Privacy & Cookie Policy

1. Information we collect

We may collect:

• the details you submit through our forms (name, email address, phone number, messages);
• account and authentication information, if you create a portal account;
• the portfolio configurations you build, including name, description, selected strategies or substrategies, allocations and scale;
• browsing and usage data (pages viewed, referrer, UTM parameters);
• technical data (IP address, browser type, device, user agent).

2. How we use your information

Your information is used to:

• reserve and confirm your Founding Member application;
• operate the platform, maintain accounts and portfolios, and respond to support requests;
• communicate with you by email, SMS or phone;
• improve the website and our services;
• meet our legal obligations.

3. Marketing and communications

With your consent, we may send you communications by email or SMS (product news, content, offers). You can unsubscribe at any time through the link provided, by replying STOP, or by writing to us. We comply with Canada's Anti-Spam Legislation (CASL). We never sell or share your data for third-party marketing purposes.

4. Hosting and service providers

We rely on third-party providers to operate the site and process data, namely:

• Coolify on our own infrastructure (website and platform hosting);
• Supabase (database and authentication);
• GoHighLevel (customer relationship management, and the email, SMS and phone communications we send you);
• Cloudflare (Turnstile bot protection on our forms).

5. Bot protection (Cloudflare Turnstile)

To prevent spam and automated submissions, our forms use Cloudflare Turnstile. For that purpose Cloudflare may process technical data (IP address, browser headers and signals). This data is used solely to distinguish humans from bots and is not used for advertising.

Cloudflare Turnstile Privacy Addendum

6. Sharing your information

We share your information only with the service providers listed above (for the purposes described), with authorities where the law requires it, or in the context of a reorganization or acquisition (with notice). We do not sell your data.

7. Cookies and local storage

We keep tracking to the strict minimum. Essential authentication and password-recovery cookies support sign-in and account recovery, and functional browser storage retains preferences while you use the platform. We use no advertising or analytics pixels (Meta, TikTok, Google Ads) by default. Blocking or clearing essential cookies or storage can affect functionality. You can block or delete these through your browser settings.

8. Data retention

We retain prelaunch and enquiry records for up to 36 months, account and portfolio information for as long as needed to operate your account, and technical logs for up to 12 months. You may request deletion of your data at any time, subject to our legal obligations.

9. Your rights (Law 25 and PIPEDA)

Under Québec's Law 25 and Canada's PIPEDA, you have the right to access your information, correct it, delete it, withdraw your consent and request its portability. To exercise these rights, write to us at support@imperiumsis.com; we will respond within 30 days. You may also file a complaint with the Commission d'accès à l'information du Québec (CAI) or the Office of the Privacy Commissioner of Canada.

10. Security

We protect your information with reasonable measures (HTTPS/TLS encryption, reputable hosting, restricted access). In the event of a confidentiality incident, we will act in accordance with Law 25.

11. Minors

Our services are not directed at people under 18 and we do not knowingly collect their information. If you believe a minor has sent us data, contact us and we will delete it.

12. Changes to this policy

We may update this policy. Material changes will be flagged on the site and, where appropriate, by email. The last-updated date above reflects the version in force.

13. Contact

Privacy officer: Imperium Systematic Solutions Inc., support@imperiumsis.com.

Imperium Systematic Solutions Inc. operates under the English form of its registered name. The company is registered with the Registraire des entreprises du Québec as Solutions Systématique Imperium inc., NEQ 1180990872, at 255 14e Avenue, Saint-Jean-sur-Richelieu, Québec J2X 1B7, Canada.