Requirements

We may disclose information when required by law, including:

• Responding to subpoenas or court orders
• Cooperating with law enforcement investigations
• Complying with CASL reporting obligations
• Enforcing or defending 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 contract termination (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 transmission or electronic storage is completely secure.

8. Your Rights

Under Canadian and Quebec laws, you have the following rights:

a) Right of access

You may request a copy of your personal data that we hold.

b) Right to rectification

You may request 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 erasure

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

e) Right to complain

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

To exercise your rights, contact our Privacy Data Protection Officer using the details provided in section 1.

9. Cookies and Similar Technologies

We use cookies and similar technologies for:

• Essential functionality (authentication, preferences)
• 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 to individuals under 14 years of age. We do not knowingly collect personal information from children without verifiable parental consent.

11. Changes to the Policy

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

12. Contact

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