Draft — not legal advice, not yet reviewed by counsel. This page is placeholder content structured around PIPEDA and CASL requirements so a lawyer has a starting point to edit, not finished policy. Do not treat this as your live, binding Privacy Policy until it has been reviewed by an Ontario/Canadian privacy lawyer.

Privacy Policy

Last updated: [date] · Draft

Who we are

[Legal business name], operating as Kairos (“we,” “us”), provides an AI-powered missed-call and lead-capture service for home-service businesses in Ontario. This policy explains how we collect, use, and protect personal information under the Personal Information Protection and Electronic Documents Act (PIPEDA).

Contact: [privacy contact email] · [mailing address]

What we collect, and why

  • From callers/texters (people who contact one of our business customers): phone number, name (if given), the content of calls and text conversations, and voice call recordings/transcripts — collected to capture the details of their service request and pass them to the business they contacted.
  • From website visitors who submit the inquiry form: name, phone number, trade, and any message provided — collected to respond to their inquiry about our service.
  • From our business customers (contractors): business and contact details, account and billing information — collected to provide and bill for the service.

We do not collect more than is needed for these purposes.

AI voice calls and recording

When our AI voice assistant answers a call on behalf of a business customer, it identifies itself as an AI assistant at the start of the call and discloses that the call may be recorded and transcribed to capture the caller's details. Continuing the call after that disclosure is treated as consent to that recording, for that purpose. Recordings and transcripts are used only to capture and relay the caller's request to the business they called — not for unrelated training or marketing without separate consent.

Text messages (SMS)

Our AI text-back messages identify the business (and that they are from an AI assistant) at the start of the conversation. A missed call is treated as an implied request for a follow-up text about that inquiry. Reply STOP to any message to opt out of further texts; reply START to opt back in.

Who we share information with

We use the following service providers to operate Kairos. Each processes personal information only as needed to provide their part of the service, under contractual terms:

  • Twilio — phone numbers, call routing, SMS delivery
  • ElevenLabs — AI voice conversation processing
  • Anthropic — AI text conversation processing (Claude)
  • Supabase — database and account authentication
  • Resend — transactional email delivery
  • Stripe — payment processing (business customers only)

Some of these providers may process or store data outside Canada. [Describe safeguards / contractual protections here.]

Retention

[Retention periods to be defined — e.g. how long call transcripts, SMS conversations, and lead records are kept, and the deletion schedule.]

Your rights

You may request access to, correction of, or deletion of your personal information by contacting [privacy contact email]. We will respond within the timelines required by PIPEDA.

Security

We use encryption in transit and at rest, access controls, and other safeguards appropriate to the sensitivity of the information. [Expand with specifics / link to security practices.]

Questions or complaints

Contact us at [privacy contact email]. You may also contact the Office of the Privacy Commissioner of Canada.

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