Privacy Policy

1. Introduction

VIVAVAN CONSULTING INC. (“we”, “our”, or “us”) operates Trailfolio. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our service.

We are committed to compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including British Columbia's Personal Information Protection Act (PIPA) and Quebec Law 25.

We do not sell your personal information.

2. Information We Collect

We may collect information that you provide directly to us, including:

• Account information (name, email address)
• Data you enter for analysis: employment and self-employment income, RRSP / TFSA / FHSA / RESP contribution room and balances, investment holdings (ticker symbols, units held, and prices), realized and unrealized capital gains, property values, mortgage terms, rental income and expenses, CPP/OAS estimates, dependant information used for benefit calculations (Canada Child Benefit, GST/HST credit), and the brokerage institution and masked account reference when you import account statements
• Usage data and analytics

We do not collect Social Insurance Numbers (SIN), bank login credentials, or brokerage account access credentials. Trailfoliodoes not have access to your bank accounts, brokerage accounts, or any external financial accounts. Account statements you import are files you upload yourself; the raw file is parsed and immediately discarded, never stored.

3. How We Use Your Information

We use the information we collect to:

• Provide and maintain our service
• Process your scenario modeling calculations
• Send you service-related communications
• Improve and optimize our platform

4. Consent

By creating an account and using Trailfolio, you provide implied consent for us to collect, use, and process your personal information as necessary to deliver the service described in this policy.

Marketing communications require your express opt-in consent in accordance with Canada's Anti-Spam Legislation (CASL). You may opt out of marketing communications at any time using the unsubscribe link in any marketing email or by contacting us.

Non-essential cookies and identity-linked tracking — the Analytics and Advertising categories described in section 6 — are used only with your express opt-in consent, collected through our cookie-consent banner. Anonymous, cookieless usage measurement that is never linked to you runs without consent, as described in section 6. You can change or withdraw your consent at any time via the “Cookie settings” link in the page footer.

You may withdraw your consent for non-essential data processing at any time by contacting us. Please note that withdrawing consent may limit your ability to use certain features of the service.

5. Data Storage and Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit
• Encryption at rest for database storage
• Industry-standard password hashing (passwords are never stored in plaintext)
• Encrypted database connections

Canadian data residency: Your primary data is stored and processed in Canada. Some ancillary services (such as email delivery or authentication providers) may process limited data outside of Canada, as described in the Third-Party Services section below.

6. Cookies and Tracking

We use cookies and similar browser-storage technologies in three categories. The non-essential categories are off by default and are used only with your express opt-in consent, which you can give, refuse, or withdraw at any time. Separately from cookies, we measure site usage with anonymous analytics that stores nothing on your device and is never linked to you (see “Analytics” below).

Strictly necessary (always active):

• A secure, HTTP-only session cookie for authentication
• Short-lived access tokens held in browser memory only (not stored in cookies or localStorage)
• A browser-storage entry (“vv_consent”) that records your cookie-consent choices, together with the date of your decision and the consent version it applies to, so we can honour them on later visits

Analytics (no cookies; account linking opt-in): We never set analytics cookies. Analytics runs for all visitors in an anonymous, cookieless, memory-only mode that stores nothing on your device and is not linked to your identity (see “Analytics” below). The Analytics option in the consent banner controls whether analytics is linked to your account: unless you opt in, analytics events carry no account identity and we cannot connect them to you. If we ever move analytics from memory-only to persistent storage, we will update this policy first, and persistent analytics will apply only where you have opted in.

Advertising cookies (opt-in): Used to show advertising on our Trailfolio (trailfolio.com) and Passavia (passavia.ca) sites, as described under “Advertising” below. No advertising cookies are set on your device unless you opt in.

Your consent choices: On your first visit, a consent banner lets you accept all cookies, reject all non-essential cookies, or set the Analytics and — on our ad-supported sites — Advertising categories individually. Until you opt in, only strictly necessary storage is used. You can change or withdraw your consent at any time via the “Cookie settings” link in the page footer (or open your cookie settings here); withdrawal takes effect immediately for your subsequent browsing. If we materially change our cookie practices, the banner will ask for your consent again.

Outside the consent-gated advertising described below, we do not use third-party advertising cookies or cross-site tracking cookies. We do not currently respond to Do Not Track (DNT) browser signals, as there is no industry-standard technology for honoring DNT requests.

Analytics: We use a privacy-focused analytics service (PostHog) configured with memory-only storage. No persistent identifiers, cookies, or localStorage entries are placed on your device for analytics purposes. Analytics runs for all visitors in an anonymous mode that cannot identify you: each visit uses a new random identifier, events are not linked to any account, and client IP addresses are not forwarded to PostHog by our first-party proxy and are discarded at ingestion. Analytics data is processed by PostHog in the United States. If you opt in to the Analytics category, analytics is additionally linked to your account as described under “Logged-in users” below.

Anonymous usage data (all visitors): We collect aggregated, anonymous usage data such as page views, feature usage, referring websites, and general geographic region, through the anonymous analytics mode described above and through server-side page-view, click, and card-impression counters. To count unique daily visitors, our servers derive a one-way hash from your IP address and browser signature using a random salt that rotates and is deleted every day: the raw values are never stored, the hash cannot be reversed or linked across days, and it is deleted within 35 days. We cannot identify individual visitors from this data.

Logged-in users (Analytics opt-in): When you sign in and have opted in to the Analytics category, we associate analytics data with your account (email and display name) to improve your experience and our service. We do not record your browsing sessions: session recording is disabled in our analytics configuration. If we ever enable it, we will update this policy first and ask for your consent.

Events we track: In addition to page views, we record which calculators you use, when you save or run scenarios, when you create comparisons, when you click through to a licensed consultant, the regulator’s public register, or a sponsored partner, when you create an account or sign in, when you start a plan upgrade and whether it completes, fails, or is cancelled, and when you interact with AI-powered features. Without an Analytics opt-in these events are anonymous; with it they are linked to your account. We use this data to understand which features are most valuable and to improve the service.

Advertising

Our Trailfolio (trailfolio.com) and Passavia (passavia.ca) sites display advertising served by Google AdSense. Google, as a third-party vendor, uses cookies — including the DoubleClick/DART cookie — to serve ads to our users based on their prior visits to this website and other websites on the Internet.

Personalized advertising runs only if you opt in to advertising cookies. If you decline, or have not yet made a choice, we signal Google through Google Consent Mode to serve non-personalized ads only — these are based on the page you are viewing rather than on your browsing history, and no advertising cookies are stored on your device.

Visitors in the EEA, UK, and Switzerland: Where required by law, Google presents its own certified consent message — built on the IAB Transparency & Consent Framework (TCF) — in place of our banner. You make your advertising-cookie and personalization choices, and can review the advertising partners involved, directly through that message; our own banner does not appear in these regions so you are not asked twice. You can reopen Google's message at any time via the “Cookie settings” link in the page footer.

You may opt out of personalized advertising from Google at any time in Google Ads Settings, and from other participating vendors at www.aboutads.info/choices. For more detail, see how Google uses information from sites that use its services.

7. Third-Party Services

We use the following third-party services to operate Trailfolio:

• Cloud hosting and database infrastructure providers (data stored and processed within Canada)
• Google OAuth - Optional authentication service. If you sign in with Google, your authentication data may be processed in the United States in accordance with Google's privacy policy.
• Stripe — Payment processing for paid subscriptions. Stripe receives your email address, Stripe customer ID, and plan and subscription state; your card details are collected and held by Stripe only and are never stored on our servers. Payment data is processed in the United States in accordance with Stripe's privacy policy.
• Resend — Transactional email service for account messages such as email verification and password resets. Resend processes your email address, display name, and the content of those messages in the United States in accordance with Resend's privacy policy.
• PostHog - Privacy-focused analytics service, running for all visitors in an anonymous, cookieless mode and linked to your account only if you opt in to the Analytics category (see section 6). Collects page views and feature usage events; uses memory-only storage (no persistent identifiers on your device) and session recording is disabled. Analytics data is processed in the United States in accordance with PostHog's privacy policy.
• Google AdSense — Advertising service on our Trailfolio (trailfolio.com) and Passavia (passavia.ca) sites. Subject to your consent choices (see section 6), Google may set and read advertising cookies and process ad-related data (such as IP address, page URL, and ad interactions) in the United States in accordance with Google's privacy policy.
• AI assistant integrations (MCP API) — Trailfolio offers an API that allows third-party AI assistants (such as Claude and ChatGPT) to access our calculator tools on your behalf. When you connect Trailfolio to an AI assistant, the assistant authenticates via OAuth 2.0 and sends calculator inputs (the same categories described in section 2 above) to our servers. These inputs are processed in real time to produce calculation results and are not stored beyond the request lifecycle. No additional personal information is collected through MCP access beyond what is already associated with your Trailfolio account (email and display name).

With the exception of Google's advertising services — which, where you have consented to advertising cookies, process data for ad serving under Google's own privacy policy — these third-party service providers act as data processors on our behalf and are contractually required to protect your information in accordance with this Privacy Policy and applicable privacy laws, and are prohibited from using your data for their own marketing purposes. We do not sell your personal information. Apart from the consent-based advertising described in section 6, we do not share your personal information with third parties for marketing purposes.

8. Chat Assistant Data

When you use the in-app chat assistant, we store your messages (both your questions and the assistant’s responses), the timestamps of each message, and the identifier of the calculator you were viewing when you started the conversation. Any calculator inputs or results you share with the assistant are stored only insofar as they appear in the text of your messages — we do not keep a separate structured snapshot of your inputs after the request completes. This is the minimum we need to resume conversations across sessions and devices and to meet our obligations to you under PIPEDA.

Where it lives. Chat data is stored on the same Canadian infrastructure described in the Data Storage section above. Your conversations never leave Canada for persistence.

Retention. Each chat session is automatically deleted 30 days after its last message, together with every message it contains. There is no historical archive: once a session ages out, it is gone for good.

Third-party model providers. To generate responses, the text of your questions and the relevant calculator context are sent to Google AI Studio (Google's Gemini / Gemma API), where they are processed in the United States. Under Google's current Gemini API Terms of Service, the paid-tier API does not use your inputs or the model's outputs to train Google's models. Google may retain the content briefly for abuse monitoring under its standard API terms. If we later adopt an additional model provider, we will update this section before routing any data there.

Your controls. You can delete any individual conversation from the chat panel at any time, or wipe your entire chat history in one click from Settings › Privacy. Deletion cascades to every message in the removed sessions and is irreversible. If you prefer to make the request through us directly, use the contact address at the bottom of this policy.

What we don't promise. We may access individual conversations when investigating suspected abuse, safety incidents, or a direct request from you, so “we never look at your chats” is not a guarantee we can honestly make. What we do promise is that conversations are not sold and not shared with advertisers.

9. Your Rights

Under PIPEDA and applicable provincial privacy legislation, you have the right to:

• Access, correct, or delete your personal information
• Request a copy of your personal data
• Ask us to restrict processing of your information
• Withdraw consent for non-essential data processing

We will respond to data access requests within 30 days, as required by PIPEDA. Contact us at the email below to exercise these rights.

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at 1-800-282-1376. Quebec residents may also file with the Commission d’accès à l’information du Québec (CAI); British Columbia residents may file with the Office of the Information and Privacy Commissioner for British Columbia.

10. Data Breach Notification

In the event of a data breach that poses a real risk of significant harm to you, we will:

• Notify affected users as soon as feasible
• Report the breach to the Office of the Privacy Commissioner of Canada
• Maintain records of all breaches for at least 5 years, meeting both PIPEDA and Quebec Law 25 (§3.5) requirements

11. Data Retention

We retain your personal information for as long as your account is active. If your account is terminated, you have 30 days to request a data export (see our Terms of Service). After that period, we may retain certain data for:

• Legal compliance and tax purposes (up to 7 years)
• Backup and disaster recovery (up to 90 days)
• Aggregated, anonymized analytics (indefinitely)
• Chat sessions and messages: retained for 30 days from the last message, then automatically deleted

You may request earlier deletion by contacting us at the email below.

12. Children's Privacy

Our service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will provide at least 30 days' notice via email or a prominent notice within the service. We will also post the updated policy on this page and update the “Last updated” date.

14. Contact Us

Privacy Officer. Pursuant to Quebec Law 25 §3.1, the senior officer of VivaVan Consulting Inc. serves as our Privacy Officer and is responsible for our compliance with applicable privacy legislation. Direct privacy questions, access requests, and correction requests to the email below.

If you have questions about this Privacy Policy, please contact us at: [email protected]

If you are not satisfied with our response, you may escalate your privacy complaint to the Office of the Privacy Commissioner of Canada at 1-800-282-1376. Quebec residents may also escalate to the Commission d’accès à l’information du Québec (CAI); British Columbia residents may escalate to the Office of the Information and Privacy Commissioner for British Columbia.