Last updated: [DRAFT — insert date of legal review]
This is a working draft prepared to reflect what Zeerus actually collects, stores, and shares today. It has not been reviewed by a lawyer and should not be relied on for real customers until it is. Bracketed items need a decision from you (or your lawyer) before this goes live.
This policy explains how Zeerus collects, uses, and protects personal information. It covers two different groups of people:
From agency users, directly:
On behalf of agency users, about their clients:
Collected automatically:
We do not sell personal information, and we do not use your clients' personal information for any purpose other than providing the Service to your agency.
We handle personal information in line with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA): we only collect what's reasonably needed to provide the Service, we don't use it for unrelated purposes, and we give you tools to access, correct, and delete data. For automated emails to your clients, the Service requires your agency to record that a client has consented before those emails are sent, in line with CASL.
Zeerus's database is hosted on Supabase infrastructure in the ca-central-1 (Canada) region. [Confirm: does anything — file storage, backups, logging — live outside Canada? Say so here if so; data residency claims need to be accurate for every subprocessor, not just the primary database.]
We share information with a small number of service providers who help us run Zeerus, each bound by their own privacy and security commitments:
Some of these providers operate infrastructure outside Canada as part of their global service (for example, Stripe's payment processing, and Sentry's EU hosting). [Confirm each subprocessor's data location and add specifics here — this matters for customers with strict data residency requirements.]We don't share personal information with anyone else, except where required by law or to protect the rights, safety, or property of Zeerus, our users, or the public.
Every agency's data is isolated using row-level security in our database, so one agency cannot access another's records. Passwords are hashed, not stored in plain text. Data in transit is encrypted (HTTPS/TLS). [Add any further specifics — encryption at rest, access-control practices, incident response process — once finalized.]No system is perfectly secure, and we can't guarantee absolute security, but we take reasonable technical and organizational measures to protect the information you trust us with.
We retain agency and client data for as long as the agency's account is active. If an agency closes its account, we retain data for [e.g. 30 days] to allow export, then delete it. The audit log is retained for as long as the underlying account exists, as it exists specifically to provide an unmodifiable record of account activity.
Under PIPEDA, you (or, where your agency is the controller, your clients through your agency) have the right to access the personal information we hold, request corrections, and request deletion, subject to our legitimate need to retain certain records (for example, billing history or the audit log). To make a request, contact [privacy contact email].
Zeerus uses a single essential session cookie to keep you signed in. We don't use advertising or third-party tracking cookies. [Update this if analytics tooling is added later.]
Zeerus is a business tool for licensed insurance professionals and is not directed at, or intended for use by, children.
If we make material changes to this policy, we'll notify agency owners (for example, by email or an in-app notice) before the changes take effect.
Questions or requests about this policy can be sent to [privacy contact email].