Privacy Policy

1. Information We Collect

1.1. Information You Provide Directly

We collect information that you voluntarily provide, including:

• Contact Information: Name, email address, phone number, and business name when you submit an application, book a call, or opt into our waitlist.
• Qualification Data: Business description, revenue range, marketing spend, and timeline information submitted through our application flow.
• Communications: Content of emails, SMS messages, chat messages, or any other communications you send to us.
• Payment Information: Billing details processed through our third-party payment processor (Stripe). We do not store full credit card numbers on our servers.

1.2. Information Collected Automatically

When you access our Services, we automatically collect:

• Device and Browser Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and language preferences.
• Usage Data: Pages visited, time spent on pages, click patterns, scroll depth, referring URLs, and navigation paths.
• Cookies and Similar Technologies: We use cookies, pixel tags, and local storage to recognize your browser, remember preferences, and understand how you interact with our Services. See Section 6 for cookie details.
• Analytics Data: We use Vercel Analytics, Meta Pixel (Facebook), and Hyros for performance monitoring, conversion tracking, and attribution.

1.3. Information from Third Parties

We may receive information about you from:

• Advertising Platforms: Meta (Facebook/Instagram) and other ad networks that share conversion and audience data.
• CRM and Marketing Tools: Go High Level, Airtable, and other tools integrated with our Services.
• Publicly Available Sources: Business directories, social media profiles, and other publicly accessible information.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To provide, operate, and maintain our agentic growth system, including lead qualification, content creation, and campaign management.
• Communications: To respond to inquiries, send service updates, deliver marketing materials, and provide customer support.
• Personalization: To tailor our Services, content, and advertisements to your interests and business needs.
• Analytics and Improvement: To analyze usage trends, measure campaign effectiveness, improve our website performance, and develop new features.
• Legal Compliance: To comply with applicable laws, respond to legal requests, and protect our rights and the safety of our users.
• Fraud Prevention: To detect, prevent, and address fraud, abuse, security risks, and technical issues.

3. SMS and Email Communications

3.1. SMS Program

If you opt into our SMS communications, you consent to receive recurring text messages from OnTheScroll related to service updates, appointment reminders, promotional offers, and marketing content. Message frequency varies. Message and data rates may apply.

3.2. Opting Out of SMS

You may opt out of SMS messages at any time by replying "STOP" to any message. After opting out, you will receive a confirmation message and will no longer receive SMS from us. To rejoin, sign up again through our website. For assistance, reply "HELP" or email hello@onthescroll.ai.

3.3. Email Communications

You may unsubscribe from marketing emails by clicking the "unsubscribe" link included in every email, or by contacting us directly. Transactional emails (e.g., booking confirmations, account notifications) will continue even after unsubscribing from marketing communications.

3.4. Carrier Disclaimer

Wireless carriers are not liable for delayed or undelivered messages. Message and data rates may apply. Contact your wireless provider for details about your text and data plan.

4. How We Share Your Information

We do not sell your personal information. We may share your data with the following categories of recipients:

• Service Providers: Trusted third-party companies that help us deliver our Services, including hosting providers (Vercel), CRM platforms (Go High Level, Airtable), payment processors (Stripe), email delivery services, and analytics tools.
• Advertising Partners: Platforms such as Meta (Facebook/Instagram) for ad targeting, retargeting, and conversion measurement. This may include sharing hashed email addresses, phone numbers, or cookie identifiers.
• Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity.
• Legal Requirements: When required by law, court order, or governmental authority, or when we believe disclosure is necessary to protect our rights, safety, or the rights of others.
• With Your Consent: When you explicitly authorize us to share your information with a specific third party.

We do not share SMS opt-in data or consent with any third parties for their own independent marketing purposes.

5. Data Retention

We retain your personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account and Lead Data: Retained for the duration of your engagement with us plus 3 years, unless you request deletion sooner.
• Marketing Data: Retained until you unsubscribe or request deletion.
• Financial Records: Retained for 7 years as required by tax and accounting regulations.
• Usage and Analytics Data: Retained in aggregated or anonymized form for up to 3 years.

6. Cookies and Tracking Technologies

We use the following types of cookies and tracking technologies:

• Essential Cookies: Required for basic website functionality (session management, security tokens). Cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website (Vercel Analytics, page view tracking).
• Advertising Cookies: Used by Meta Pixel and Hyros to track conversions, build audiences, and serve relevant ads across platforms.
• Preference Cookies: Remember your choices (e.g., form pre-fills) to improve your experience.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality. Most browsers allow you to refuse cookies, delete existing cookies, or alert you when a cookie is being set.

7. Data Security

We implement industry-standard administrative, technical, and physical security measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls limiting data access to authorized personnel
• Regular security assessments and monitoring
• Secure hosting infrastructure through Vercel and Supabase

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal retention requirements.
• Portability: Request your data in a structured, commonly used, machine-readable format.
• Objection: Object to the processing of your data for direct marketing purposes.
• Restriction: Request that we limit how we process your data in certain circumstances.
• Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at hello@onthescroll.aiwith the subject line "Privacy Rights Request." We will respond within 30 days.

9. Data Deletion

You have the right to request deletion of your personal data at any time. To submit a data deletion request, email hello@onthescroll.aiwith the subject line "Data Deletion Request." We will verify your identity, process the request, and permanently delete your data within 30 days. You will receive confirmation via email when deletion is complete.

Please note that we may retain certain information as required by law (e.g., financial records for tax purposes) or for legitimate business interests (e.g., fraud prevention). Aggregated or anonymized data that cannot identify you may also be retained.

10. International Data Transfers

Our Services are primarily operated from Canada. If you access our Services from outside Canada, your information may be transferred to, stored, and processed in Canada or other jurisdictions where our service providers operate. By using our Services, you consent to such transfers. We take steps to ensure that your data receives an adequate level of protection in the jurisdictions in which we process it.

11. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal data, please contact us at hello@onthescroll.ai.

12. Third-Party Links and Services

Our website may contain links to third-party websites, services, or applications that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policy of every site you visit.

13. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• The right to know what personal information we collect, use, disclose, and sell.
• The right to request deletion of your personal information.
• The right to opt out of the sale of your personal information. We do not sell personal information as defined by the CCPA.
• The right to non-discrimination for exercising your privacy rights.

To exercise these rights, contact us at hello@onthescroll.ai.

14. Quebec and Canadian Privacy Law

As a company operating from Quebec, Canada, we comply with applicable Canadian federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25). This includes your right to access, correct, and request deletion of your personal information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by law, provide notice through our website or via email. Your continued use of our Services after any changes constitutes acceptance of the updated policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

OnTheScroll
Client Acquisition Operating Systems Inc.
Email: hello@onthescroll.ai
Address: 6740 Rue Briand, Montréal QC, H4E 3L5, Canada