Privacy notice
Effective: [DATE] · Version: 2026-09-25-draft · Privacy officer: [NAME], [email protected], [POSTAL ADDRESS] (Law 25 s.3.1)
1. Who we are
[LEGAL ENTITY NAME] ("Headsupp", "we"), [NEQ / registration number], [address, Québec, Canada]. This notice covers the Headsupp iOS app and headsupp.ai.
2. What we collect and why
| Data | Purpose | Legal basis / consent |
|---|---|---|
| Phone number | Sign-in (one-time code) | Contract |
| Your photo (face) and reference photos | Creating your twin's portrait and animated face | Explicit consent (biometric — Law 25 s.12, LCCJTI s.44) |
| Your voice sample | Creating your twin's voice | Explicit consent (biometric) |
| Call audio and transcripts | Running the call; recaps; what your twin remembers about a caller (only if the caller opts in) | Contract; consent for memory |
| Hashed phone numbers from your contacts | Finding friends who use Headsupp (optional) | Consent; only hashes leave your device |
| Usage and diagnostics | Limits, billing, crash reports | Legitimate interest |
3. Who processes it for us
Supabase (storage, database), Cloudflare (API), Modal (face and voice models), LiveKit (calls), Deepgram (speech recognition), OpenAI (language model: your twin's replies, call recaps and memory notes; memory embeddings), Google (portrait generation), ElevenLabs (fallback voice), Twilio (SMS codes), Sentry (crash reports), Railway (call orchestration). [Counsel: sub-processor list with countries and DPA references — LEG-6.] Data may be processed outside Québec and Canada (Law 25 s.17 assessment on file).
4. How long we keep it
See the retention schedule. Deleting your account removes your twin, photos, voice, transcripts and memories.
5. Your rights
Access and portability (request your data), correction, deletion (delete your account), withdrawal of consent at any time, and a complaint to the Commission d'accès à l'information du Québec or your local authority. Reply within 30 days.
6. Children
Headsupp is for adults 18 and over. We do not knowingly collect data from anyone under 18.
7. Twins of other people
A twin may only be created by the person it depicts. If you believe a twin depicts you without consent, use the takedown form; non-consensual intimate imagery is removed within 48 hours (TAKE IT DOWN Act).
8. Changes
We will notify you in the app before material changes take effect and record the version you accepted.