Effective Date: July 19, 2026
Version 1.1
Introduction
Capfluence Inc. ("Capfluence," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit our website at www.capfluence.app, request a demo, subscribe to our platform, or otherwise interact with us.
This Privacy Policy applies to three groups of individuals:
Website visitors, including anyone who reads the blog, browses information about Capfluence, or fills in a form on the website;
Subscribed users of the Capfluence platform, meaning financial advisors, teams, and firm employees who have been granted access to the platform under a subscription;
Prospects, meaning individuals whose contact information and professional details are surfaced through the platform's contact intelligence features to help subscribed users identify and reach potential clients.
Different sections of this Privacy Policy will be more relevant to different groups. Where a section applies specifically to prospects, we say so.
Capfluence is subject to the Personal Information Protection and Electronic Documents Act ("PIPEDA") federally. Where personal information relates to residents of Quebec, we also comply with An Act respecting the protection of personal information in the private sector, commonly known as Law 25. Where personal information relates to residents of Alberta or British Columbia, we comply with the applicable provincial privacy legislation.
We collect the following categories of personal information.
Information You Provide to Us
Contact and demo request information. When you request a demo or submit a form on the website, we collect your name, business email address, firm or employer, role, and any information you choose to include in your message.
Account information. When you become a subscribed user, we collect information necessary to create and maintain your account, including your name, business email, role, firm affiliation, and authentication credentials.
Communication content. When you communicate with us by email or through the platform, we collect the content of those communications.
Payment information. When you subscribe, we collect billing information as needed to process payment. Payment card information is processed by our payment processor and is not stored by Capfluence.
Information Generated Through Your Use of the Service
Content you create in the platform. As a subscribed user, you may add contacts, notes, custom fields, pipeline data, and other content. We store and process this content to provide the platform to you.
Connected account data. Where you connect an email account or calendar account to the platform, we access data from that account to provide the connected functionality. This may include email metadata, message content, calendar events, attendee lists, and meeting details. We use Nylas as an intermediary provider to establish and maintain these connections.
Usage data. We collect information about how you interact with the platform, including features used, actions taken, session duration, timestamps, IP address, browser type, device type, operating system, and language settings.
Support information. When you contact support or interact with us about the platform, we collect information about your inquiry and any information you provide in the course of resolving it.
Information About Prospects
To provide the contact intelligence features of the platform, Capfluence collects and processes personal information about individuals who are not themselves users of the platform. These individuals are the potential clients whom our subscribed users may wish to identify and reach out to. We describe this practice in more detail in Section 8.
The categories of information we may collect about a prospect include name, professional title and role, employer or firm, verified business contact information (including business email and business telephone number), publicly available biographical information, professional history, professional registrations and credentials, indicators of life or career events that may be relevant to a financial services relationship, and derived attributes or signals produced by our processing of the above.
Website Analytics and Cookies
We use Google Analytics and PostHog to understand how visitors use our website and platform, including which pages are visited, how long visitors stay, and how users interact with product features. These tools use cookies and similar technologies to collect information about your device and browsing activity.
Cookies are small text files that a website places on your device. We use cookies for authentication, session management, security, remembering preferences, and analytics. You can control cookies through your browser settings. Disabling some cookies may affect the functionality of the website or the platform.
How We Collect Information
We collect information in three ways.
Directly from you. Where you provide information to us through a form, subscription, communication, or use of the platform.
Automatically. Through cookies, analytics tools, log files, and connected account integrations.
From third parties. To build and maintain the contact intelligence data we make available through the platform, we collect information about individuals from external sources. These sources are described in Section 4 and Section 8.
We use personal information for the following purposes.
To provide the Service. To deliver the website and platform, authenticate users, process transactions, maintain your account, support connected integrations, produce contact intelligence, generate AI-produced content within the platform, and provide the features you have subscribed for.
To respond to inquiries and requests. To answer questions submitted through the website, schedule demos, respond to support requests, and process requests to exercise privacy rights.
For payment and billing. To process subscription payments, invoice you, and manage renewals.
For product improvement and analytics. To understand how the website and platform are used, identify problems, measure feature adoption, evaluate performance, and improve the Service.
For AI and automated processing. The platform uses automated processing and artificial intelligence to power certain features, including matching and ranking prospects to help a subscribed user identify potentially relevant contacts, drafting suggested content such as emails, generating summaries of meetings, and producing daily briefings for subscribed users. This processing operates on personal information about subscribed users and about prospects. Where such processing produces a suggested output, that output is presented to the subscribed user for review, editing, and decision. Capfluence does not make decisions about any prospect based exclusively on automated processing that produce legal or similarly significant effects on the prospect. The subscribed user remains the decision-maker for any communication or outreach they choose to initiate.
For research, development, and aggregate insights. To improve our AI models, develop new features, publish industry benchmarks and thought leadership, and support other research using aggregated and de-identified data.
For marketing communications to subscribed users, demo requestors, and consenting website visitors. Where you have provided your email address to us through a demo request or another form and have consented to receive further communications from us, we may send you information about Capfluence, product updates, industry insights, and other content. You can withdraw consent at any time by using the unsubscribe link in any commercial email or by contacting privacy@capfluence.app.
For security, fraud prevention, and to protect Capfluence and its users. To detect and prevent unauthorized access, security incidents, misuse of the platform, and violations of our Terms of Service.
To comply with legal obligations and enforce our rights. Including responding to legal process, cooperating with regulators, protecting our legal interests, and enforcing our contracts.
Legal Bases for Collection, Use, and Disclosure
Under PIPEDA and Law 25, personal information is collected, used, and disclosed on the basis of consent except where a lawful exception applies.
For website visitors, subscribed users, and demo requestors, we generally rely on consent (either express or implied through voluntary interaction with us) or on the necessity of processing to perform the contract we have entered into with you.
For prospects, Capfluence collects and processes information from four categories of sources, each with a distinct legal basis.
Government and Regulatory Sources
Publicly accessible records maintained by government or self-regulatory bodies, including corporate filings, statutory registries, professional licensing records, court and tribunal records, and regulatory sanctions. Relied on under PIPEDA's publicly available information provisions and, where applicable, provincial legislation.
Professional and Business Directories
Business contact information published in professional and business directories where the individual has provided the information in connection with their role. Relied on under PIPEDA's publicly available information provisions and business contact information provision.
Licensed Third-Party Data Providers
Business contact and enrichment data supplied to us by licensed data providers who represent to us that they have a lawful basis for supplying it. Relied on under those providers' representations and our own reasonable diligence.
Capfluence-Derived Data
Attributes, signals, and analysis Capfluence generates internally by processing information from the above sources. Relied on under the same legal bases that applied to the underlying data.
We share personal information only as described here.
With service providers. We share information with third parties that provide services to us, including cloud hosting, analytics, payment processing, communications infrastructure, and support tools. Our service providers process personal information on our behalf under contractual obligations to protect that information and use it only as we direct.
With integrated third-party services. Where you connect a third-party service to the platform, we share the information necessary to operate that connection. For example, where you connect an email account, we exchange information with the email provider through Nylas to send, receive, and process messages you initiate. Your use of the connected third-party service remains subject to the terms and privacy practices of that third party.
Between subscribed users of the same firm subscription. Where a subscription covers multiple users at the same firm, information within the shared workspace, including content added to the platform, may be visible to other users under the same subscription and to their supervisors. We describe how this operates further in enterprise agreements where applicable.
For legal reasons. We may disclose personal information if required by law, court order, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others.
In connection with a business transaction. We may disclose personal information to a purchaser, successor, or acquirer in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets. Where such disclosure occurs, we will require the recipient to protect the personal information in a manner consistent with this Privacy Policy or provide affected individuals with a meaningful opportunity to object.
Where Information Is Stored and Processed
Personal information is hosted in Canada. Capfluence's platform runs on Amazon Web Services in the AWS Canada (Central) region, located in Montreal, Quebec. This is our primary and default location for all customer, user, and prospect data.
Some of our service providers, integrations, and analytics tools may process limited personal information outside Canada, including in the United States, in the course of providing services to us. Where personal information is processed outside Canada, it is subject to the laws of the jurisdiction where the processing takes place, including any lawful right of foreign courts, law enforcement, and regulatory authorities to access that information. We apply contractual protections and reasonable safeguards to personal information handled by our service providers regardless of location.
Where we transfer personal information about Quebec residents outside Quebec, we conduct a documented assessment before the transfer as required by Law 25.
How Long We Keep Information
We retain personal information only as long as necessary to fulfil the purposes for which it was collected, to comply with legal, regulatory, contractual, or accounting obligations, to enforce our rights, and to resolve disputes.
Retention periods vary by category of information. Account and subscription information is retained while your subscription is active and for a defined period afterwards to support any post-termination export, resolve billing and support matters, and meet legal obligations. Communications and support records are retained for a period appropriate to their subject matter. Contact intelligence data is retained for as long as it is accurate and relevant to the purposes of the Service, subject to correction, refresh, and removal in the ordinary course of maintaining the database.
Where personal information is no longer needed, we securely delete or de-identify it.
The Contact Intelligence Database (Information About Prospects)
This section applies to prospects: individuals whose contact information and professional details appear in Capfluence's contact intelligence features.
What Is in the Database
The database contains information intended to help a subscribed user identify and evaluate potential clients. It focuses on Canadian professionals whose business context suggests they may be relevant to a financial advisor's practice. The categories of information collected are described in Section 1.
Where It Comes From
We compile the database from the four categories of sources described in Section 4: government and regulatory sources, professional and business directories, licensed third-party data providers, and Capfluence-derived data.
How Capfluence Uses It
We use the database to provide contact intelligence to subscribed users, allow them to search and filter for potentially relevant prospects, produce matches and rankings using automated processing, and support related features. Capfluence does not send commercial electronic messages or telephone calls to prospects. Any outreach a subscribed user chooses to send to a prospect is the subscribed user's responsibility, sent through the subscribed user's own connected email systems or channels, and subject to the subscribed user's own compliance obligations under CASL, the Unsolicited Telecommunications Rules including the National DNCL, PIPEDA, Quebec Law 25, and any professional conduct rules applicable to the subscribed user.
Your Rights as a Prospect
If you are a prospect and you believe your information may appear in Capfluence's contact intelligence database, you have the rights described in Section 9. In particular, you may request access to the personal information we hold about you, request correction of inaccurate information, and request that we cease using your information for contact intelligence purposes, subject to the limits set by law.
Depending on where you live and how your personal information is processed, you may have some or all of the following rights.
Right of access. You may request access to the personal information we hold about you, including a description of the information, how it is used, and to whom it has been disclosed.
Right of correction. You may request that we correct personal information that you believe to be inaccurate or incomplete.
Right to withdraw consent. Where our processing is based on consent, you may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.
Right to request cessation of processing. Where legally applicable, you may request that we cease using or disclosing your personal information.
Rights concerning automated processing (Quebec residents). Where personal information is used to render a decision based exclusively on automated processing, you have the right to be informed of the personal information used, the reasons and principal factors that led to the decision, and the right to have the personal information used to render the decision corrected. As described in Section 3, Capfluence does not use exclusively automated processing to render decisions producing legal or similarly significant effects on prospects, but you may nonetheless contact us for more information about how automated processing operates in features that may affect you.
Right to data portability (Quebec residents). Where applicable under Law 25, you may request that personal information collected from you be transferred to a person or organization you designate, in a structured, commonly used technological format.
Right to complain. You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca), and if you are a Quebec resident, with the Commission d'accès à l'information du Québec (www.cai.gouv.qc.ca).
How to Exercise Your Rights
To exercise any of these rights, please contact us at privacy@capfluence.app. We will respond to your request within 30 days. Where the request is complex or where responding within 30 days is not reasonably possible, we may extend the response period as permitted by law and will inform you of the extension.
We may need to verify your identity before responding to your request. Where a request is manifestly unfounded, excessive, or repetitive, we may decline it or charge a reasonable fee, in accordance with applicable law.
How We Protect Information
We use reasonable administrative, technical, and physical safeguards to protect personal information from loss, theft, unauthorized access, disclosure, copying, use, and modification. These safeguards include encryption in transit and at rest, access controls, authentication requirements, logging and monitoring, employee training, and vendor due diligence.
No security safeguard is perfect. If we become aware of a breach of security safeguards involving personal information, we will act promptly to contain the incident, assess the risk of significant harm, and, where required, notify affected individuals and the applicable regulator.
The Service is intended for use by professionals aged 18 and over. We do not knowingly collect personal information from children under 18. If you believe we have collected personal information from a child under 18, please contact us at privacy@capfluence.app.
Third-Party Links and Services
The website and platform may contain links to third-party websites and integrate with third-party services. This Privacy Policy does not apply to third parties. We are not responsible for the privacy practices of third parties. When you leave our website or connect a third-party service, we encourage you to review the privacy practices of that third party.
Marketing and Commercial Electronic Messages
Where you provide us with your email address in connection with a demo request, subscription, or other form on the website and consent to receive further communications from us, we may send you commercial electronic messages, including product updates, industry insights, and other content relevant to Canadian financial services professionals. Every commercial electronic message we send includes an unsubscribe link and our contact information as required by CASL.
You may withdraw consent to receive commercial electronic messages at any time by using the unsubscribe link in any such message or by contacting privacy@capfluence.app. Withdrawal takes effect within 10 business days.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will update the Effective Date at the top of this Privacy Policy. Where the update is material, we will provide additional notice, which may include email to subscribed users or a notice on the website.
Continued use of the Service after an update takes effect indicates your acceptance of the updated Privacy Policy.
Questions, requests, or complaints about this Privacy Policy or our privacy practices can be directed to our Privacy Officer.
Capfluence Inc.
Attention: Privacy Officer
2727 Steeles Avenue West, Unit 103-1025
Toronto, Ontario M3J 3G9
Canada
Email: privacy@capfluence.app
