Privacy Policy

1. Introduction

WarmLead ("we", "us", "our") operates the website warmlead.ca and provides AI powered marketing services for Canadian retirement residences. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our website and services.

We are committed to complying with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's Anti-Spam Legislation (CASL), and Quebec's Law 25 (An Act to modernize legislative provisions as regards the protection of personal information).

2. Privacy Officer

Our Privacy Officer is responsible for overseeing our compliance with privacy legislation and for handling all inquiries related to personal information.

3. Information We Collect

We collect personal information through the following channels:

Through our website forms

• Name, email address, and phone number
• Business name and facility details

Through our AI voice calling system (on behalf of clients)

• Call recordings and transcripts
• Call metadata such as duration and time
• Caller responses including name, relationship to the prospective resident, care type interest, timeline, and tour booking preferences

Through advertising platforms

• Information from individuals who interact with Google and Meta ad campaigns, including clicks, form submissions, and engagement data

Automatically from our website

• IP address, browser type, pages visited, and referring URL

4. How We Use Your Information

We use your personal information for the following purposes:

• To respond to inquiries submitted through our website
• To provide and deliver our marketing services to clients
• To contact leads on behalf of our clients using our AI voice calling system
• To run and optimize Google and Meta advertising campaigns
• To manage client relationships through our CRM system
• To send booking confirmations and service related communications
• To improve our services and website
• To comply with legal obligations

5. Consent

• We obtain consent at the point of collection. Website forms include a clear statement of purpose.
• For AI voice calls, leads consent by submitting their contact information through advertising forms or client websites.
• All AI calls include a disclosure that the call is being recorded.
• Consent is not a condition of accessing our website.
• You can withdraw consent at any time by contacting us. Please note that withdrawal may affect our ability to provide certain services.
• We do not use pre-checked consent boxes or default opt-ins.

6. Sharing and Disclosure

We share personal information with the following service providers to deliver our services:

• GoHighLevel (CRM): stores and manages client and lead data. Servers may be located in the United States.
• Retell AI: powers our AI voice calling system. Call recordings and transcripts are processed through their platform.
• Google and Meta: campaign performance data for advertising operations.
• Our clients: lead information generated through campaigns is shared with the client whose community was advertised.

We ensure all third party service providers maintain security standards comparable to PIPEDA requirements through contractual agreements.

We do not sell personal information to third parties.

We may disclose information if required by law, regulation, or court order.

7. Data Retention

• Contact information for active leads: retained in our CRM until the lead converts, requests removal, or 24 months from last contact, whichever comes first.
• Call recordings and transcripts: retained for 12 months for quality assurance, then securely deleted.
• Website analytics data: retained for 26 months.
• Client account data: retained for the duration of the client relationship plus 12 months.
• You may request deletion of your data at any time by contacting our Privacy Officer.

8. Security Safeguards

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

• HTTPS encryption for all website communications
• Encrypted databases and secure API connections to third party services
• Access controls limiting who can view personal information
• Regular security assessments
• Employee training on data protection practices

If we discover that personal information has been compromised, we will assess whether the breach poses a real risk of significant harm and will notify affected individuals and the Office of the Privacy Commissioner as required by law.

9. International Data Transfers

Some of our service providers, including GoHighLevel, Retell AI, Google, and Meta, may store or process data outside Canada, including in the United States.

We use contractual safeguards to protect information transferred internationally. Please be aware that information stored outside Canada may be subject to the laws of that jurisdiction, including laws that may permit access by government authorities.

10. Your Rights

Under PIPEDA and Quebec's Law 25, you have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Withdraw consent for specific uses of your information
• Request deletion of your personal information
• Receive your data in a portable format (such as CSV)
• Be informed about automated decision-making that significantly affects you
• File a complaint about our privacy practices

To exercise any of these rights, contact our Privacy Officer at stefan@warmlead.ca. We will respond within 30 days.

11. AI and Automated Decision-Making

• We use AI voice technology (powered by Retell AI) to contact leads on behalf of our clients.
• Our AI assistant does not pretend to be human.
• Call recordings are used for quality assurance and service delivery. They are not used to train third party AI models.
• If a caller requests to speak with a person, the system immediately flags the lead for a human callback.
• You have the right to know when AI is being used in communications with you.

12. CASL Compliance

In compliance with Canada's Anti-Spam Legislation:

• We only send commercial electronic messages to individuals who have consented to receive them.
• All messages identify WarmLead as the sender and include our contact information.
• All messages include a clear and functional unsubscribe mechanism.
• We do not harvest email addresses using automated programs.
• To opt out of commercial messages, use the unsubscribe link in any message or contact us directly.

13. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children.

For Quebec residents under the age of 14, consent must be provided by a parent or legal guardian in accordance with Law 25.

14. Sensitive Information

• Our AI voice calling system may incidentally collect health-related information during conversations, such as care type needs or mobility concerns.
• We apply heightened safeguards to any sensitive information we receive.
• We only collect sensitive information when necessary for the identified purpose and with explicit consent.
• We do not collect detailed medical diagnoses, financial information, or other highly sensitive personal data.

15. Complaints

If you have concerns about how we handle your personal information, please contact our Privacy Officer first at stefan@warmlead.ca.

If you are not satisfied with our response, you may file a complaint with:

• Office of the Privacy Commissioner of Canada: www.priv.gc.ca
• Commission d'acces a l'information du Quebec (for Quebec residents): www.cai.gouv.qc.ca

16. Changes to This Policy

• We review this policy at least annually and update it as our practices evolve.
• If we make material changes, we will update the date at the top of this page.
• Continued use of our services after changes are posted constitutes acceptance of the updated policy.

This policy is provided for informational purposes. Please consult legal counsel for formal compliance review.