Privacy Policy
Last updated on October 1, 2024.
Application of this Privacy Policy
This Privacy Policy describes the ways in which PlaceHolder Canada Inc. (“Placeholder”, “we”, “us”, or “our”) collects, uses, and discloses your personal information (“Personal Information”) through the Lead Assistant, an email-based product for organization and automation of customer communications (the “Lead Assistant Subscription Service”). “Personal Information” includes any information that can be used on its own or with other information to identify a single person or to identify an individual in context.
This Privacy Policy sets out how we handle Personal Information that we gather when you are using the Lead Assistant Subscription Service. It does not cover the practices of individuals, companies and entities we do not own, control or manage.
If you see an undefined term in this Privacy Policy, it has the same definition as in our Terms of Service for Subscription Services (“Terms”).
By using the Lead Assistant Subscription Service or submitting Personal Information through the Lead Assistant Subscription Service, you acknowledge that you have read about how we process your information as set out in this Privacy Policy, now and as amended, by us. Please do not use the Lead Assistant Subscription Service and do not submit any information through it if you have not read this Privacy Policy or do not agree with its terms.
Information We Collect and How We Use the Information
From time to time, we may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
Personal Data - While using the Lead Assistant Subscription Service, we may ask you to provide us with personally identifiable information that can be used to contact or identify you, which may include, but is not limited to:
Email address
First and last name
Usage data
Contents and metadata of your emails
Usage Data - We and our service providers may collect certain information by automated means, such as cookies, web beacons, log files, and similar technology (explained more below), as you use the Website. This includes data such as your internet protocol address, device characteristics, browser characteristics, operating system, language preferences, clickstream data (e.g., a list of pages or URLs visited before and after the website visit), search terms entered, and dates and times of visits to the Website. This information allows us to recognize you and personalize your experience if you return to the Website and to improve the Service.
Cookies — a “cookie” is a file that websites send to a visitor’s internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.
Web Beacons — a “web beacon”, also known as an internet tag, pixel tag, or clear GIF, is a clear graphic image that may be embedded in an email to record when a user opens the email or may be loaded by a web browser to record a user’s visit to a particular website.
Log Files — a “log file” is a file that records how users interact with websites or a server.
We process your email data using AI and machine learning to provide features such as automatic message type identification and classification, inbox labeling, summary reports, auto-generated draft replies, suggested call-to-actions, listing-specific recommendations, contact history display etc. This processing is integral to the service we provide and is performed with your consent.
We do not make automated decisions using your data. We do not use any profiling tools or systems to process your data and make decisions based on profiling.
Access to Google User Data - We use OAuth authentication to manage your email inbox on your behalf. OAuth is a secure mechanism that gives us access to your Google account data without sharing your password. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including Limited Use requirements. Specifically, data obtained from Google Workspace APIs is not used to develop, improve, or train generalized AI and/or ML models.
You may provide your consent to data collection during the account creation process or within your account settings. You can also opt-out or withdraw your consent at any time through your account settings. If you choose not to provide certain types of personal data, you may be unable to access functionalities of the service particularly those that require email processing.
Please review How Google uses data when you use our partners’ sites or apps.
Usage of Google Analytics - We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies. The information generated by the cookie about your use of the website, including your IP address, will be transmitted to and stored by Google.
Purpose and Scope:
Analysis: Google will use this information to evaluate your use of our website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.
Data Sharing: Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
User Options:
Opt-Out: You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of the Services.
Browser Add-On: Additionally, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under Google Analytics Opt-out Browser Add-on.
How We Share Information
We may share your Personal Information in the following situations:
With Service Providers: To monitor and analyze the use of our Service, to contact you and to assist in the operation of our AI and machine learning algorithms.some text
Email data is transiently shared with third-party Large Language Model providers for summarizing, labeling and drafting.
Post-processing, email data is either irrevocably deleted, or only stored in an anonymized fashion to learn from it on how to better process future messages.
We will only work with Service Providers that adhere to strict data usage policies.
For Business Transfers: To affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, dissolution, bankruptcy, acquisition, or sale of Placeholder or all or a portion of our assets or other business transfers, but Placeholder will require the acquiring organization to agree to protect the privacy of Personal Information in a manner that is consistent with this Privacy Policy.
With Affiliates: To any of the companies and business entities that form part of the Placeholder group in order to serve you better and to provide you with information about our affiliates’ products and services.
With Your Consent: We may disclose your personal information for any other purpose with your consent.
Where Required: To a government institution that has asserted its lawful authority to obtain the information or where Placeholder has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to Placeholder’s legal counsel;
Safety: When we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the Subscription Service, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our terms of use or other legal agreements, violations of law, or other misuse of the Subscription Service.
We may also share or sell aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
We do not transfer or disclose your information to third parties for purposes other than the ones provided, to provide or improve the Services.
All data sharing, including with Google APIs, adhere to external policies like the Google API Services User Data Policy, including the Limited Use requirements.
Third Party Links
The Service may contain third party links. You acknowledge that we are not responsible for the collection and use of Personal Information by such third parties that are not under our control. We encourage you to review the privacy policies of each website you visit.
Data Retention and Deletion
Except as otherwise permitted or required by applicable law or regulation, we retain Personal Information only for as long as is necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting or reporting requirements.
In some circumstances, we may aggregate and de-identify Personal Information so that it may no longer be associated with you. We reserve the right to use such aggregated and de-identified data for any legitimate interest.
You have the right to request the deletion of your Personal Information at any time. Upon your request, we will delete your data unless we are legally required to retain it.
How We Protect Information
The security of Personal Information is very important to us. We use administrative, technical, and physical measures to secure Personal Information against unauthorized access, use, disclosure, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your DataCo Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your DataCo Account, please contact us following the instructions in the Contact Us section below.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the DataCo Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted to our website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.
Children’s Information
The Service is not directed to, nor do we knowingly collect Personal Information from, any one under the age of majority without parental/guardian consent. If you have reason to believe that we may have collected a minor’s Personal Information without parental/guardian consent, please contact us at the contact information listed below.
Changes to this Privacy Policy
If we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page. If we make any revisions that materially change the ways in which we use or share the Personal Information previously collected from you through the DataCo Service, we will give you the opportunity to consent to such changes before applying them to that Personal Information to the extent required by law.
Contact Us
PlaceHolder has a data protection officer and privacy officer who is responsible for matters relating to privacy and data protection and who can be contacted at the information below.
If you have any questions about this Privacy Policy or our use of Personal Information collected through the Service, please contact us at privacy@placeholder.com.
© 2025 Placeholder Canada Inc.