This Privacy Policy explains how 9534-1327 Québec inc., doing business as "Clara Boost" ("Clara Boost", "we", "us", "our"), collects, uses, discloses, and protects personal information when you visit [claraboost.com](https://claraboost.com), use our products or services, interact with our marketing, or communicate with us.
We are based in Quebec, Canada. We aim to comply with applicable privacy laws, including Canada's PIPEDA, Québec's privacy law (Law 25) where applicable, and, depending on where you are located, other laws such as the GDPR and California privacy laws (CCPA/CPRA).
We have designated a Privacy Officer responsible for ensuring compliance with applicable privacy laws; contact details are at the end of this Policy. By using our website or services, you consent to the practices described here. If you do not agree, please do not use our services.
* Transaction information: purchase history, billing details (payment card details are processed by our payment processors; we do not store full card numbers).
* Communications: messages you send us (email, chat, SMS, social media), support requests, feedback.
* Registration and participation data: sign-ups for services, courses, webinars or consultations, survey and form responses.
* User content you choose to share: testimonials, reviews, comments, or submissions (content submitted for publication may become publicly visible).
* Marketing preferences: your opt-ins / opt-outs for email and SMS.
* Location data: general geographic location based on IP address.
* Cookie / pixel data: online identifiers and browsing activity via cookies and similar technologies.
### 2.3 Information from Third Parties
We may receive information from social media platforms (when you interact with us), advertising / analytics partners, payment processors, and public databases.
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## 3. How We Use Your Information
We only use your information when we have a valid reason: to fulfill a contract, comply with legal obligations, pursue legitimate business interests, or with your consent. Specifically, to:
* Provide products and services: deliver purchases, provide access, fulfill orders, offer support, manage accounts.
* Operate registrations and services: courses, consultations, bookings, confirmations, reminders.
* Communicate with you: transactional messages, responses to inquiries, important updates.
We use cookies, pixels, and similar technologies to keep the website working, remember preferences, understand traffic, measure advertising, and (where enabled) show relevant ads. These may be first-party or third-party.
### 4.1 Types of Cookies
* Essential cookies: required for basic functionality; cannot be disabled.
* Analytics cookies: understand how visitors interact with our site.
* Functional cookies: remember preferences and settings.
* Marketing cookies: deliver relevant ads and track campaign performance.
### 4.2 Consent for Cookies
Where required by law, we obtain consent before placing non-essential cookies. Manage preferences via our cookie tool (if displayed) or browser settings.
### 4.3 Third-Party Technologies
We may use third-party analytics and advertising tools that set their own cookies. These third parties have their own privacy policies.
### 4.4 Your Choices
Control cookies through browser settings, device settings, or industry opt-out tools. Blocking cookies may affect functionality.
Do Not Track: our site does not currently respond to "Do Not Track" signals.
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## 5. SMS and Email Communications
### 5.1 Consent
We only send marketing communications (email or SMS) with your express consent. You may opt in through our website forms, during checkout, or by other clear affirmative action. We keep records of your consent. We comply with Canada's Anti-Spam Legislation (CASL): we only send commercial electronic messages with your consent, identify ourselves in every message, and provide a clear unsubscribe mechanism.
### 5.2 SMS Messaging
If you opt in to receive SMS / text messages, we will use your mobile number to send messages related to the program or service you joined (confirmations, reminders, follow-ups, updates, and promotional content where you consented).
* Opt-in required: you will only receive texts if you consented. We may use a confirmation step as additional verification.
* Message frequency: varies based on your interactions and preferences.
* Carrier rates: message and data rates may apply.
* STOP to opt out: reply STOP to any message to unsubscribe.
* HELP for assistance: reply HELP for assistance.
* No purchase required: consent to SMS is not a condition of purchase.
Important: we do not sell, share, or disclose mobile phone numbers, SMS opt-in data, or SMS consent records to third parties or affiliates for their marketing or promotional purposes. We only share this data with service providers strictly necessary to deliver messages (messaging platforms, carriers, aggregators).
### 5.3 Opting Out
Unsubscribe from marketing emails via the "unsubscribe" link in any email. To stop SMS, reply STOP to any message. You may also contact us directly. Even after opting out, we may still send non-marketing messages necessary to deliver what you requested (receipts, access links, service notices).
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## 6. Disclosure of Your Information
We do not sell your personal information. We may share it with:
* Service providers: companies performing services on our behalf (hosting, payment processing, email and SMS delivery, analytics, advertising, CRM and automation tools, customer support). They access only what is necessary and are contractually bound to protect it.
* Business transfers: in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you of any such change.
* Legal requirements: when required by law, court order, or government request, or to protect our rights, safety, or property.
* With your consent: for any other purpose with your explicit agreement.
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## 7. International Data Transfers
We may store or process personal information in Canada, the United States, or other countries where we or our service providers operate. Laws there may differ from yours. Before transferring outside Quebec or Canada, we assess adequacy and use appropriate safeguards (such as contractual protections) where required.
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## 8. Data Retention
We retain your personal information only as long as necessary to fulfill the purposes described, comply with legal obligations, resolve disputes, and enforce our agreements.
* Transaction and accounting records: retained per tax and accounting laws (typically 6–7 years in Canada).
* Account information: retained while active and for a reasonable period after closure.
* Marketing consent records: retained while subscribed, plus a reasonable period thereafter.
* Analytics data: typically retained in anonymized or aggregated form.
When no longer needed, we securely delete or anonymize your information.
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## 9. Data Security
We implement reasonable technical and organizational measures (encryption, access controls, secure storage). No method of transmission or storage is 100% secure. If a breach creates a legal notification duty, we will notify affected individuals and regulators as required.
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## 10. Your Rights
Depending on your location, you may have rights to:
* Access a copy of the information we hold about you.
* Correction of inaccurate or incomplete information.
* Deletion of your data, subject to legal exceptions.
* Portability in a structured, commonly used electronic format.
* Withdraw consent at any time where processing is based on consent.
* Object to certain processing activities.
* Automated decisions: be informed and request human review.
* De-indexation of public information that harms you or is no longer necessary.
* Complaint with a supervisory authority.
To exercise these rights, contact us below. We respond within the timeframes required by law (typically 30 days) and may verify your identity first.
### 10.1 California Residents
Additional rights under CCPA/CPRA: to know what we collect, to opt out of the sale or sharing of personal information, and to non-discrimination. We do not sell your personal information.
### 10.2 European Residents
Rights under the GDPR (EEA, UK, Switzerland). Legal bases: consent, contract performance, legitimate interests, legal obligations. You may complain to your local data protection authority.
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## 11. Children's Privacy
Our services are not directed to children under 16 (or the applicable age of digital consent). We do not knowingly collect their information without parental consent where required, and will delete it promptly if discovered.
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## 12. Third-Party Links
Our website may link to third-party sites. We are not responsible for their privacy practices; review their policies.
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## 13. Changes to This Policy
We may update this Policy. Changes are posted here with an updated date. For significant changes, we may provide additional notice (website or email). Continued use after changes constitutes acceptance.
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## 14. Contact Us
For questions or to exercise your rights, contact our Privacy Officer:
* Company: 9534-1327 Québec inc. (doing business as "Clara Boost")
* Address: 2614 Rue Aubert, Longueuil, QC J4M 2L3, Canada