Privacy Policy

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

Last Updated: August 25, 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).
• For clarity, “Attractr” refers to the application at beta.attractr.live (or its production successor), and “Audience Lab” refers to the community site at audiencelab.attractr.live; both are covered by 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. Akuntsu maintains procedures to assess confidentiality incidents promptly. Where an incident presents a risk of serious injury, Akuntsu will notify the Commission d’accès à l’information (CAI) and affected individuals with diligence, as required by Quebec law, and will record the incident in its register of confidentiality incidents.

5. Your Legal Rights

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

• Right of Access — confirm whether we hold data about you, and obtain a copy.
• Right to Rectification — correct inaccurate, incomplete, or outdated information.
• Right to Erasure — request deletion, subject to legal retention obligations.
• Right to Data Portability — receive your data in a structured, machine-readable format.
• Right to Object to processing for certain purposes.
• Right to Withdraw Consent at any time where processing is based on consent. If withdrawal means we can no longer provide a specific feature, we will tell you before you withdraw.
• 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.

The rights described in this policy apply as provided by the law that governs a given individual and a given activity. Not every right applies to every person in every situation. Akuntsu honours the rights that apply to you under the applicable law.

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. Publicly Available Professional Information

Akuntsu maintains a professional-sector research registry containing limited professional information obtained from publicly accessible sources, including a person’s name, professional role, organization, discipline, geographic area, and professional contact details, together with the source from which the information was obtained. The legal basis, permissible uses, and outreach conditions associated with this registry are subject to confirmation under applicable Quebec privacy and Canadian anti-spam requirements before external deployment. Individuals may request correction or removal from future outreach at any time by contacting privacy@akuntsu.com. Removal requests are recorded on a persistent suppression list so that the individual is not re-contacted or re-added in future research.

9. Privacy Complaint Procedure

If you have a concern about how Akuntsu handles your personal information, you may contact the Person in Charge of the Protection of Personal Information at privacy@akuntsu.com. We will acknowledge your complaint, review and investigate it as needed, respond to you, and where appropriate escalate it internally. If you are not satisfied with our response, you may contact the Commission d’accès à l’information du Québec.

10. 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 present on Akuntsu.com; does not currently deploy any tags. Analytics data collection is delivered via Google Site Kit’s own Google tag (see below). 
• Google Analytics 4 (US) — website traffic and usage analytics. Activated only with your consent, including for visitors in Canada; see Cookie Policy.
• Google Ads / Remarketing (US) — not currently in use.
• Google Site Kit (US) — WordPress plugin used to manage and configure our Google Analytics and Search Console integrations; Site Kit’s own Google tag is the mechanism currently delivering Google Analytics 4 data collection on this site (see Google Tag Manager entry above); it does not independently collect personal information beyond what is disclosed for Google Analytics 4 above.
• Google Fonts (US) — web font delivery. Currently loads on every visit, including before consent, and transmits your IP address to Google as part of the font request. Akuntsu is migrating to self-hosted fonts to remove this pre-consent transmission; until that migration is complete, this is disclosed here as a functional/essential technical dependency. 
• Hostinger (website hosting) / WordPress / Elementor — website hosting and page rendering.
• Notion — internal workspace; used for research synthesis and project documentation.

General Retention Principle: Akuntsu keeps personal information only as long as necessary for the purposes described, or for the period required by applicable law. Financial and transaction records are kept for the period required by applicable tax and accounting law, generally six years, and longer where the law requires it. 

A.4 Retention

• Lead Magnet & Audit Inquiries: 24 months from last contact, then deleted or de-identified, 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 de-identified.
• Google Analytics Data: auto-expires after 14 months.
• Google Ads / Remarketing Data: No remarketing data is currently collected.
• 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, that will be derived from aggregated user interactions once the Clara AI (ClaraLive.ai) engine is operational, 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 de-identified, aggregated insights via Clara AI once operational, 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.
• Google Analytics 4 (US) — audiencelab.attractr.live runs its own separate GA4 property, distinct from the Akuntsu.com property disclosed in Schedule A.3; the Google Site Kit and Google Fonts disclosures in Schedule A.3 apply equally to this property. 
• Hostinger — web hosting for audiencelab.attractr.live (in addition to Akuntsu.com, disclosed in Schedule A.3). 
• Sendbird — in-platform chat.
• Whereby — video streaming.
• Stripe — payment processing. Stripe.js is scoped to checkout and payment-settings pages only, where it sets fraud-prevention cookies (e.g., __stripe_mid, __stripe_sid) essential to processing your payment securely. It is not loaded on the landing page, legal pages, or elsewhere on the site.
• Intercom — customer support chat. Loads only once you grant Functional consent; for signed-in users, Intercom receives your name and email to maintain your support conversation.
• SendGrid — transactional email delivery for the Attractr application. 
• Mapbox — interactive maps within the Attractr application. 
• Cloudflare — content delivery network for the Attractr application. Cloudflare Web Analytics has been disabled entirely as of 31 August 2026 (Real User Measurement turned off at the account level and removed from the Content Security Policy) and no longer collects data on this site.
• Heroku (a Salesforce company) — application hosting for the Attractr platform. 
• PR Butterfly Studio (Serbia) — software development and technical processing, acting strictly as a data processor under a Data Processing Agreement incorporating contractual safeguards, including EU Standard Contractual Clauses where applicable (Module Two: Controller to Processor).

PR Butterfly Studio, 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 PR Butterfly Studio 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 contractual safeguards, including Standard Contractual Clauses where applicable. Copies of relevant DPAs are available on request to privacy@akuntsu.com.

Akuntsu will make reasonable efforts to notify users of new or replacement sub-processors 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 de-identified before any training use, removing direct identifiers, unless and until a full anonymization process is documented. You may withdraw this authorization at any time via a self-service toggle in your account settings, without penalty to your platform access.

Withdrawal applies going forward and does not affect training already carried out using data collected before withdrawal.

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.