1. Introduction
Solutions LucentFlow Inc. ("LucentFlow", "we", "us", or "our") is a Québec-based technology company offering AI-driven business process automation services. We are committed to protecting the confidentiality and integrity of the information we process for our clients.
This policy describes how we collect, use, store, disclose, and safeguard client information in compliance with:
- Québec’s Act respecting the protection of personal information in the private sector (Law 25)
- Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
- Other applicable provincial and federal privacy laws
2. Scope of Policy
Applies to:
- Business clients using LucentFlow services
- Employees, contractors, and representatives authorized to use the platform
Excludes:
- Personal data processed for internal HR purposes (covered under a separate internal policy)
- Public business data or anonymized/aggregated datasets
3. Information We Collect
3.1 Client Account Information
- Company name and contact details
- Billing, payment, and subscription data
- Technical settings and service preferences
3.2 Data Processed Through Our Services
- Internal business documents
- Workflow and process data
- Operational and performance records
- Employee work-related information (non-medical)
3.3 Technical Information
- IP addresses, browser/device identifiers
- Access logs and system usage patterns
- Security events and diagnostic data
4. How We Use Information
We use client data to:
- Deliver, maintain, and improve our automation services
- Monitor service performance and usage
- Provide support and respond to inquiries
- Ensure platform security and compliance
- Meet legal or contractual obligations
We do not sell, rent, or share client information for marketing or unrelated business purposes.
5. Legal Grounds for Processing
We rely on the following legal bases:
- Contract performance (e.g., service delivery)
- Legal obligations (e.g., tax, regulatory compliance)
- Legitimate interests (e.g., fraud prevention, security)
- Consent (when explicitly obtained)
6. Data Retention and Deletion
We retain data only as long as required:
- Output files are deleted upon delivery unless otherwise stated
- Operational logs are kept for up to 12 months
- Custom retention periods are defined in the Statement of Work (SOW)
Clients may request data deletion, subject to legal and operational requirements.
7. Data Security and Confidentiality
We implement administrative, technical, and physical safeguards including:
- Encryption (in transit and at rest)
- Role-based access controls
- Multi-factor authentication
- Monitoring and breach detection
All staff and contractors are subject to confidentiality agreements and internal access policies.
8. Subprocessors and Third Parties
We use trusted service providers for hosting, support, and billing. For example:
- AWS (cloud infrastructure)
- Payment processors
- Legal, auditing, and IT consultants
These subprocessors are contractually bound to data protection obligations equal to ours.
A list of current subprocessors is available on request.
9. Cross-Border and International Data Transfers
LucentFlow stores most client data in Canada (AWS Canada Central region).
Temporary transfers to other jurisdictions (e.g., U.S.) may occur for backup or technical purposes. In such cases, we apply:
- Standard Contractual Clauses (SCCs)
- Adequacy assessments
- Technical and contractual safeguards aligned with Law 25 and PIPEDA
10. Use of AI and Automated Decision-Making
Our services may use AI/ML for workflow automation.
We commit to the following:
- Clients retain final decision-making authority
- AI outputs are based solely on client-provided input
- We do not use AI to profile individuals or make employment decisions unless pre-approved
- Clients may request human review of automated outputs
11. Your Privacy Rights
Under Canadian law, authorized client representatives may:
- Access information we hold about them
- Correct inaccurate or outdated records
- Request deletion (within legal limits)
- Withdraw consent (where applicable)
- Object to specific processing
- Request data in a portable format
To exercise these rights, contact us at: privacy@lucentflow.ca
12. Business Transfers
If LucentFlow undergoes a merger, acquisition, or asset sale, client data may be transferred to the successor entity.
We will notify clients and continue protecting their information under this policy.
13. Policy Changes
We may update this policy to reflect operational or legal changes.
Material updates will be communicated via:
- Email to authorized client contacts
- Notices on our platform
Use of services after notification indicates acceptance.
14. Complaints and Contact
To ask questions or file a privacy complaint, contact:
Privacy Officer
Solutions LucentFlow Inc.
Montréal, Québec
📧 privacy@lucentflow.ca
Regulatory contacts:
- Commission d'accès à l'information du Québec — www.cai.gouv.qc.ca | 1‑888‑528‑7741
- Office of the Privacy Commissioner of Canada — www.priv.gc.ca | 1‑800‑282‑1376
