Privacy Policy

This policy reflects Akuntsu’s current data practices and is undergoing review by Quebec legal counsel.

Last Updated: August 10, 2026

Akuntsu Inc. (“Akuntsu”, “we”, “us”, “our”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us. This Privacy Policy governs:

• Akuntsu.com and all associated subdomains, downloadable resources, lead magnets, and market research initiatives (see Schedule A);
• Attractr and Audience Lab, Akuntsu’s performing arts platform and community, including user accounts, Production Pages, Live Rooms, marketplace transactions, and user-submitted content (see Schedule B).

Where this Privacy Policy and a Schedule conflict, the Schedule controls for its respective platform.

We operate from Montreal, Quebec, Canada. Our practices comply with Quebec’s Law 25, Canada’s PIPEDA, Canada’s Anti-Spam Legislation (CASL), and, for individuals located in the European Union, the GDPR.

1. Corporate Identity & Privacy Officer

• • Corporate Entity: Akuntsu Inc. (6878938 Canada Inc.)
  • Chief Executive Officer: Serge Labelle
  • Mailing Address: 4060 Boulevard Saint-Laurent, Suite 703, Montreal, Quebec, Canada, H2W 1Y9
  • Privacy Officer: Yuko Nakamura
  • Privacy Contact: privacy@akuntsu.com

     

2. Personal Information We Collect

See Schedule A (Akuntsu.com) and Schedule B (Attractr / Audience Lab) for platform-specific detail.

3. Third-Party Service Providers & Cross-Border Transfers

We share personal information only with service providers acting as data processors under contractual safeguards equivalent to Law 25. Full processor lists appear in each Schedule. Where a provider processes data outside Canada, Akuntsu conducts a Privacy Impact Assessment (PIA) before transfer and maintains a contract (including Standard Contractual Clauses where applicable) with the receiving processor.

4. Security Measures

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the data processed, including mandatory multi-factor authentication (MFA) across administrative access, encryption of data at rest and in transit, role-based access controls, and logging of system access events. In the event of a confidentiality incident presenting a risk of serious injury, Akuntsu will notify the Commission d’accès à l’information (CAI) and affected individuals with diligence, in accordance with Law 25’s requirements. We maintain an internal register of confidentiality incidents as required by Law 25.

5. Your Legal Rights

Depending on your location, you may have rights under Law 25, PIPEDA, or the GDPR, including:

1. Right of Access — confirm whether we hold data about you, and obtain a copy.
2. Right to Rectification — correct inaccurate, incomplete, or outdated information.
3. Right to Erasure — request deletion, subject to legal retention obligations.
4. Right to Data Portability — receive your data in a structured, machine-readable format.
5. Right to Object to processing for certain purposes.
6. Right to Withdraw Consent at any time, without penalty.
7. Right to Lodge a Complaint with:
   
   Commission d’accès à l’information du Québec (CAI)
   cai.gouv.qc.ca | 1-888-528-7741
   

To exercise any right, contact privacy@akuntsu.com. We respond within 30 days, as required by Law 25.

6. Language / Langue

This Privacy Policy is available in both English and French. For users located in the Province of Quebec, the French version shall prevail where required by applicable law.

Cette politique de confidentialité est disponible en français et en anglais. Pour les utilisateurs situés au Québec, la version française prévaut lorsque la loi applicable l’exige.

7. Changes to This Policy

We may update this Privacy Policy to reflect technological, legal, or operational changes. Material updates are indicated by revising the “Last Updated” date, and where changes materially affect your rights, we will provide additional notice.

8. Contact Us

Questions about this Privacy Policy: privacy@akuntsu.com

SCHEDULE A — Akuntsu.com (B2B Services, Leadgen, Research)

A.1 What We Collect

• Downloadable Resources, Demos & Lead Magnets (via Tally, Brevo, Airtable): First Name, Last Name, Work Email, Job Title, Discipline/Role, Organization Name.
• Audit Requests, Contact & Booking Forms: Full Name, Work Email, Company Name, Job Role, Project Requirements, Pain Points, Budget Range, Selected Service Areas.
• Surveys & Sector Studies (via Tally): Name, Contact Details, Professional Role, Sector, Regional Base, Operating Costs, Qualitative Responses. Participation is offered on an Identifiable or fully Anonymous basis, clearly gated at survey start.
• Direct Professional Outreach (via Mailmeteor / Google Workspace): outreach dates, campaign tokens, role relevance, opt-out status. CASL-compliant: every commercial message includes our physical address and a functional unsubscribe mechanism, valid for at least 60 days, honored within 10 business days.
• Website Analytics (Google Analytics 4): standard log data. Non-essential tracking is disabled by default, activating only on explicit cookie-banner consent.

A.2 Purpose & Legal Basis

A.3 Third-Party Processors

• Tally (EU) — forms, surveys, dynamic lead magnets.
• Airtable (US) — CRM, audit pipeline, consent logs.
• Brevo (EU) — newsletter and resource delivery.
• Mailmeteor (Google Workspace-integrated) — outreach campaigns.
• Google Tag Manager (US) — tag management container used to deploy the analytics and advertising tools listed below; does not itself collect personal information.
• Google Analytics 4 (US) — website traffic and usage analytics. Activated only with your consent; see Cookie Policy.
• Google Ads / Remarketing (US) — used to show relevant ads to visitors who have previously interacted with our website, based on non-anonymized advertising identifiers. Activated only with your consent; see Cookie Policy.
• Google Site Kit (US) — WordPress plugin used to manage and configure our Google Analytics and Search Console integrations; does not independently collect personal information beyond what is disclosed for Google Analytics 4 above.
• Hostinger (website hosting) / WordPress / Elementor — website hosting and page rendering.
• Notion — internal workspace; used for research synthesis and project documentation.

A.4 Retention

• Lead Magnet & Audit Inquiries: 24 months from last contact, then deleted or anonymized, unless an active commercial relationship exists.
• Marketing Subscribers: until unsubscribe or consent withdrawal.
• Raw, Identifiable Survey Data: retained 12 months post-collection for follow-up/validation, then deleted or irreversibly anonymized.
• Google Analytics Data: auto-expires after 14 months.
• Google Ads / Remarketing Data: governed by Google’s own retention settings for remarketing audiences (typically up to 540 days); withdrawing consent stops new data collection but does not retroactively delete data already processed by Google.
• Former Client Records: retained 7 years for Quebec commercial/tax record-keeping, then securely deleted.

A.5 Client Operational Data

Where Akuntsu processes a client’s own staff, contact, or financial data while delivering an active service (e.g., Staff CRM/LINE-WhatsApp automation, Budget/P&L tracking), that processing is governed by a separate Data Processing Agreement executed per engagement, not by this Privacy Policy.

A.6 Liability Cap (Akuntsu.com Services)

See Terms of Use, Section 4 — a separate cap from Attractr’s, reflecting the different nature and scale of each service.

SCHEDULE B — Attractr & Audience Lab (Platform, Accounts, Marketplace, UGC)

B.1 Eligibility

Attractr and Audience Lab are intended solely for individuals 18 years of age or older. By registering, you represent you meet this requirement. We reserve the right to use third-party identity verification services to confirm age; verification providers act as data processors and are contractually obligated to delete verification data once confirmation is complete. We do not knowingly collect personal information from anyone under 18; if we learn we have, we delete it as soon as possible.

B.2 What We Collect

• Identity & Role-Based Data: name, email, verified date of birth, phone number. For Suppliers: tax IDs (GST/HST/QST), business registration details, banking information for payouts. For audience members: interests and creators supported.
• Audience Lab Data: forum posts, community comments, educational progress tracking, WordPress/WooCommerce interaction data.
• Automated Technical Data: IP addresses, device information, usage metrics.
• AI-Generated Insights: predictive “Cultural Intelligence” signals derived from aggregated user interactions by the Clara AI (ClaraLive.ai) engine, designed to avoid identifying specific individuals and not used for individual-level profiling or decisions with legal or similarly significant effects.

B.3 How We Use Your Information

To provide and maintain the Services (marketplace, Audience Lab, Clara AI features); process payments and payouts; communicate about your account and provide support; personalize your experience; generate anonymized, aggregated insights via Clara AI to improve the Services and support market research; detect and prevent fraud and security issues; and enforce our Terms.

B.4 Third-Party Processors

• Brevo SAS — newsletter and email communications.
• Airtable Inc. (US) — CRM and member database management.
• Automattic Inc. / WordPress.com (US) — website hosting, blog publishing.
• Sharetribe — marketplace infrastructure.
• Google Cloud — data storage.
• Sendbird — in-platform chat.
• Whereby — video streaming.
• Stripe — payment processing.
• Butterfly Innov (Serbia) — software development and technical processing, acting strictly as a data processor under an executed Data Processing Agreement and Transfer Impact Assessment incorporating EU Standard Contractual Clauses (Module Two: Controller to Processor).

Butterfly Innov, as Akuntsu’s technical processor, is separately authorized to engage its own limited sub-processor(s) for functions within its scope of work; any such further sub-processing is governed by Akuntsu’s Data Processing Agreement with Butterfly Innov and is not a use of your data beyond what is disclosed above.

Transfers to sub-processors located in the United States (Airtable, Automattic) are governed by executed Standard Contractual Clauses. Copies of relevant DPAs are available on request to privacy@akuntsu.com.

Akuntsu will notify users at least 14 days before onboarding any new or replacement sub-processor with access to their data, and users may object by contacting privacy@akuntsu.com.

B.5 Retention & Deletion

• Account data: retained until account deletion.
• Financial data: retained 7 years for tax compliance.
• Security logs: retained 12 months.
• CRM records (Airtable): retained for active membership duration plus 24 months, unless earlier deletion is requested.

Upon a valid account deletion request, all personally identifiable information linked to the profile — legal name, professional handle, verification logs, email, uploaded avatars, billing records — is deleted or de-identified from our active production systems, except where retention is required or permitted by law (e.g., financial recordkeeping, fraud prevention, or security purposes) or exists in secure backups pending routine rotation. Forum posts and comments you created prior to deletion remain visible, stripped of personal identity and reassigned to an anonymized handle labeled [Anonymous User], to preserve community continuity. By participating in Audience Lab forums, you grant Akuntsu the permanent, non-exclusive right to maintain such anonymized text.

B.6 Artificial Intelligence & Machine Learning Training

Our AI engine, ClaraLive.ai, is under active development and not currently operational or deployed in the current launch phase. By default, your content and personal data are not used to train our AI models. Any use of your data for machine learning training requires your separate, explicit, affirmative opt-in consent — this option is unchecked by default at registration. Before any future training, data is subjected to irreversible anonymization removing all personally identifiable information. You may withdraw this authorization at any time via a self-service toggle in your account settings, without penalty to your platform access. This consent applies specifically to the training use described above. Any new or materially different use of your data for AI training will require separate, additional consent.

B.7 Liability Cap (Attractr / Audience Lab)

See Terms of Use, Section 4.