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Privacy Policy

Last updated: June 28, 2026.

1. Who We Are

thinqOS is a product of AI4Outcomes, operated by DeMers IT Inc., a company incorporated in Ontario, Canada. This policy explains what we collect, how we use it, and your rights under applicable privacy law. For users in Canada this includes PIPEDA and provincial privacy laws (such as Quebec's Law 25 and the BC and Alberta PIPA); for users in the EU and UK it includes the GDPR and UK GDPR; for users in the United States it includes state privacy laws such as the CCPA and CPRA.

2. Information We Collect

We collect the following categories of information:

3. How We Use It

We do not sell your data, we do not use your cognitive state to train third-party models without your explicit consent, and we do not share your data with advertisers. For the purposes of the CCPA and CPRA, we do not "sell" or "share" personal information as those terms are defined.

4. Where Your Data Lives

5. Third Parties and Sub-processors

We use the following sub-processors to operate the platform:

We will give notice to registered users before adding a new sub-processor that materially changes how your data is handled. Enterprise customers may request a data-processing agreement (DPA) at legal@thinqos.com.

6. International Users, Legal Bases, and Transfers

thinqOS is operated from Canada, and your data is processed in Canada and the United States, including by the sub-processors listed above. Where the GDPR or UK GDPR applies to you, our legal bases for processing are the performance of our contract with you (to provide the platform), your consent where we request it, and our legitimate interests in operating, securing, and improving the service. Cross-border transfers out of the EU or UK rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum. If you are in Quebec, additional rights and French-language obligations under Law 25 apply, and you may contact us to exercise them.

7. Your Rights

Under applicable privacy law, including PIPEDA and provincial Canadian laws, and, where they apply to you, the GDPR, UK GDPR, and US state privacy laws, you have the right to:

To exercise any of these rights, contact us at legal@thinqos.com.

8. Data Retention

We keep each category of data only as long as needed:

Anonymized, aggregated data may be kept longer for service improvement and abuse prevention.

9. Cookies and Local Storage

We use a Clerk session cookie for authentication and a session-storage key that tracks an active admin impersonation session. We use no analytics, tracking, or advertising cookies.

10. Security

11. Data Breach Notification

If a breach of our security safeguards creates a real risk of significant harm, we will notify affected users and the Office of the Privacy Commissioner of Canada as required under PIPEDA, without undue delay. Where the GDPR or UK GDPR applies, we will also notify the relevant supervisory authority within 72 hours of becoming aware of a qualifying breach, and affected individuals where required.

12. Children's Privacy

thinqOS is intended for adults. You must be at least 18 years old to use it, and it is not directed to children. If you believe someone under 18 has created an account, contact us at legal@thinqos.com.

13. Changes to This Policy

We may update this policy from time to time. "Material changes" means changes to the data we collect, how we use or share it, retention, or your rights. We will give at least 30 days' notice of material changes by email to registered users and in-product. Continued use after the notice period constitutes acceptance.

14. Contact

Questions about this policy? Contact us at legal@thinqos.com.