DRAFT — for legal review before launch. Not yet in force. Section 1a (file uploads) is new and NEEDS OLIVER'S REVIEW.

Privacy Policy

Last updated: [DATE]. Operator: MONAD INDUSTRIES SOFTWARE CORP. ("we"). Contact / Privacy Officer: privacy@example.com.

1. What we collect

• Tax documents you upload (e.g. Notice of Assessment, T4, W-2, 1040, P60, P45). Processed in server memory only and discarded immediately after reading; never written to disk or a database.
• Extracted figures (tax year, income totals, tax withheld, tax code, lines already claimed) and your questionnaire answers, used to compute your results.
• Identification numbers (SIN, SSN/ITIN, National Insurance number) are automatically removed before any processing by our AI provider and are never stored.
• Payment: handled by Stripe; we receive confirmation of payment, not your card details.
• Technical data: IP address for rate-limiting and security (short-lived), a session cookie.

1a. File uploads [NEW — needs Oliver's review]

• You may upload up to 5 files per check (PDF, JPG or PNG, max 10 MB each). We check the file type from its contents and reject anything else.
• Each file is held in server memory only while we read it: PDFs by text extraction, photos by optical character recognition (OCR) on our own server. The photo or PDF itself is not sent to xAI or any other third party.
• SIN, SSN/ITIN and National Insurance numbers are removed from the extracted text. Only that redacted text is sent to xAI to identify figures such as tax year, income and tax withheld.
• The file is wiped from memory as soon as reading finishes (normally within seconds). Files are never written to disk or a database, and their contents are never written to our logs.
• The figures we extract are shown to you to confirm or correct before any check runs. Only those figures and your answers are kept with your session.

2. Why (purposes and legal bases)

To provide the service you request (contract, GDPR/UK GDPR Art. 6(1)(b)); with your express consent for processing financial information (PIPEDA; Quebec Law 25 s. 12; IRC §7216 for US tax return information); security and fraud prevention (legitimate interests); legal obligations (tax/accounting records of payments).

3. Subprocessors and transfers outside your country

• xAI LLC (United States) — AI model (Grok) that reads the redacted text of your document and writes plain-language explanations. We request no retention for training; data is transferred to the US.
• Neon (Postgres database, region [TBD]) — stores computed results only.
• Render (hosting, region [TBD]).
• Stripe (payments).

Quebec residents (Law 25): before communicating personal information outside Quebec we conducted a privacy impact assessment [TO COMPLETE]; information sent to xAI in the United States may be accessible to US authorities under US law. EU/UK: transfers rely on Standard Contractual Clauses / the UK IDTA or Addendum [TO CONFIRM with each subprocessor].

4. Retention

Uploads: deleted immediately after processing (seconds). Session state: memory, expires after 2 hours of inactivity. Computed reports: [12 months] then deleted, or sooner on request. Payment records: as required by tax law.

5. Your rights

Access, correction, deletion, portability, withdrawal of consent, objection and restriction (GDPR/UK GDPR); access and correction (PIPEDA); Quebec Law 25 rights incl. de-indexation and information on automated decisions. Our eligibility results are produced by fixed rules, not decisions with legal effect. Complain to the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, the UK ICO, or your EU supervisory authority.

6. US users — IRC §7216 consent

Federal law requires this consent form be provided to you. Unless authorized by law, we cannot use your tax return information for purposes other than providing the service without your consent. By ticking the consent box you consent to us using your tax return information to identify possible credits and to disclose a redacted copy to xAI LLC (US) for that purpose only. Consent is valid for [one year]. If you believe your tax return information has been disclosed or used improperly, contact the Treasury Inspector General for Tax Administration (TIGTA) at 1-800-366-4484 or complaints@tigta.treas.gov. [Counsel to confirm whether §7216 applies to this service and final wording per Rev. Proc. 2013-14.]

7. Security

TLS, strict security headers, rate limiting, redaction before AI processing, no document storage, least-privilege access.

8. Children

Not intended for users under 16 (13 in the US).