Privacy Policy.
Last updated: June 2026
Version 1.1 — June 2026
17760809 Canada Inc. Operating as GoldenEye Canada
[BUSINESS ADDRESS — TO BE INSERTED]
legal@getgoldeneye.com | getgoldeneye.com
Your Privacy Matters
GoldenEye Canada is committed to protecting your personal information. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and how you can exercise your privacy rights. We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario privacy legislation.
1. Who We Are
17760809 Canada Inc. Operating as GoldenEye Canada is the controller of the personal information collected through the GoldenEye platform. We are accountable for all personal information under our control.
Our Privacy Officer can be reached at:
Privacy Officer — GoldenEye Canada
[BUSINESS ADDRESS — TO BE INSERTED]
legal@getgoldeneye.com
2. Scope
This Privacy Policy applies to all personal information collected by GoldenEye Canada through:
- the GoldenEye Resident mobile application;
- the GoldenEye web billing portal at getgoldeneye.com;
- the GoldenEye marketing website and lead capture / neighbourhood enquiry forms, including enquiries from prospective residents who have not yet subscribed;
- email and other communications with GoldenEye Canada;
- the resident sign-up and verification process; and
- the SOS Feature and patrol monitoring functions.
This Policy does not apply to the personal information practices of Security Companies, patrol drivers, or other third parties, who maintain their own privacy practices.
3. Personal Information We Collect
We collect only the personal information that is necessary for the purposes identified in this Policy. The categories of information we collect are set out in the table below.
| Category | Data Collected | Purpose |
|---|---|---|
| Prospect / Lead Information | Full name, email address, residential address or neighbourhood, cluster of interest, and CASL consent record (timestamp, method, and source of consent) | To respond to your neighbourhood enquiry, determine whether service is available or planned in your area, and — with your express consent — notify you about cluster availability and send marketing communications |
| Identity & Account | Full name, email address, password (hashed), date of birth, government-issued ID document | Account creation, identity verification, age confirmation |
| Address & Property | Residential address, property type, unit number | Cluster assignment, service eligibility, billing |
| Payment Information | Payment card details, billing address, transaction history (processed by Stripe — we do not store raw card data) | Subscription billing, payment processing, financial records |
| Location Data | GPS coordinates (when SOS is activated or when using patrol monitoring features) | SOS alert delivery, display of patrol position on resident dashboard |
| Device & Usage | Device type, operating system, app version, IP address, usage logs, push notification tokens | Platform security, debugging, service delivery, push notifications |
| Communications | Support tickets, emails, in-app messages, feedback submitted to GoldenEye Canada | Customer support, service improvement, legal compliance |
| Verification Documents | Government-issued photo ID, proof of address | Resident identity verification required for platform access |
4. How We Collect Personal Information
We collect personal information:
- directly from you, when you create an account, subscribe to the Service, complete verification, submit a neighbourhood enquiry or lead capture form, or contact us;
- from our Community Growth Partners, who may collect your name, contact information, and express consent in person during neighbourhood canvassing, using GoldenEye-approved consent forms;
- automatically, through your use of the Platform, including location data when you activate the SOS Feature;
- from our payment processor (Stripe), which provides us with transaction confirmation and billing status; and
- from our identity verification process, during which you submit documents directly to us through the Platform.
We do not purchase personal information from data brokers or third-party marketing lists.
5. Purposes for Which We Use Personal Information
GoldenEye Canada collects, uses, and discloses personal information only for the following purposes:
5.1 Service Delivery
- to create and manage your resident account;
- to verify your identity and residential address;
- to assign you to the correct neighbourhood Cluster;
- to process your subscription and billing;
- to display the live patrol position of the on-duty driver in your Cluster;
- to deliver push notifications including patrol activity updates and SOS-related alerts; and
- to enable and process SOS Feature activations.
5.2 Safety & Security
- to transmit your location to the on-duty patrol driver when you activate the SOS Feature;
- to maintain logs of SOS activations for safety and accountability purposes; and
- to investigate misuse of the SOS Feature or other breaches of our Terms of Service.
5.3 Communications
- to send transactional emails including subscription confirmations, billing receipts, and service notifications;
- to send cluster activation notifications and service updates; and
- to respond to your support requests and enquiries.
5.4 Legal & Compliance
- to comply with applicable laws and regulatory requirements;
- to establish, exercise, or defend legal claims; and
- to fulfil our obligations under PIPEDA, the Consumer Protection Act 2002 (Ontario), and other applicable legislation.
5.5 Marketing (With Consent)
- to send promotional communications about GoldenEye Canada's services, where you have provided express consent under CASL;
- to contact prospective residents who have submitted a neighbourhood enquiry or otherwise provided express consent (online or through a Community Growth Partner) about service availability in their area, where such consent has been obtained under CASL and may be withdrawn at any time via the unsubscribe mechanism included in every commercial message; and
- to conduct surveys or gather feedback about the Service, where you have consented to participate.
We will not use your personal information for any purpose other than those listed above without your prior consent, or as required by law.
6. Legal Basis for Processing
GoldenEye Canada processes your personal information on the following legal bases under PIPEDA:
- Consent — you provide express or implied consent at the time of enquiry, account creation, subscription, or as otherwise described in this Policy;
- Contractual necessity — processing is required to deliver the Service under our Terms of Service;
- Legal obligation — processing is required to comply with applicable laws; and
- Legitimate interest — processing is necessary for our legitimate business interests, including platform security and fraud prevention, where those interests are not overridden by your privacy rights.
7. Location Data — Special Notice
GoldenEye Canada collects your GPS location only when you activate the SOS Feature. We do not continuously track your location in the background. Your location is transmitted to the on-duty patrol driver in your Cluster for the sole purpose of responding to your SOS alert. Location data collected through SOS activations is retained for 90 days for safety and accountability purposes and then deleted.
8. Disclosure of Personal Information
GoldenEye Canada does not sell your personal information. We may disclose your personal information to the following categories of recipients:
8.1 Security Companies & Patrol Drivers
We share your name, residential address, and GPS location (on SOS activation) with the licensed Security Company assigned to your Cluster and with the on-duty patrol driver, solely for the purpose of delivering the Service and responding to SOS alerts.
8.2 Service Providers
We engage the following categories of third-party service providers who process personal information on our behalf under contractual data processing agreements:
- Payment processing — Stripe (payment card data and transaction processing);
- Cloud hosting & database — Supabase (platform infrastructure and database hosting, with data hosted in the Canada Central region);
- Push notifications — Firebase Cloud Messaging / Apple Push Notification Service (notification delivery);
- Email delivery — Resend (transactional and consented marketing email delivery);
- Mapping services — Mapbox (patrol position display and routing).
8.3 Legal & Regulatory
We may disclose personal information where required by law, court order, or lawful demand from a government authority, or where we believe disclosure is necessary to protect the rights, property, or safety of GoldenEye Canada, our residents, or the public.
8.4 Business Transfers
In the event of a merger, acquisition, sale of assets, or corporate restructuring, your personal information may be transferred to the successor entity, subject to equivalent privacy protections.
9. Retention of Personal Information
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:
| Information Type | Retention Period | Basis |
|---|---|---|
| Prospect / lead data (non-converting) | 24 months from last contact, or until consent is withdrawn (whichever is earlier) | CASL consent records and legitimate business follow-up |
| Account & subscription data | Duration of subscription + 7 years | Tax and financial record obligations |
| Identity verification documents | Duration of subscription + 1 year | Anti-fraud and security purposes |
| SOS activation location data | 90 days from activation | Safety and accountability |
| Payment transaction records | 7 years from transaction | CRA and financial legislation |
| Support communications | 3 years from last interaction | Legal claims and dispute resolution |
| Marketing consent records | Duration of consent + 3 years | CASL compliance |
10. Cross-Border Data Transfers
GoldenEye Canada's platform is hosted on Supabase infrastructure, with resident data stored in the Canada Central region. Our platform development partner, Robust Devs Ltd, is located in the United Kingdom and engages engineering personnel in Pakistan. Personal information may be accessed by or transferred to service providers in these jurisdictions in the course of delivering the Service.
Where personal information is transferred outside of Canada, GoldenEye Canada takes reasonable steps to ensure it receives equivalent protection, including through contractual data processing agreements that impose obligations consistent with PIPEDA. By using the Service, you consent to these transfers.
11. Security
GoldenEye Canada implements and maintains appropriate technical and organisational security measures to protect your personal information against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:
- encryption of personal information in transit (TLS) and at rest;
- role-based access controls limiting internal access to personal information;
- hashed storage of account passwords using industry-standard algorithms;
- regular security assessments of the Platform; and
- contractual security obligations imposed on all service providers who handle personal information.
No method of electronic transmission or storage is completely secure. While we take commercially reasonable steps to protect your information, we cannot guarantee absolute security.
12. Your Privacy Rights
Subject to applicable law, you have the following rights in respect of your personal information:
- Access — you may request a copy of the personal information we hold about you;
- Correction — you may request correction of inaccurate or incomplete personal information;
- Withdrawal of consent — you may withdraw consent to processing at any time, subject to legal and contractual restrictions (withdrawal of consent to the processing required to deliver the Service will result in termination of your subscription; withdrawal of marketing consent may be exercised at any time via the unsubscribe link in any commercial message);
- Complaint — you have the right to make a complaint to the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca if you believe we have not complied with our obligations under PIPEDA.
To exercise any of the above rights, please contact our Privacy Officer at legal@getgoldeneye.com. We will respond to your request within 30 days. We may require you to verify your identity before processing your request.
13. Cookies & Tracking
The GoldenEye web billing portal and marketing website use cookies and similar tracking technologies to:
- maintain your session and authentication status;
- remember your preferences;
- analyse platform usage and performance; and
- prevent fraud and ensure security.
You may control cookie settings through your browser. Disabling certain cookies may affect the functionality of the web portal. A full Cookie Policy is available at getgoldeneye.com/cookies.
14. Children
The Service is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor without appropriate consent, we will delete it promptly. If you believe a minor has provided us with personal information, please contact us at legal@getgoldeneye.com.
15. Changes to This Policy
GoldenEye Canada may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by email or through the Platform at least 30 days before the changes take effect. The date of the most recent revision is shown at the top of this document. Your continued use of the Service after the effective date of an updated Policy constitutes your acceptance of the changes.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:
Privacy Officer
17760809 Canada Inc. Operating as GoldenEye Canada
[BUSINESS ADDRESS — TO BE INSERTED]
legal@getgoldeneye.com
getgoldeneye.com/privacy