Privacy Policy

Last updated: [confirm date of counsel-reviewed version]

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

What cruisr Does With Your Data

cruisr runs bookkeeping and month-end close on top of the accounting system You already use. To do that, We read from Your ledger and Your bank and card feeds, prepare and post accounting entries, and deliver a close package back to You.

Three things follow from that, and they are the shape of everything below:

Our connections are read-only, and We hold no payment permissions. We can see transactions, statements and documents. We cannot move money into or out of Your accounts. There is no payment rail wired into cruisr.
Your accounting system stays Yours. Your QuickBooks or Xero remains in Your name, under Your administration, throughout. You may revoke Our access from Your own admin panel at any time.
We do not sell Your data, and We do not use Your financial data to train models on behalf of anyone other than Your own account.

The technical and organizational specifics behind these statements — encryption, hosting, data residency, backup and access controls — are published on Our Trust & Security page rather than restated here, so that the two documents cannot drift apart.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to cruisr.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Company operates from the Province of Quebec, Canada. Our legal entity name is [confirm registered legal entity name].
Governing jurisdiction refers to: the Province of Quebec, Canada.
Connected Financial System means an accounting system, bank, card issuer, payroll provider or similar service that You authorize cruisr to connect to on Your behalf.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to cruisr, accessible from cruisr.ai
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Usage Data

Data From Connected Financial Systems

When You authorize cruisr to connect to a Connected Financial System, We receive the records that system holds and that Our access permits. Depending on the system, this may include transaction and statement lines, chart-of-accounts and tracking-category structures, invoices, bills and supporting documents, vendor and customer records, and payroll totals posted to the ledger.

Some of these records contain personal information about people other than You — Your employees, Your customers and Your suppliers. Where they do, You are the party who determines why that information is collected, and cruisr processes it on Your behalf and on Your instructions.

Our connections to these systems are read-only. We do not hold, and do not request, permission to initiate a payment or transfer.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#mainWhere_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about the cookies we use in our Cookie Policy.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

International Transfers of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other place where a party involved in the processing is located. Where that is outside Quebec, We are required to assess before the transfer whether the information would receive adequate protection, having regard to the sensitivity of the information, the purposes for which it is to be used, the protections it would be given, and the legal framework of the receiving jurisdiction.

Our current hosting region and the locations of Our subprocessors are published on Our Trust & Security page.

[Needs counsel: the Law 25 privacy impact assessment for out-of-Quebec transfers, and the contractual terms relied on for each subprocessor. Do not state a residency or adequacy conclusion here until that assessment exists.]

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless adequate protections are in place.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The specifics of how We protect Your data — encryption in transit and at rest, hosting and data residency, backup and restore practice, and the access controls governing who at cruisr can see what — are published and kept current on Our Trust & Security page. They are stated there rather than restated here so that the two documents cannot drift out of sync, and so that a change to a control is published in one place.

The controls that govern access to Your books inside cruisr are part of the product, not only of Our internal practice: rights are assigned per financial area, the same person cannot both prepare and approve the same item, approvals above a dollar threshold You set require a named person, closed periods lock, and every entry carries its source document and full change history.

No method of transmission over the Internet or of electronic storage is completely secure. While We use the measures described on Our Trust & Security page to protect Your Personal Data, We cannot guarantee its absolute security.

Subprocessors

We use a small number of third-party providers to deliver the Service — hosting, bank-feed connectivity, and the AI model provider whose models prepare accounting work. Each is bound to confidentiality and security obligations, and each is named on Our Trust & Security page.

[Confirm with counsel: whether this policy should list subprocessors and their processing locations inline, or whether the Trust & Security reference is sufficient; and confirm the notification mechanism for adding a subprocessor.]

Your Rights Under Law 25 and Canadian Privacy Law

cruisr handles financial and personal data in line with Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, and with applicable Canadian federal privacy legislation.

Subject to the limits those laws set, You have the right to:

Access the personal information We hold about You, and be told how it is being used;
Correct personal information that is inaccurate, incomplete or ambiguous;
Withdraw consent to a use of Your personal information, or ask that its use cease, where no legal or contractual obligation requires Us to continue;
Deletion or de-indexing of personal information, in the circumstances the legislation provides for;
Portability — to receive the computerized personal information You provided Us in a structured, commonly used technological format;
An explanation where a decision about You is based exclusively on automated processing of Your personal information, and to have the reasons and the principal factors behind it explained;
Complain to the Commission d'accès à l'information du Québec (the CAI) if You believe Your rights have not been respected.

To exercise any of these rights, contact Our Privacy Officer using the details in the Contact Us section below. We will respond within the time limit the applicable legislation sets.

Privacy Officer

Our Privacy Officer is responsible for the protection of personal information at cruisr and is Your first point of contact for any question, request or complaint about it.

Privacy Officer: [confirm name and title] Email: privacy@cruisr.ai

Breach Notification

If a confidentiality incident involving personal information presents a risk of serious injury, We will notify the affected individuals and the Commission d'accès à l'information du Québec promptly, and We will keep a register of confidentiality incidents as the legislation requires.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: hello@cruisr.ai
Privacy officer: privacy@cruisr.ai