Privacy Policy

1. Who is responsible

Soomi Inc. ("Soomi", "we") is responsible for the personal information described in this policy. We are a corporation incorporated under the laws of Canada (corporation number 1801775-1), at 28 Sevenoaks Ave, Etobicoke, Ontario M8Z 3P9.

Our privacy officer is accountable for how we handle personal information. You can reach them at privacy@soomi.ca.

We handle personal information under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, for people in Quebec, the Act respecting the protection of personal information in the private sector (Law 25). This policy covers our website, the Soomi portal and the Soomi apps.

When you use Soomi through an organization. If your employer or another organization provides your Soomi account, that organization decides what happens to the content in its workspace (mail, files, calendars and so on). For that content we act on the organization's behalf and only on its instructions, under our Data Processing Agreement with it. Questions about how your organization uses your content should go to your organization; we will help it answer them. This policy still covers the account information we hold to run the service for you.

2. What we collect

We collect only what we need to provide Soomi, and we tell you why.

When	What we collect
You create an account	Your name, username and Soomi email address, a recovery email address, your language, and your acceptance of our terms (which version, in which language, and when)
You buy a plan	Your billing address (it decides your currency and tax), and a reference to your card with its brand, last four digits and expiry. We never receive your full card number: you enter it on our payment processor's secure form.
You complete your profile	Optionally, your phone number and postal address
You manage a family plan	For each member, their name and Soomi address; for a minor, also their date of birth, and your confirmation that you are their parent or guardian
You use Soomi	Your content (mail, files, calendars, contacts, chats), which is yours and is handled as described in our Terms; and technical information needed to run and secure the service, such as storage used, device passwords you create (we store only a protected form) and security logs that can include IP addresses
You contact us	Your name, email address and what you tell us
You join our waitlist or mailing list	Your email address, your company if you give it, your consent to receive messages, and the date, IP address and browser you used when you confirmed

We do not collect government ID, and we do not buy information about you from anyone.

3. Why we use it, and what we never do

We use personal information only to:

• create and run your account, and deliver the services you signed up for;
• bill you, collect payment, issue refunds and keep the records tax law requires;
• keep accounts and the service secure, and detect and stop abuse;
• answer your questions and support requests;
• send you notices about your account and the service (billing, security, changes to our terms);
• send marketing messages, only if you have opted in (section 10);
• meet our legal obligations.

We never:

• sell personal information, or rent or trade it;
• use it, or your content, for advertising or to build profiles of you;
• use your content to train AI models;
• open your content, except at your request, to investigate reported abuse, or when Canadian law requires it.

If we ever want to use personal information for a new purpose, we will ask you first.

4. Where it is held, and how we protect it

In Canada. Your account information and your content are stored and processed on servers in Canadian data centres, run by Canadian providers and operated by us. Our backups are held in Canada too.

Encrypted, with keys we hold. The disks your information is stored on are encrypted. The keys that unlock them are held by Soomi, on key servers we run ourselves outside our hosting provider, with a backup key held offline by our privacy officer. Our backups are encrypted before they leave the server, with keys only we hold, so a copy of a backup is unreadable to anyone else, including the provider that stores it.

Inside our own database, the most sensitive account details (such as names, email addresses and billing addresses) are additionally encrypted field by field, so even a copy of the database does not reveal them. Passwords are never stored: sign-in is handled by our own identity server, which keeps only a protected hash.

Every connection to Soomi is encrypted in transit. Access to production systems is limited to the people who need it. Our servers can be reached for administration only through a private network, with cryptographic keys rather than passwords; our staff console uses its own separate sign-in.

The limit we want you to know. We rent our servers from a Canadian hosting provider rather than owning the hardware. While a server is running, its unlocked key is in that server's memory, which the provider's systems could in principle access. Encryption protects what is stored on disk and in backups; it does not protect a running system from the operator of the hardware it runs on. Our contract and our choice of a Canadian provider are what protect against that, and include all necessary protections to ensure no external entity can access any of your data.

5. Service providers who receive personal information

We run almost everything ourselves: sign-in, billing, mail, files, office editing and backups are our own systems, not third-party services. Our production network can reach only a short list of outside services, and every addition is reviewed first. These are the providers that receive personal information:

Provider	What they do for us	What they receive	Where
ThinkOn	Hosts our production servers, storage and backups	Everything we store, encrypted on disk with keys we hold (section 4)	Canada
Moneris Solutions	Processes card payments	The card details you type into its secure form (directly from your browser, including your IP address and browser), and from us: a payment token, your postal code, the amount and currency. Not your name or email address.	Canada (ownership: see section 6)
Patrii	Hosts our public website, our waitlist and mailing-list system, and the relay for our internal alerts	Waitlist and mailing-list subscribers' email addresses, consent records, IP addresses and browsers; no customer content	Canada

Rarely, if a refund cannot go back to your card, we may send it by Interac e-Transfer from our bank, which then receives the email address or phone number you give us for it.

We have agreements with each that limit their use of the information to providing their service to us.

When you send an email, it is delivered to the recipient's mail provider, as all email is. That is your communication, not a disclosure by us.

6. Our foreign dependencies, listed in full

We would rather show you every place Soomi depends on something outside Canada than make a sweeping claim. None of these receives your content. This is the complete list, and we update it whenever it changes.

Dependency	Why we depend on it	What it receives	Foreign because
Moneris Solutions	Card payments	The payment details in section 5	A Canadian company whose owners have agreed to sell it to Francisco Partners, a US private-equity firm
Card networks (Visa, Mastercard and others)	Every card payment passes through them	The transaction details any card payment carries	US companies
Let's Encrypt	Issues the security certificates that encrypt connections to Soomi	Only the public names of our servers; no personal information	A US non-profit
Public DNS for our domains	Lets the internet find Soomi's servers by name	Lookups of our public server names, from the networks making them	Our DNS provider's name servers run on Amazon Web Services (US)
Reverse DNS for our IP addresses	Lets other mail servers check that our mail is genuine	Lookups of our servers' addresses	Served by Cloudflare (US) on behalf of our hosting provider
The .com domain registry	Our .com domains depend on it	Nothing about you	Operated by Verisign (US)

When you email or share with someone outside Canada, their own providers receive what you send them. That is your choice, not one of our dependencies.

7. Requests from authorities

We disclose personal information or content to a government or police authority only when valid Canadian legal process requires it (for example, a production order or warrant issued under Canadian law), and only what that process requires. A request from outside Canada must go through Canadian legal process authorized by a Canadian court.

We tell you about such a demand before we respond, unless the law or a court order forbids it, so you can challenge it. For content in a business workspace, we tell the organization.

We do not build or install any way for authorities to access or intercept content directly. Soomi is not end-to-end encrypted, so we can be compelled to produce what we hold; that is why we hold it in Canada, under Canadian law, and keep as little personal information as we can.

8. How long we keep it

We keep personal information only as long as we need it for the purposes in section 3, or as the law requires.

Information	How long
Your account and your content	While your account is open. After you delete it or it closes, it is held 30 days in case you change your mind, then deleted.
Your data export	The download link lasts 24 hours; the archive is deleted 48 hours after it is ready.
Records of the terms and consents you accepted	After your account closes, for as long as we may need to show what was agreed (the legal limitation period)
Billing and tax records	As long as Canadian tax law requires
A record that your account existed and was deleted, without your content	Kept, so your Soomi address is never given to someone else
Backups (of everything above)	Removed within 90 days
Security logs	Up to 90 days, then deleted
Records Canadian law requires us to keep about communications (who, when, from where; never their content)	Only if a law requires it, and only for the period that law sets. Where no law requires it, we do not keep them.
Waitlist and mailing list	Until you unsubscribe. We then delete your details within 30 days, keeping only a coded (one-way) record of your address so we never email you again

Backups and deletion. Backups exist only so we can restore the service after a failure. We do not restore individual files, messages or accounts from backups on request. Deleted information can remain in our encrypted backups until they expire, within 90 days, and is then gone.

9. Your rights

You have the right to:

• Access the personal information we hold about you, and learn how we use it and who we have shared it with.
• Correct it if it is inaccurate or incomplete.
• Take it with you. You can download a complete copy of your account yourself at any time, in standard formats (mail as .eml, calendars as .ics, contacts as .vcf, files as you stored them). On request we also provide your account information in a structured, commonly used format.
• Withdraw consent where we rely on it, for example for marketing messages, at any time. Withdrawing does not affect what was done before, and some uses (like billing records) are required by law.
• Have it deleted. You can delete your account yourself in the portal; it is held for 30 days in case you change your mind, then deleted as described in section 8. Accounts in a business workspace are removed by the organization; an organization's own deletion is arranged with us at privacy@soomi.ca.

To use any of these rights, write to privacy@soomi.ca. We may ask you to confirm your identity first. We answer within 30 days; if we need longer, we tell you why. Using your rights is free.

If you are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca), or, in Quebec, to the Commission d'accès à l'information (cai.gouv.qc.ca).

10. Marketing messages and cookies

Marketing messages. We send news and offers only if you have opted in, and we confirm your sign-up with a second email before adding you. Every message says who it is from and has an unsubscribe link; we act on an unsubscribe within 10 business days, as Canada's anti-spam law (CASL) requires. Our messages contain no tracking pixels and we do not track which links you click. Account and billing notices are not marketing, and you receive them while you have an account.

Cookies. We use cookies only to make Soomi work. We use no advertising, analytics or tracking cookies, and our website and portal load no third-party scripts or fonts.

Cookie	Purpose	How long
Sign-in session	Keeps you signed in to the portal	Up to 30 days, or until you sign out
Security cookies	Protect the sign-in process against forgery	A few minutes
Language	Remembers whether you chose English or French	1 year
App hand-off	Lets the portal open Files and Mail for you without signing in again	Up to a few hours
Files, Mail and sign-in apps	Each app's own sign-in session	Until you sign out or the session ends

Because these cookies are needed for Soomi to work, they cannot be turned off while you use it.

11. Children and family plans

Soomi accounts are for adults. A person younger than the age of majority where they live can have an account only as a member of a family plan, created by their parent or guardian, who confirms that relationship and consents on the child's behalf. Children cannot sign up by themselves.

For a child, we collect only their name, their Soomi address and their date of birth (to know when they become an adult on the plan), stored encrypted. We use a child's information only to provide their account. We never send children marketing, and we never use their information for advertising or profiling.

The parent or guardian can ask to see, correct or delete their child's information at any time, and can remove the child from the plan, which deletes the child's account. When a child reaches the age of majority, they take over their own account and accept our terms themselves.

We do not verify age or identity with documents; we rely on what the parent or guardian tells us.

12. If something goes wrong (security incidents)

If personal information we hold is lost, accessed or disclosed without authorization, we act straight away to contain it and reduce the harm.

If the incident creates a real risk of significant harm to you, we:

• notify you as soon as we can, telling you what happened, what information was involved, what we have done, and what you can do to protect yourself;
• report it to the Office of the Privacy Commissioner of Canada, and, where people in Quebec are affected, to Quebec's Commission d'accès à l'information;
• tell any other organization that can help reduce the harm.

We keep a record of every incident, whether or not it had to be reported, as the law requires.

If you think your account or our service has been compromised, write to privacy@soomi.ca immediately.

13. Changes to this policy, and contact

Every version of this policy is dated, and we keep a record of which version you accepted. If we make a material change (for example, a new kind of information, a new purpose, or a new service provider that receives personal information), we tell you by email and in the portal before it takes effect and, where the law requires, ask for your consent again. Earlier versions are available at soomi.ca/legal.

Contact our privacy officer

• Mark Morais, Privacy Officer, Soomi Inc.
• Email: privacy@soomi.ca
• Mail: 28 Sevenoaks Ave, Etobicoke, Ontario M8Z 3P9, Canada