Privacy policy

1. General Information, Scope & Effective Date

SettleShift is a business name of 2007192 Ontario Inc., 336 Rideau Street, Ottawa, Ontario K1N 5Y5, Canada ("SettleShift", "we", "us", or "our") operates the settleshift.ca website and the SettleShift applications (Delivery & Cash, Time & Attendance, and the Tenant Admin platform).

This Privacy Policy outlines our data governance practices to ensure compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including Quebec Law 25.

2. SettleShift as a Service Provider (Data Controller vs. Processor)

SettleShift operates strictly as a Service Provider (Data Processor) with respect to the operational information, employee profiles, timecards, and driver records entered into our platform by our commercial customers (Employers).

The Customer acts as the Data Controller. The Customer retains sole legal custody and control of the data they process through SettleShift and is exclusively responsible for establishing the legal basis for collection, obtaining necessary employee consents, and responding to employee data inquiries.

For information collected directly from website visitors, account administrators, and billing contacts, SettleShift acts as the Data Controller.

3. Personal Information We Collect

• Customer Account Information: Administrator names, business email addresses, role assignments, securely hashed passwords, and authentication logs.
• Billing & Subscription Data: Subscription plans, invoice history, and payment status. Credit card details are securely processed directly by Stripe and are never transmitted to or stored on SettleShift servers.
• Operational Data Processed on Behalf of Customers: Delivery & Cash records (driver names, phone numbers, pay rates, shift assignments) and Time & Attendance records (employee names, PINs securely hashed, punch times, break intervals, correction audit logs, and photographs taken at punches or the recorded reason why no photograph was taken).
• Device & Telemetry Data: IP addresses, browser specifications, paired device designations, and access timestamps necessary for platform security and session management.
• Website Visitors & Trackers: SettleShift utilizes zero tracking cookies, advertising pixels, or third-party marketing analytics on its public website.

4. Time Kiosk Visual Verification & Biometric Disclaimer

The Time & Attendance application captures static photographs of personnel exclusively for visual shift-verification by authorized management personnel.

SettleShift explicitly warrants that it does not utilize facial recognition software, nor does it extract, process, or store biometric templates, facial geometry, or algorithmic measurements from these photographs.

SettleShift provides Tenant Owners with an exclusive administrative toggle to exempt individual personnel from photographic capture to facilitate Customer compliance with statutory workplace accommodation obligations.

5. Purpose of Collection and Processing

• To provide, maintain, and deliver the SettleShift SaaS platform and associated functionalities.
• To calculate operational metrics (settlements, hours, and pay) strictly as configured by the Customer.
• To administer account provisioning, billing, and technical support.
• To secure the platform against unauthorized access, investigate misuse, and maintain immutable audit logs.
• To send service messages required for the operation of the account (invitations, password resets, retention reminders). Product-update emails are sent only if the recipient has given separate, optional consent (the consent box is unticked by default).
• To fulfill our statutory and regulatory compliance obligations.

We do not sell personal information, use it for advertising, build marketing profiles, or make automated decisions about individuals.

6. Consent to Data Processing

Where SettleShift acts as a Data Processor, the Customer (as Data Controller) is solely responsible for establishing a valid legal basis for the collection and processing of personal information relating to its employees, drivers, and other individuals, including obtaining any required consents or providing any required notices under applicable employment and privacy legislation.

Where SettleShift acts as a Data Controller (website visitors, trial requests, account administrators, and billing contacts), we collect and process personal information on the following bases:

• Performance of a contract or steps taken at the request of the individual prior to entering a contract (account creation, trial requests, billing, and essential service communications).
• Compliance with legal obligations (tax, accounting, and regulatory record-keeping).
• Legitimate interests pursued by SettleShift in operating, securing, and improving the platform, provided those interests are not overridden by the individual’s rights.
• Consent, where required or appropriate. In particular, we send optional product-update and marketing emails only after the individual has given separate, express consent (the consent box is unticked by default). Consent may be withdrawn at any time as easily as it was given by contacting the Privacy Officer or using the unsubscribe mechanism provided in each message.

Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal, nor does it affect processing that is necessary for the performance of the contract or compliance with legal obligations.

7. Disclosure, Sub-Processors & Cross-Border Transfers

Customer records, photographic data, and active databases are physically hosted on servers located within Canada. We engage the following specialized third-party sub-processors to facilitate platform delivery. Some of these sub-processors may transmit or process network data in the United States:

• Vercel: Application frontend hosting and delivery.
• Cloudflare: Secure network routing, DNS management, and email forwarding.
• Resend: Transactional email delivery.
• Stripe: Payment processing and subscription management.
• Microsoft OneDrive: Secure, encrypted off-site backup storage.
• Google: Corporate mailbox infrastructure.

All sub-processors are bound by strict data processing agreements. Backup archives exported to third-party storage are symmetrically encrypted at rest prior to leaving SettleShift infrastructure.

8. Data Retention, Archival & Automatic Purging

• Timecard Photographs: Automatically purged 90 days after capture.
• Active Operational Records: Maintained for the duration of the active subscription.
• Closed Accounts: Accounts are classified as closed upon explicit cancellation, the conclusion of an unconverted trial, or after 30 days of suspension for non-payment. Closed accounts enter a 90-day export window, after which the tenant, its operational data, photographs, and associated audit records are permanently and irrevocably deleted.
• Encrypted Backups: Subject to a 90-day rolling deletion schedule. Purged production data expires from all backup archives within 90 days of platform deletion.
• SettleShift Billing & Tax Records: Subscriptions, invoices, and platform payment records are retained for 6 years to comply with Canada Revenue Agency (CRA) requirements.
• Trial Requests: Automatically purged 24 months after receipt.
• Security Incident Logs: Retained for 5 years.

We send reminder emails to the Owner when access ends, when 60 days remain, when 30 days remain, and a final notice when 5 days remain in the export window.

A legal hold (set by Super Admin with a required reason) pauses deletion for as long as the hold remains in place.

9. Security Safeguards & Access Controls

• All data in transit is secured using Transport Layer Security (TLS/HTTPS).
• Timecard photographs and backup archives are encrypted at rest.
• Administrative passwords and employee PINs are cryptographically hashed; plain-text credentials are never stored.
• Data architecture enforces strict logical isolation (tenant separation) to prevent cross-customer data exposure.
• SettleShift platform administrators are technologically and administratively prohibited from viewing or downloading Customer operational records, employee hours, or photographs.

10. Confidentiality Incidents and Breach Notification

SettleShift maintains a comprehensive incident response protocol and confidentiality incident register. In the event of a security breach creating a real risk of significant harm (PIPEDA) or risk of serious injury (Law 25), SettleShift will promptly notify the affected Customers, the Office of the Privacy Commissioner of Canada, and any other applicable provincial regulatory authorities as required by law.

11. Data Subject Rights, Access & Correction

Data Subjects possess the right to access, correct, port (in CSV/JSON format), or request the deletion of their personal information.

Where consent is the basis for processing, individuals may withdraw that consent as easily as it was given by contacting the Privacy Officer.

Because SettleShift operates as a Data Processor for workplace records, all employees or contractors of a Customer must direct their privacy requests directly to their Employer (the Customer). SettleShift is contractually prohibited from bypassing the Customer to fulfill such requests but will assist the Customer in executing their statutory duties.

For data where SettleShift acts as the Data Controller (e.g., website visitors, account owners), individuals may submit requests directly to our Privacy Officer. SettleShift will process all direct requests within 30 days.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada. Once we begin serving customers in Quebec, you may also contact the Commission d’accès à l’information du Québec.

12. Modifications to this Privacy Notice

SettleShift reserves the right to modify this Privacy Policy. Material changes will be communicated to the designated account administrator via email no less than 30 days prior to their effective date. Continued use of the platform following the effective date constitutes acceptance of the revised policy.

13. Privacy Officer Contact Information

All privacy-related inquiries, data access requests, or regulatory communications should be directed to the SettleShift Privacy Officer, hello@settleshift.ca.