Pholeo Privacy Policy
Effective Date: September 27, 2026
Last updated: October 8, 2026 (corrected company legal name).
Introduction
Pholeo Technologies Inc. ("Pholeo," "we," "us," or "our") operates the Pholeo
marketing portfolio platform (the "Service"), including portfolio
creation and publishing, first-party templates, free and paid
subscription plans, and job listings. This Privacy Policy explains how
we collect, use, disclose, and protect your personal information when
you use the Service.
Please read this Privacy Policy together with our Terms of Service.
Where we rely on consent for a particular use (for example, promotional
emails), we will ask for that consent separately where required by law.
Using the Service means you acknowledge this Privacy Policy; it does not
waive rights you have under PIPEDA or other applicable law.
1. Definitions
-
Personal Information means information about an
identifiable individual, as defined under the Personal Information
Protection and Electronic Documents Act (PIPEDA).
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User Content means any content uploaded or created by
users on the Service.
-
Billing Information means payment-related data such
as credit or debit card details, billing address, and transaction
history.
2. Information Collection
We collect the following categories of information:
-
Registration Information: When creating an account,
we collect your name, email address, and authentication credentials
(password is stored in hashed form).
-
Billing Information: When you subscribe to a paid
plan or make a purchase, our third-party payment processor collects
your payment details (e.g., credit or debit card number, expiration
date, and billing address). Pholeo does not directly store full
payment card numbers. We receive and retain limited transaction data,
such as the last four digits of your card, transaction amounts, and
billing dates, for record-keeping and support purposes.
-
User Content: We store content you upload or create
on the platform, including marketing materials and portfolio
information.
-
Contact Form Submissions: If you add a contact form
to a published portfolio, we collect the name, email address, and
message a visitor submits so we can deliver that message to you.
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Usage Data: We collect data on how you use the
platform, including page views, feature interactions, clicks, and
errors.
-
Device Information: We collect device type, operating
system, browser type, browser language, and IP address.
-
Employer Account Information: If you create an
employer account, we collect information needed to operate that
account (such as name, email, company or organization details you
provide, and authentication credentials).
-
Job Application Information: If you apply to a role
through the Service, we process information related to that
application, including your identity as associated with your account
or application, your published portfolio content made available to the
employer for that application, any optional message you include, and
application status updates within the platform.
3. Use of Information
We use collected information for the following purposes:
- To provide, maintain, and improve the Service
- To authenticate users and manage accounts
- To process payments, manage subscriptions, and send billing-related communications (e.g., receipts, renewal reminders, and failed payment notices)
- To communicate with you about your account, including service announcements, security alerts, and customer support messages
- To deliver contact form submissions from visitors to the portfolio owner who enabled the form
- To operate job listings, including enabling employers to post roles, enabling candidates to apply with portfolio-based applications, showing employers the candidate information described in Section 6, and providing application-status visibility where available
- To enforce our Terms of Service, including employer-use restrictions related to candidate data
- To send product research and feedback requests related to improving the Service (for example, short surveys or interview invites). These messages are not promotional offers. Each such message will include a way to opt out of future product-research emails (such as an unsubscribe link or an equivalent opt-out instruction), and you may also opt out through your account settings or by contacting [email protected]. Opting out of product-research emails does not affect transactional or account messages (such as billing, security, or support)
- To send promotional communications, such as information about new features, offers, or content relevant to you (you may opt out of promotional emails at any time using the unsubscribe link in any such email or through your account settings)
- For analytics purposes, to understand how users interact with the Service and to improve our offerings
- To detect, prevent, and address fraud, abuse, or security issues
4. Data Storage and Security
We primarily store user data in secure cloud infrastructure located in
Canada, but some of our service providers may process data in other
jurisdictions. We implement industry-standard security measures,
including encryption of data in transit and at rest, access controls,
regular security reviews, and secure authentication protocols. While we
take reasonable steps to protect your information, no method of
electronic storage or transmission is completely secure, and we cannot
guarantee absolute security.
6. Employer Access to Candidate Information
When a candidate submits a job application through the Service, the
following information becomes visible to the employer who posted the
role:
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The candidate's name and any information included in their published
portfolio, including case studies, project descriptions, stated
outcomes, and skills.
-
An application snapshot of published portfolio information, which may
include the portfolio title, headline, thumbnail, specialisation or
skill tags, and the contact email shown on the published portfolio, if
the candidate has provided one.
-
Any optional message the candidate includes with their application.
-
The candidate's application status as updated within the platform.
The following information is not visible to employers through the
Service:
-
The candidate's account email address, unless the candidate has also
included that address (or another contact email) in their published
portfolio.
-
Any portfolio content the candidate has not published (drafts,
unpublished work).
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Any information from other applications the candidate has submitted on
the platform.
-
Private hiring notes an employer records about an application. Those
notes are visible only to that employer.
Pholeo tracks employer interactions with applications, including when an
application is viewed or a status is changed, for platform analytics and
to provide candidates with application status visibility. This activity
data is not shared with third parties. Employers are prohibited from
using candidate data outside of the permitted uses described in Section
3A of the Terms of Service. Pholeo may investigate reports of misuse and
suspend or terminate accounts as described in the Terms.
7. Cookies and Tracking Technologies
We and our partners may use cookies and similar tracking technologies:
-
Essential Cookies: Required for the Service to
function, including authentication and session management.
-
Analytics Cookies: Used to understand how users interact with the Service (including marketing pages), measure performance, and identify areas for improvement. We use product analytics tools, currently Mixpanel and Google Analytics 4 (measurement ID configured in our site), that may set their own cookies or similar identifiers and may process usage data (such as page views, device/browser information, approximate location derived from IP, and referral information) in other jurisdictions, including the United States, as described in Sections 4 and 12. More detail is in our Cookie Policy.
-
Preference Cookies: Used to remember your settings
and preferences across sessions.
You can manage cookie preferences through your browser settings.
Disabling certain cookies may affect the functionality of the Service.
8. User Rights
Under applicable privacy laws, including PIPEDA, you have the following
rights regarding your personal information:
-
Access: You may request access to the personal
information we hold about you.
-
Correction: You may request correction of inaccurate
or incomplete personal information.
-
Deletion: You may request deletion of your account
and associated personal data, subject to our legal retention
obligations (see Section 9).
-
Withdrawal of Consent: You may withdraw your consent
for data processing at any time, subject to legal or contractual
restrictions. Withdrawal of consent may affect your ability to use
certain features of the Service.
-
Export / copy of your information: Where available in
product settings, or upon request where required by applicable law,
you may obtain a copy of certain personal information we hold about
you in a commonly used, machine-readable format, where technically
feasible.
-
Opt Out of Marketing and Product Research: You may
opt out of promotional communications and/or product-research and
feedback emails at any time (see Section 3).
To exercise any of these rights, contact us at
[email protected]
or use the relevant options in your account settings. We will respond to
your request within 30 days.
9. Data Retention
We retain your personal information for as long as necessary to provide
the Service, fulfill the purposes described in this Privacy Policy, or
as required by applicable laws. Specifically:
-
Account Data: Retained for as long as your account is
active. Upon account deletion, we will delete or anonymize your
personal data within 30 days where feasible, except for residual
copies in backups or logs and where required for legal, security, or
compliance purposes.
-
Billing and Transaction Records: Retained for a
period of up to 7 years after the date of the transaction to meet
tax, audit, and financial record-keeping requirements.
-
Usage and Analytics Data: Retained in aggregated or
anonymized form and may be kept indefinitely for analytical purposes.
After the applicable retention period, we will securely delete or
anonymize your personal data in accordance with our data management
practices and legal obligations.
10. Data Breach Notification
In the event of a data breach that creates a real risk of significant
harm to individuals, Pholeo will notify affected users and the Office
of the Privacy Commissioner of Canada as required under PIPEDA. We will
provide notification as soon as feasible after becoming aware of the
breach, including a description of the breach, the types of information
involved, and the steps we are taking in response.
11. Children's Privacy
The Service is not intended for individuals under the age of 18. We do
not knowingly collect personal information from children under 18. If
we become aware that we have collected personal information from a child
under 18, we will take steps to delete such information promptly. If you
believe a child under 18 has provided us with personal information,
please contact us at
[email protected].
12. International Data Transfers
Pholeo is based in Canada, and your personal information is primarily
stored and processed in Canada, but some service providers may process
data in other jurisdictions (including, where applicable, the United
States). If you access the Service from outside Canada, your information
may be transferred to, stored in, and processed in Canada or other
countries. Privacy laws in those countries may differ from those in your
jurisdiction. We take reasonable steps to protect personal information
when it is processed by service providers, including contractual
obligations to safeguard the information, consistent with this Privacy
Policy and applicable Canadian privacy law. If we rely on consent for a
particular transfer or use, we will obtain it as required.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify
users of any material changes at least 30 days in advance through email
or in-app notifications. The "Effective Date" at the top of this page
indicates when this Privacy Policy was last revised. Your continued use
of the Service after the updated Privacy Policy takes effect constitutes
your acceptance of the changes.
14. Contact
If you have questions, concerns, or complaints about this Privacy Policy
or our data practices, please contact us at:
[email protected]
If you are not satisfied with our response, you may file a complaint
with the Office of the Privacy Commissioner of Canada at
www.priv.gc.ca.
15. Governing Law
This Privacy Policy is governed by and construed in accordance with the
laws of Canada, including PIPEDA and applicable provincial privacy
legislation.