Privacy Policy – PULSE
Person responsible for the protection of personal information: Guillaume Knepper, Conseil SNDGK Inc. (contact@conseilsndgk.com)
Jurisdiction: Quebec, Canada
1. Introduction
Conseil SNDGK Inc. ("we", "us", "our", "PULSE") is committed to protecting personal information in accordance with Quebec's Act respecting the protection of personal information in the private sector (Law 25).
This policy explains what data we collect, why we collect it, how it is used, and what your rights are.
Consent to the collection and processing of your personal information is obtained actively when creating your account, through the explicit acceptance of these conditions via a dedicated checkbox. This consent may be withdrawn at any time in accordance with article 8.
2. Personal Information Collected
We only collect information necessary for the operation of the service.
a) Identification
- First and last name
- Email address
This information is collected via Clerk, our secure authentication provider.
b) Payment
- We never have access to full credit card numbers.
- Payment information is tokenized and secured by Stripe in accordance with PCI-DSS standards.
c) Usage Data
- History of generated analyses
- Instructions and content submitted to artificial intelligence
- Technical metadata related to service usage
- Technical logs necessary for security and proper functioning
We do not intentionally collect sensitive personal information.
3. Purposes of Collection
- Authentication and account management
- Generating personalized analyses
- Managing subscriptions and quotas
- Providing technical support
- Improving the service
- Complying with our legal obligations
We do not sell or rent your personal information.
4. Third-Party Processing and Transfer Outside Quebec
- Clerk (authentication)
- Stripe (payment)
- Convex (database)
- Vercel (hosting and application infrastructure)
- Google Gemini (data processing)
These processes may involve a transfer outside Quebec. In accordance with Law 25, a Privacy Impact Assessment (PIA) was conducted on February 12, 2026. A summary of the findings is available upon request from the person in charge of personal information protection.
5. Use of Artificial Intelligence
- Results generated are recommendations.
- No decision producing a direct legal effect on the user is made in an entirely automated manner.
6. Information Security
- Encryption of data in transit (HTTPS / TLS)
- Secure hosting via Vercel
- Restricted access to data according to the principle of least privilege
- Access logging
- Rotation and protection of API keys
- Privacy incident registry
In the event of an incident presenting a serious risk of harm, the persons concerned and the Commission d’accès à l’information du Québec will be notified in accordance with Law 25.
7. Data Retention
- As long as your account is active
- Then deleted within a maximum of 90 days after account closure, unless otherwise required by law (e.g., tax obligations).
8. Your Rights
- Right of access to your information
- Right to rectification
- Right to withdraw consent
- Right to data portability (in a structured and technological format)
- Right to file a complaint with the Commission d’accès à l’information du Québec
To exercise your rights:
📧 contact@conseilsndgk.com
Responsible: Guillaume Knepper
9. Cookies
10. Confidentiality Incident Management
- Notifying the Commission d'accès à l'information du Québec (CAI) as soon as possible.
- Notifying the individuals affected by the incident.
- Maintaining a register of confidentiality incidents.
11. Policy Update
We may modify this policy to reflect changes in the service or legal requirements. The update date will appear at the top of the document.