Privacy Policy

Placera is a personal investment planning tool built for Canadians. This policy explains what personal information is collected, why, where it is stored, and what rights you have over it. Placera does not sell, share, or monetize your personal information.

This policy is published in compliance with the Act Respecting the Protection of Personal Information in the Private Sector (Quebec, RLRQ c P-39.1, as amended by Law 25) and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

The person responsible for the protection of personal information at Placera is the Operator. To reach them:

Email: support@placera.ca

You may contact the Privacy Officer to exercise any of the rights described in this policy, to ask questions, or to file a complaint. We will respond within 30 days.

We collect only the information necessary for the purposes described below.

• Identity and contact — your email address, collected when you create an account with an email and password or sign in with Google (Google also provides your display name).
• Account password — if you create an account with a password, it is stored only as a secure one-way hash by our authentication provider, never in plaintext, and is separate from the passphrase that encrypts your financial data.
• Financial planning data — date of birth, province, annual income, investment account balances, contribution schedules, and plan settings that you enter manually.
• Technical data — session tokens and connection metadata managed by Supabase Auth (IP address, browser type, timestamps).
• Diagnostic data — when the app encounters a fault, limited technical information (the error message, browser and operating system type, the page where the error occurred, and connection metadata including your IP address) is sent to our error-monitoring provider, Sentry. This is used solely to detect and fix problems. We do not record your browsing sessions.
• Support correspondence — if you contact us, your email address, your message, and (when you use the in-app "Contact support" form) a few technical details — your plan status, app language, the page you were on, and your browser type. We never ask for your passphrase, recovery code, or balances.

We do not collect or store payment card numbers — card details are entered directly on Stripe's hosted checkout and never reach our systems. We do not collect social insurance numbers or CRA credentials.

Personal information is collected for the following purposes:

1. Authenticating your identity and maintaining your account.
2. Storing and syncing your investment plan across devices.
3. Calculating projections, contribution room, and goal-planning outputs.
4. Processing subscription payments and managing your trial and paid access.
5. Responding to support requests or rights exercises.

We will not use your personal information for any purpose other than those listed above without obtaining your prior consent.

By creating an account or continuing as a guest, you consent to the collection, use, and retention of your personal information as described in this policy. Consent is obtained at or before the point of collection.

You may withdraw your consent at any time by contacting us at support@placera.ca. Withdrawing consent may prevent us from providing some or all of the service.

When you use Placera without signing in, all data is stored exclusively in your browser's localStorage. Nothing is transmitted to any server. Clearing your browser storage permanently deletes all guest data.

If you enable PIN protection, sensitive fields are encrypted in-browser using AES-256-GCM with a key derived from your PIN via Argon2id. The plaintext is never written to disk.

When you sign in, data is stored in a Supabase-managed Postgres database. Before leaving your browser, sensitive fields (date of birth, income, balances, contribution room) are encrypted with AES-256-GCM using a data-encryption key (DEK) derived from your passphrase via Argon2id. Supabase stores only the wrapped (encrypted) form of the key — Placera cannot read your financial data.

A one-time recovery code is generated at setup. If you lose both your passphrase and recovery code, your encrypted data cannot be recovered by Placera.

Some of your personal information is processed by third-party services outside Quebec and Canada:

• Supabase Inc. (United States) — database infrastructure, authentication, and real-time sync. Database storage uses the AWS ca-central-1 region (Montreal); however, Supabase's support and operational staff are based in the United States and may access metadata in the course of service delivery.
• Google LLC (United States) — OAuth identity provider. Google processes your email address and identity token to authenticate you. Google's privacy policy applies to this processing.
• Functional Software, Inc. (Sentry) (United States) — error and performance monitoring. When the app encounters a fault, diagnostic data (error details, browser and operating system type, the page involved, and connection metadata including your IP address) is transmitted to Sentry. We have disabled the collection of personally identifying request data and we do not use session recording; Sentry is used solely to keep the service reliable.
• MailerSend (operated by MailerLite) — email delivery. When you create an account with email and password or request a password reset, we send a confirmation or reset email through MailerSend. Only your email address and the message content (a verification link) are processed — no financial data is involved.
• Stripe, Inc. (United States) — subscription payments. When you subscribe, your email and a Stripe customer identifier are shared with Stripe, and your card details are entered directly on Stripe's secure (PCI-DSS) checkout — we never see or store your card number. No financial data from your account (balances, income, contribution room) is shared with Stripe.
• Zoho Corporation (Canadian data centres in Toronto and Montreal) — support email and ticketing. When you contact support, your email address, message, and any technical details included are stored in Zoho Mail and Zoho Desk. No financial data from your account is included unless you add it yourself.

Prior to these transfers, a privacy impact assessment (PIA) was conducted as required by s. 17 of the Act. We have determined that these providers apply protections equivalent to Quebec law requirements (such as TLS in transit, encryption at rest, and recognized security certifications). You may request a summary of the PIA by contacting the Privacy Officer.

Under Quebec Law 25, you have the following rights. To exercise any of them, email support@placera.ca with the subject line matching the right you are invoking. We will respond within 30 days.

• Right of access (s. 27) — request a copy of all personal information we hold about you.
• Right of correction (s. 28) — request that inaccurate, incomplete, or ambiguous information be corrected.
• Right of deletion (s. 28.1) — delete your account and all associated personal information at any time, directly and without contacting us, using the Delete account option in the account menu. Deletion is immediate and permanent: your account, financial data, and encryption keys are erased and cannot be recovered. You may also request deletion by email when information is no longer necessary for the purposes for which it was collected, or when you withdraw your consent. Some information may be retained for legal or security purposes.
• Right of portability (s. 27) — request a copy of your personal information in a structured, commonly used technological format (JSON), so you can transfer it to another service.
• Right to withdraw consent — withdraw consent for collection or use at any time. This may result in account closure.

If you believe your rights have been violated, you may file a complaint with the Commission d'accès à l'information du Québec (CAI).

We retain personal information only as long as necessary for its purpose:

• Account and financial data — retained until you delete your account (instantly, via the Delete account option in the account menu) or request deletion. Deleting your account permanently erases your profile, financial data, and encryption keys.
• Session and authentication logs — retained by Supabase for up to 24 hours.
• Subscription billing records — retained for 7 years as required by Quebec tax law.
• Security incident logs — retained for 5 years per breach register requirements.
• Guest data (localStorage) — exists only in your browser; deleted when you clear your storage or use the "Wipe everything" option.

When data is no longer needed, it is permanently deleted or anonymized so that it can no longer be attributed to you.

In the event of a confidentiality incident (breach, unauthorized access, or accidental disclosure) that presents a risk of serious harm to any individual, Placera will:

1. Notify the Commission d'accès à l'information (CAI) without delay.
2. Notify affected individuals as soon as possible, with a description of the incident, the information involved, and steps you can take to protect yourself.
3. Record the incident in our confidentiality incident register.

Note: because sensitive financial data is encrypted client-side and Placera does not hold your plaintext DEK, a server-side breach would expose only encrypted ciphertext.

Placera accepts users aged 14 and older. Users under 14 must obtain verifiable consent from a parent or guardian before using the service and before any collection of personal information. Parents or guardians may contact support@placera.ca to provide consent or to request deletion of a minor's data.

Placera does not use advertising networks, marketing trackers, or behavioural analytics, and we do not record your browsing sessions. The only third-party processing of technical data is error and performance monitoring through Sentry, described under Cross-border transfers above, which is used solely to detect and fix faults. Email delivery (MailerSend) processes your address only to send account emails such as confirmation and password reset — never for advertising or tracking. No cookies are set beyond what Supabase Auth requires for session management.

Material changes will be noted with an updated "Last updated" date at the top of this page. If you are a registered user, we will notify you by email at least 30 days before material changes take effect. Continued use after that date constitutes acceptance of the revised policy.

To exercise your rights, ask questions, or file a privacy complaint, contact the Privacy Officer: support@placera.ca. We will acknowledge your request within 5 business days and respond fully within 30 days.

If you are dissatisfied with our response, you may file a complaint with the Commission d'accès à l'information at cai.gouv.qc.ca.