Privacy policy.

1. Our roles by activity

Whether Allemnii is a "controller" (decides why and how personal data is used) or a "processor" (acts only on a client's instructions) depends on the activity.

We do not run advertising, we do not sell personal data, and we do not build independent profiles of individuals.

2. Personal data we collect for ourselves

When we act as controller, we collect the following.

• Enquiries and communications: name, business email, organization, role, and the content of your message when you contact us or book a conversation.
• Training and events: registration details and any feedback you choose to give. Training delivered for a client is covered in Section 4.
• Recruiting: application materials such as CVs, contact details, and interview notes.
• Website technical data: IP address, browser type, and pages requested, recorded in standard server logs.
• Account data for our own tools: name, email, role, and authentication identifiers.
• Business contact details of prospects and client personnel (name, business email, organization, and role), usually given to us directly.

Why we use it. To respond to you, deliver and improve our services, send communications you have agreed to receive, evaluate applications, keep our website and tools secure, and meet legal obligations.

Our basis. Your consent where it is required (marketing communications, testimonials, keeping applications beyond a specific vacancy), and our legitimate business interests where the law permits (answering business enquiries, security). You can withdraw consent or unsubscribe at any time.

Email marketing. Any commercial email we send follows Canada's anti-spam law and includes an unsubscribe link.

Sharing. We share personal data only with service providers acting under written terms (Section 5) and where the law requires it. We do not sell personal data.

3. Allemnii Marketing

Allemnii Marketing, our social publishing tool, uses LinkedIn's APIs (the Community Management API and Share on LinkedIn) to publish content to the Allemnii LinkedIn Page and, in future, to LinkedIn Pages that our clients authorize us to manage. Members of an organization using our tool can also connect their own LinkedIn account to publish posts to their personal LinkedIn profile.

What we access. When a member connects their LinkedIn account, LinkedIn gives us an access token (and, where LinkedIn issues one, a refresh token), the member's name and LinkedIn member ID, and the permissions they granted. When a Page administrator connects, we also receive the list of Pages they administer, and for the Page they link we keep its name and LinkedIn identifier. We keep the content of posts we publish and the identifier LinkedIn assigns to each published post. We also keep any brand settings, such as tone of voice and logos, that users of our tool provide.

How we use it. Only to schedule and publish posts approved by an authorized member of the organization that connected the Page, and to show the status of those posts. A post to a personal profile is published only when that member schedules it. We do not use LinkedIn data for advertising, we do not sell it, we do not share it with third parties for their own use, and we do not combine it with other data to build profiles of individuals.

Engagement metrics (planned). We plan to read engagement metrics for the posts we publish, such as impressions, clicks, and reaction, comment, and share counts, to show administrators how those posts perform. We do not collect these metrics yet. When we do, we will keep them for 90 days by default, or longer if a client asks us to keep a longer history for its own Page, and delete them when the integration ends.

Client Pages. If we manage a Page for a client, the client's authorized administrator connects it, we act on that client's instructions as its processor (Section 4), and we keep each client's LinkedIn data separate from every other client's. A member's LinkedIn connection belongs to that member: if they work in more than one organization in our tool, the same connection publishes for each, while each organization's linked Page, posts, and brand settings stay separate.

Storage and security. Access and refresh tokens are encrypted with keys held in Google Cloud Key Management Service (Cloud KMS) before we store them, and each token is bound to the member it belongs to. Tokens never leave our servers and are used only for requests the member has authorized. Access to them is limited to the systems and personnel that need it.

Disconnecting. A member can disconnect at any time from our tool, or by removing our application in their LinkedIn account settings. Disconnecting from our tool revokes the token at LinkedIn and deletes it immediately. Otherwise, a daily check deletes tokens that LinkedIn reports as revoked, tokens that stopped working more than 7 days earlier, and tokens of people who no longer belong to any organization in our tool. In every case, including the end of a contract, we delete the stored tokens within 30 days, together with the LinkedIn profile details and Page links stored with them, unless the law requires us to keep them. To ask us to delete other data, email privacy@allemnii.com.

LinkedIn's terms. We use LinkedIn data in accordance with the LinkedIn API Terms of Use and the LinkedIn Marketing API Program Terms. LinkedIn's own handling of your data is described in LinkedIn's Privacy Policy.

4. Personal data we handle for clients

When we build, operate, or deliver training and consulting for a client, we act as a data processor. The client is the controller: we process personal data only on its documented instructions and only to deliver the contracted service. We do not use that data for our own purposes. Each engagement is governed by the client agreement and a DPA, which prevails over this policy for that engagement.

Depending on the solution, the personal data may include:

• Account identity: name, email address, and authentication identifiers.
• User-generated content: text, files, and other content that end users submit.
• Role and usage data: a user's role in the solution and related operational flags.
• Technical data: transient authentication tokens, and IP address and user-agent captured in platform logs.

We process only what the engagement requires. We do not process employee identifiers or profile individuals unless the client's documented requirements call for it.

Individual requests. If you want to access, correct, export, or delete personal data in a solution a client operates, contact that client. If a request reaches us directly, we pass it to the relevant client promptly and help the client fulfil it on its instruction.

5. Service providers, AI model providers, and data location

Service providers. We use third parties to help us operate, and they act under written terms no less protective than those we owe our clients. They are mainly cloud infrastructure and productivity providers, such as Google Cloud and Google Workspace. Our own tools also use Resend to send invitation and notification emails, which receives the names and email addresses of the people we email, and Tavily for web research, which receives search queries based on post topics. Our tools' web app loads its fonts from Google Fonts, which receives visitors' IP addresses. For client engagements, the current list is maintained in the engagement's DPA, and the client is told of new providers and may object.

AI model providers. Where a solution or tool uses a third-party AI model, we access it through Google Cloud's Vertex AI, which acts as our service provider and, for client engagements, is listed in the DPA. The enterprise terms that apply include commitments that customer data is not used to train the models.

Advertising and analytics. We do not use advertising or analytics providers.

Where data is held. Allemnii is established in Canada, and our personnel may access data from Canada. We host in the United States or Canada. Our own tools store data and run AI processing in Google Cloud's United States regions. For client engagements, the region is agreed with the client. Where processing involves a cross-border transfer, it is carried out under the provider's data processing terms, including standard contractual clauses where they apply, and the client agreement. For client engagements, the data protection law that applies is determined by the client's jurisdiction and the DPA.

6. Retention and deletion

We keep personal data only as long as the purposes in this policy require, then delete or anonymize it.

Client deletion requests. On a validated client instruction, we delete personal data from the live database within 30 days. Platform logs and backups are not edited individually; they expire on their standard schedules, after which the data is gone from them too. On termination of an engagement we delete or return client data as the DPA provides.

7. Security and incident notification

We protect personal data with the controls in our Information Security Policy and Security & Support Documentation:

• Encryption in transit (TLS 1.2 or higher) and at rest.
• Individual-identity authentication, with access limited to authorized accounts.
• Least-privilege access to production systems, limited to the people working on the project.
• Logging of administrative activity on our cloud infrastructure.

Incidents are handled under our Incident Response Plan, and availability and recovery under our Business Continuity and Disaster Recovery Plan.

If an incident affects personal data we process for a client, we notify that client without undue delay after confirming it, within the timeframe set in the DPA, and give the information the client needs to meet its own notification duties. If an incident affects personal data we hold as controller and creates a real risk of significant harm, we notify the affected individuals and the Office of the Privacy Commissioner of Canada as the law requires.

8. Your rights

For personal data we hold as controller (Sections 2 and 3), you can ask us to:

• tell you what personal data we hold about you and how we use it;
• correct data that is inaccurate or incomplete;
• delete your data, where we do not need to keep it for a legal or contractual reason;
• stop using your data for a purpose you consented to, by withdrawing consent or unsubscribing.

Email privacy@allemnii.com. We confirm your identity, respond within 30 days, and tell you if we cannot fully meet a request and why. If you are not satisfied, you can raise a complaint with us first, and you can also contact the Office of the Privacy Commissioner of Canada.

For personal data in a solution a client operates, contact that client; Section 4 explains how we handle requests that reach us.

9. Cookies and website technologies

Our website does not use advertising, analytics, or tracking cookies.

If we add analytics or tracking tools, we will update this policy and ask for your consent through a cookie banner first.

10. Changes and contact

We review this policy at least once a year and update it when our practices change, including before we add a new tool or integration that handles personal data in a new way. The effective date at the top shows the latest version.

Questions about engagements should go through the client that operates the solution, as Section 4 explains.