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Privacy policy

What we collect, why, and what you control

Every data decision is documented here. What enters the system, where it lives, who can reach it, and how you can pull it back. PIPEDA, Quebec Law 25, CASL, and CCPA/CPRA — all covered.

Effective date: 2026-03-14 · Version: 1.0


1. Who we are

Forismo ("we", "us", "our") is a Canadian-based SaaS communications platform that provides multi-channel messaging, conversation intelligence, and AI-powered productivity tools. Our headquarters are in Canada and our primary data infrastructure is hosted in the AWS Canada (Central) region.

Privacy Officer: For all privacy-related inquiries, contact our designated Privacy Officer at privacy@forismo.com.

2. What personal information we collect

We collect information that you provide directly and information generated through your use of our platform:

CategoryExamplesPurpose
Account informationName, email address, phone numberCreate and manage your account
CommunicationsMessages, emails, SMS content, voice memosDeliver and store your conversations
Contact dataNames, emails, phone numbers of your contactsEnable multi-channel messaging
Usage dataFeatures used, timestamps, device infoImprove our platform and provide support
Voice recordingsAudio captured during calls or voice memosTranscription and call records (with consent)
AI interaction dataSearch queries, AI analysis contextPower semantic search and conversation intelligence
Payment informationBilling address, payment method (processed by third party)Process subscriptions

3. Why we collect it (PIPEDA Principle 2)

We identify the purpose for collecting personal information before or at the time of collection:

  • Service delivery — To provide, maintain, and improve the Forismo platform
  • Communication — To send, receive, and route messages across channels
  • AI features — To power semantic search, topic extraction, and conversation intelligence (requires explicit consent)
  • Security — To protect your account and maintain audit trails
  • Legal compliance — To meet regulatory requirements under PIPEDA, provincial privacy laws, and applicable US laws
  • Product improvement — To understand usage patterns and improve the platform

4. Consent (PIPEDA Principle 3 & CASL)

We obtain meaningful consent before collecting, using, or disclosing your personal information. Given the sensitivity of communications data, we rely on explicit consent for most processing.

4.1 What requires explicit opt-in

  • AI processing of your messages (semantic search, topic extraction, conversation intelligence)
  • Cross-border data transfer to AI providers (Anthropic, OpenAI, Google, GitHub Models, Modulate.ai) located in the United States
  • Voice recording and transcription
  • Commercial electronic messages (CASL compliance)
  • Marketing communications

4.2 Withdrawing consent

You can withdraw consent at any time through your account settings or by contacting privacy@forismo.com. Withdrawal may affect your ability to use certain features (e.g., AI-powered search will not function without AI processing consent).

5. Cross-border data transfers

Your primary data is stored in Canada (AWS Canada Central region via Supabase). However, certain features involve processing by service providers in the United States:

ProviderLocationPurposeSafeguards
Modulate.aiUnited StatesVoice transcription (Velma STT)DPA, data minimization
xAIUnited StatesGrok AI summaries and server-side semantic analysisDPA, data minimization
VercelGlobal (edge)Application hostingDPA, TLS encryption
TwilioUnited StatesSMS, MMS, and voice deliveryDPA, carrier-grade encryption
ResendUnited StatesTransactional email deliveryDPA, TLS encryption

All cross-border transfers are protected by Data Processing Agreements (DPAs) and adequacy assessments as required by Quebec Law 25. We minimize the personal information sent to AI providers by stripping identifiers where possible.

6. Data protection

  • Encryption at rest: AES-256 encryption on all stored data
  • Encryption in transit: TLS 1.3 (minimum 1.2) for all connections
  • Access controls: Row-level security policies, branch-scoped participant access
  • Audit trail: Immutable event log for all actions on your data
  • Message integrity: Original messages are locked at creation; changes are appended as timestamped addenda

7. Data retention

We retain your data only as long as necessary for the purposes identified:

Data typeRetention periodAction on expiry
Conversations & messages7 yearsArchived
Contacts5 years (inactive)Anonymized
File attachments3 yearsDeleted
Call recordings1 yearDeleted
Voice memos1 yearDeleted
AI processing context90 daysDeleted
Audit logs7 yearsArchived

Data subject to a legal hold will be retained until the hold is released, regardless of retention policy.

8. Your rights

Under PIPEDA, Quebec Law 25, CCPA/CPRA, and other applicable laws, you have the right to:

  • Access — Request a copy of all personal information we hold about you
  • Correction — Request correction of inaccurate personal information
  • Deletion — Request deletion of your personal information (subject to legal holds)
  • Portability — Receive your data in a machine-readable format (fulfilled within 30 days per Quebec Law 25)
  • Opt-out — Opt out of targeted advertising or sale of personal information (we do not sell PI)
  • Restrict processing — Request limits on how we process your data
  • Withdraw consent — Withdraw previously given consent at any time

To exercise any of these rights, submit a request through your account settings, email privacy@forismo.com, or use our Trust Center. We will acknowledge your request within 48 hours and fulfill it within 30 days.

9. CASL compliance

For commercial electronic messages (marketing emails, promotional SMS), we comply with Canada's Anti-Spam Legislation (CASL):

  • Express opt-in consent is required before sending any commercial message
  • All commercial messages identify the sender and include contact information
  • Every commercial message contains a functional unsubscribe mechanism
  • Unsubscribe requests are honored within 10 business days
  • We maintain records of all consent for audit purposes

Note: User-to-user messages sent through the Forismo platform are not commercial electronic messages and are governed by the messaging terms of service, not CASL.

10. Breach notification

In the event of a privacy breach that poses a real risk of significant harm:

  • We will report the breach to the Privacy Commissioner of Canada
  • We will notify affected individuals directly
  • We will document the breach, root cause, and remediation steps

We maintain records of all privacy breaches, including those that do not meet the reporting threshold, as required by PIPEDA.

11. Lawyer-client communications

Forismo provides enhanced protections for legal professionals:

  • End-to-end encryption option for privileged channels
  • No platform access to privileged content
  • Granular access controls with branch-scoped permissions
  • Legal hold capabilities to prevent deletion during litigation
  • eDiscovery support with search, export, and production tools
  • Immutable audit trails compliant with ABA Formal Opinion 477R

12. Changes to this policy

We will update this policy as our practices evolve. Material changes will be communicated via email and in-app notification at least 30 days before taking effect. Continued use of the platform after the effective date constitutes acceptance of the updated policy.

13. Contact & complaints

If you have questions, concerns, or complaints about our privacy practices:

If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner.


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