Draft. Pending review by legal counsel — not yet in force. The version that governs your use will be the one published when Hushsong opens to the public.

Privacy Policy — Hushsong (DRAFT)

DRAFT — NOT LEGAL ADVICE. Prepared as a starting point for review by a qualified Ontario lawyer. [BRACKETED] items are placeholders. Do not publish until reviewed.

Effective date: [DATE] Operated by: Legion Trade Corp. (operating as "Hushsong") ("we", "us"), 70 Princess St, Unit 2610, Toronto, Ontario, M5A 0X6, Canada. Contact: [privacy@hushsong.app].

Hushsong helps you create an AI-generated keepsake of a loved one. Because this involves sensitive biometric information (a person's face and voice), we treat your data with particular care, in line with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

1. Information we collect

Photos and voice/video recordings you upload. Faces and voices are biometric, sensitive personal information.
The message text you write.
Your email address (for your receipt and the keepsake delivery link). We do not create accounts or store passwords.
Payment is handled by our third-party payment processor; we do not receive or store your full card details.
Limited technical/usage data (e.g., IP address, device/browser, timestamps) for security, fraud prevention, and to record consent.

2. How we use it, and our legal basis (consent)

We use your information only to: create the keepsake you requested; process your payment; deliver the result; provide support; keep the service safe and lawful; and meet legal obligations. For biometric data we rely on your express, informed consent, given at checkout. We do not use your content for any secondary purpose.

3. What we will never do

We do not sell your personal information.
We do not use your uploads to train shared or general AI models.
We do not display advertising in the product, and the keepsake will never be used to advertise anything.

4. Biometric specifics

Voiceprints and faceprints are processed solely to generate your keepsake. A cloned voice is created for your order and is not reused for anyone else.

5. Sharing with service providers

We share the minimum necessary with vetted processors who act on our behalf and under contract: [voice provider — e.g., ElevenLabs], [animation provider — e.g., D-ID/Hedra], [payment processor — e.g., Stripe / Lemon Squeezy], and [hosting — e.g., Vercel]. We do not otherwise disclose your data except where required by law or to protect safety.

6. Retention and deletion

We delete source uploads (photos/recordings) shortly after your keepsake is generated — target: [e.g., within 30 days].
The finished keepsake and your consent record are retained for [PERIOD] for support, fraud, and legal reasons, then deleted.
You can request deletion of your data at any time at [privacy@hushsong.app].

7. Your rights

You may access, correct, or delete your personal information, and withdraw consent at any time (which ends further processing). Contact [privacy@hushsong.app]; we respond within [30 days].

8. Security

We use encryption in transit and at rest, access controls, and other safeguards appropriate to the sensitivity of biometric data. No system is perfectly secure.

9. Region availability & international transfers

At launch the service is offered in [North America excluding Quebec and Illinois]. We are not currently intended for use in [Quebec, the EU/UK, Illinois]. Data may be processed in [Canada / the United States] by our providers; [transfer-safeguards language — lawyer to confirm].

10. Children

The service is not for anyone under [18], and uploaded subjects must not be minors except as permitted and with proper authority.

11. Changes & contact

We will post changes here and update the effective date. Privacy contact: [privacy@hushsong.app]. [Designate a Privacy Officer per PIPEDA.]

DRAFT only. Not legal advice. To be reviewed and finalized by a qualified Ontario lawyer.