Privacy Policy
Last updated: 28 October 2026
1. Who We Are and What This Policy Covers
This Privacy Policy explains how Coeurage Labs Inc., operating as Coeurage Labs (“Coeurage Labs,” “we,” “us” or “our”), collects, uses, discloses and protects personal information. [Legal Name of Corporation] is a corporation incorporated under the Canada Business Corporations Act, with its registered office in Whitby, Ontario.
This policy applies to personal information we handle when:
you visit coeuragelabs.com (the “Website”);
you subscribe to our newsletter, book a call, complete a form or contact us;
you or your organization engage us for fractional executive, advisory or project services (“Client Services”);
you participate in a workshop, program, cohort, mastermind or talk we deliver, including on behalf of a partner organization (“Programs”).
Where a separate written agreement with a client contains confidentiality or data protection terms, that agreement also applies. If the agreement and this policy conflict, the agreement governs.
Accountability. We have designated a Privacy Officer who is responsible for our compliance with this policy and applicable privacy law. You can reach our Privacy Officer at privacy@coeuragelabs.com (see Section 12).
2. Information We Collect
We collect only the personal information we need for the purposes described in Section 3.
Website visitors: IP address, browser and device type, pages viewed, referring site and approximate location, collected automatically through cookies and our website platform.
Newsletter subscribers: name and email address, and whether you opened or clicked our emails, collected through our signup form.
Prospective clients: name, email, phone, company, role, and what you tell us about your business when you book a call or complete an intake or application form.
Clients: contact details for you and your team, billing details, and business information you share during the engagement, such as financial results, pipeline, strategy, team and operational information.
Program participants: name, email, organization, and anything you share in sessions, workbooks or surveys, collected from you or from the partner organization delivering the Program.
Anyone who contacts us: your name, contact details and message.
Business information about third parties. During Client Services, clients may share information about their employees, customers, partners or investors. We use it only to deliver the Client Services and treat it as described in Section 4. Clients are responsible for having the right to share it with us.
Payment information. Payments are processed by Waveapps. We do not store full credit card numbers.
3. How We Use Information and Your Consent
We use personal information to:
respond to inquiries and schedule calls;
assess whether we are a good fit for your needs;
deliver, manage and invoice Client Services and Programs;
send our newsletter and other communications you have agreed to receive;
report aggregated, non-identifying outcomes to partner organizations that fund or host Programs;
operate, secure and improve the Website; and
meet legal, tax and accounting obligations.
We do not sell personal information, and we do not use it for purposes unrelated to those above without your consent.
Consent. We obtain your consent when we collect personal information, except where the law allows otherwise. The form of consent depends on how sensitive the information is:
Express consent for our newsletter and other marketing emails, and before sharing identifiable information about you with a third party for a new purpose.
Implied consent where it is reasonable, for example using your contact details to reply to an email you sent us or to deliver services you engaged us for.
Withdrawing consent. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer or using the unsubscribe link in any email. If you withdraw consent, we may be unable to provide some services, and we will explain the consequences.
4. Client Information and Confidentiality
In fractional and advisory work, we see sensitive business information, including revenue, pricing, fundraising plans, strategy and team matters. We treat all of it as confidential, whether or not it is personal information.
For Client Services, we:
use client information only to deliver the services you engaged us for;
limit access to the people delivering your engagement, and require any subcontractor we involve, with your agreement, to keep it confidential;
do not share client information with other clients, Program partners or anyone else without your permission, unless required by law;
do not name you as a client, or describe your engagement in a way that identifies you, in case studies, on our Website or in marketing without your written permission;
securely delete client files 6 months after the engagement ends, except what we must keep for legal, tax or professional reasons (Section 7). Copies of deliverables you received during the engagement remain yours. If you need anything else from your files, ask us before that date.
Programs delivered with partner organizations. When we deliver a Program for a university, municipality, accelerator or other organization, that organization may share participant details with us, and we may report attendance and aggregated, non-identifying outcomes back to it. We do not share what an individual participant says in a session or one-on-one meeting without that participant’s consent. The partner organization’s own privacy policy governs the information it collects.
Confidentiality terms in your client agreement apply in addition to this section.
5. Service Providers, AI Tools and Storage Outside Canada
We use trusted third-party service providers to run our business. They process personal information on our behalf, only for the purposes we set, and under contractual terms that require them to protect it. We remain responsible for personal information we transfer to them.
Our service providers include:
Website hosting, forms and analytics: Hostinger
Newsletter: Mailerlite
Call booking and scheduling: Cal.com
Email, calendar and invoicing for institutions: Zoho
Video meetings: Zoom
Client notes, documents and project management: Notion and/or Google Workspace
Forms and intake questionnaires: Hostinger forms and/or Jotform
Payments: Waveapps
AI-assisted drafting and analysis: Anthropic (Claude) and any others
AI-assisted tools. We use AI tools to help draft documents, summarize meeting notes and analyze information for Client Services. We use business or professional versions of these tools that do not use your information to train their models. A person reviews all AI-assisted work before it is shared with you. We do not use AI tools to make decisions about you that have legal or similarly significant effects.
Storage and processing outside Canada. Some of our service providers store or process information outside Canada, including in the United States and the European Union. While it is outside Canada, it is subject to the laws of that country and may be accessible to its courts, law enforcement and national security authorities.
Other disclosures. We may disclose personal information where required or permitted by law, for example in response to a court order, to protect our legal rights, or as part of a sale or reorganization of our business, where the recipient agrees to protect it under this policy.
6. Cookies, Analytics and Email
Cookies. The Website uses cookies and similar technologies to keep it working, remember your preferences and understand how visitors use it. Where non-essential cookies are used, our cookie banner lets you accept or decline them. You can also block or delete cookies in your browser, though some features may not work.
Analytics. We use [analytics tool] to see aggregated information, such as how many people visit and which pages they view. We use this to improve the Website, not to identify individual visitors.
Email. We send commercial emails, including our newsletter, only with your consent or as otherwise permitted by Canada’s Anti-Spam Legislation (CASL). Every email identifies us and includes a working unsubscribe link. We process unsubscribe requests within 10 business days.
Links to other sites. The Website links to third-party sites and social media, such as LinkedIn and Instagram. Their own privacy policies apply when you use them.
7. Retention, Safeguards and Breaches
Retention. We keep personal information only as long as needed for the purposes it was collected for, or as required by law:
Newsletter subscriptions: until you unsubscribe.
Inquiries and booking details that do not lead to an engagement: 2 years from last contact.
Client engagement working files: securely deleted 6 months after the engagement ends, unless the client agreement says otherwise. Copies in our systems’ routine backups are overwritten on the normal backup cycle.
Contracts, invoices and financial records: 6 years after the end of the tax year they relate to, as required by the Canada Revenue Agency.
We then securely delete the information or make it anonymous.
Safeguards. We protect personal information with measures suited to its sensitivity, including:
multi-factor authentication on our business accounts;
encrypted devices and secure, access-controlled storage;
giving access only to people who need it to do their work;
confidentiality commitments from anyone working with us.
No system is completely secure, but we work to protect your information from loss, theft and unauthorized access, use or disclosure.
Breaches. If a breach of security safeguards involving personal information creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as soon as feasible, as required by law. We keep a record of every breach for at least 24 months.
8. Your Rights
You may ask to:
see the personal information we hold about you and how it has been used and disclosed;
correct information that is inaccurate or incomplete;
withdraw your consent (Section 3).
Send requests to our Privacy Officer. We may ask you to verify your identity. We will respond within 30 days, or tell you within that time if we need an extension, as the law allows. Access is free, unless we tell you about a minimal cost in advance. If we refuse a request, we will explain why, as permitted by law.
9. Children
Our services are intended for adults. We do not knowingly collect personal information from anyone under the age of majority in their province or territory.
10. Residents of Quebec
If you live in Quebec, the Act respecting the protection of personal information in the private sector may give you additional rights. To exercise them, contact our Privacy Officer, who is also our person in charge of the protection of personal information.
11. Changes to This Policy
We may update this policy to reflect changes in our services or the law. We will post the updated version on this page with a new “Last updated” date. If we make a significant change to how we use personal information, we will notify affected clients and subscribers by email before it takes effect.
12. Contact Us and Complaints
Privacy Officer
Coeurage Labs Inc., operating as Coeurage Labs
Attention: Nicole Troster, Privacy Officer
Email: privacy@coeuragelabs.com
