Privacy Policy

This Privacy Policy governs how iCleanGo Inc. collects, uses, discloses, and protects personal information of all Platform users Clients, independent Contractors, Agency owners, and Agency Contractors. This Policy complies with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and addresses the requirements of Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25, S.Q. 2021, c. 25), which applies to operations involving Quebec residents. By using the Platform, you consent to our information practices as described.

SECTION 1 WHO WE ARE AND HOW TO REACH US

iCleanGo Inc. is the Privacy Officer responsible for all personal information collected through the Platform. Privacy Officer contact: privacy@icleango.com · icleango.com/privacy · [Mailing Address], Toronto, Ontario. We respond to all privacy inquiries within fifteen (15) business days. Urgent security or breach concerns are escalated within 24 hours.

SECTION 2 APPLICABLE PRIVACY LEGISLATION

iCleanGo's privacy practices are governed by:

(a) Federal: Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5 applies to all commercial activity involving personal information across Canada;

(b) Breach Notification: PIPEDA Breach of Security Safeguards Regulations, SOR/2018-64 mandatory breach notification to individuals and the Office of the Privacy Commissioner within a reasonable time when a breach creates a real risk of significant harm;

(c) Quebec: Act Respecting the Protection of Personal Information in the Private Sector (Law 25, S.Q. 2021, c. 25, as amended) enhanced consent requirements; mandatory Privacy Impact Assessments; rights to data portability and to be forgotten; mandatory automated decision-making disclosure; 72-hour breach notification to the Commission d'accès à l'information du Québec (CAI); enhanced biometric data obligations; stricter cross-border transfer requirements;

(d) Alberta and British Columbia: Personal Information Protection Act (PIPA) substantially similar to PIPEDA. iCleanGo will comply with the applicable provincial legislation where services extend to AB or BC residents;

(e) Anti-Spam: Canada's Anti-Spam Legislation (CASL), S.C. 2010, c. 23 governs all commercial electronic messages sent by iCleanGo, as set out in the separate CASL Compliance Policy.

SECTION 3 INFORMATION WE COLLECT AND WHY

3.1 From Clients

(a) Identity: Full legal name, email, phone number to create and manage your account;

(b) Location: Service address(es) to facilitate Job delivery;

(c) Payment: Payment card details tokenized and held by Stripe (PCI-DSS compliant). iCleanGo retains transaction records including amounts, dates, and last four digits only;

(d) Property Photographs: Photos uploaded for the Photo Documentation System — retained for the period in Section 7;

(e) Service History: All Job Requests, Jobs, cancellations, disputes, and ratings;

(f) Communications: All in-platform messages between Clients and Service Providers or iCleanGo support;

(g) Device and Technical: IP address, device type, OS, app version for security and technical support;

(h) Usage: Platform interaction data collected through cookies and analytics see Section 10.

3.2 From Independent Contractors

(a) Identity: Full legal name, email, phone, date of birth;

(b) Government-Issued ID: Copy of government photo ID for identity verification;

(c) Proof of Address: Documentation confirming Canadian residential address;

(d) Background Check: Criminal background check results;

(e) Insurance: Commercial general liability insurance certificate details;

(f) Banking: Banking details through Stripe for weekly Earnings payouts;

(g) Location: GPS/geolocation data during active Jobs for At-Door Verification, job timing, and photo geotags;

(h) Performance: Completed Jobs, ratings, tier status, earnings history, compliance status;

(i) Platform Content: All photographs uploaded through the Photo Documentation System;

(j) Biometric Data (if activated and separately consented to): Facial geometry data see Section 4.

3.3 From Agencies

(a) Business Identity: Agency legal name, BN, principal contact, registered address;

(b) Business Documents: Proof of valid Canadian business registration;

(c) Insurance and WSIB: Commercial liability certificate and WSIB clearance;

(d) Banking: Agency banking details through Stripe for Agency Earnings;

(e) Agency Contractor Compliance Documents: Background checks, IDs, addresses for each Agency Contractor;

(f) Subscription and Billing: Subscription tier, fees paid, billing history;

(g) Performance and Job Records: All Jobs, Agency Earnings, and Command Centre activity.

SECTION 4 BIOMETRIC DATA SPECIAL PROVISIONS

BIOMETRIC DATA REQUIRES SEPARATE EXPLICIT CONSENT. iCleanGo will never collect biometric data without a separate, standalone consent process that is entirely distinct from acceptance of this Privacy Policy.

4.1 What Biometric Data May Be Collected

If iCleanGo activates optional AI-powered selfie matching at the time of job commencement (for Contractor identity verification), the biometric data collected is: facial geometry data processed in real-time through a third-party provider (e.g., Veriff or Persona). This is the only category of biometric data iCleanGo may collect.

4.2 Separate Explicit Consent Mandatory Before Collection

Before any biometric data is collected, iCleanGo will present a standalone biometric consent screen that clearly states:

(a) that facial geometry data (biometric data) will be processed;
(b) the specific purpose (real-time identity verification at job commencement);
(c) the name of the third-party processor and a link to their privacy policy;
(d) how the data is retained (processed in real-time, not stored by iCleanGo);
(e) the right to withdraw consent.

The Platform will not proceed with biometric collection if the Contractor does not provide this separate consent. Biometric consent is entirely voluntary.

4.3 Purpose Limitation

Biometric data is collected solely for real-time Contractor identity verification at job commencement. It is not used for any other purpose not marketing, research, profiling, or any non-verification purpose.

4.4 Retention Minimal

iCleanGo does not retain biometric data. Facial geometry data is processed in real-time by the third-party provider for identity matching and is not stored on iCleanGo's servers. The third-party provider's retention and deletion practices are governed by their separate privacy policy.

4.5 Quebec Law 25 Biometric Requirements for Quebec Residents

For Contractors who are Quebec residents, the following additional obligations apply under Law 25:

(a) Enterprise Register Notice: At least sixty (60) days before collecting biometric data from Quebec residents, iCleanGo will publish notice in the enterprise register maintained under Quebec's Act Respecting the Legal Publicity of Enterprises;

(b) Privacy Impact Assessment: iCleanGo will conduct, document, and publish a Privacy Impact Assessment (PIA) before deploying any biometric verification system applicable to Quebec residents;

(c) CAI Compliance: iCleanGo's biometric collection and handling will comply with the Commission d'accès à l'information du Québec's guidelines for biometric data;

(d) Rules on Retention and Destruction: iCleanGo will establish and publish rules governing the retention schedule and destruction of biometric data.

4.6 Consent Withdrawal

Contractors may withdraw biometric consent at any time by contacting privacy@icleango.com. Withdrawal will be processed within five (5) business days. Withdrawal may result in Platform access suspension if biometric verification has been designated as a mandatory security requirement, pending alternative verification arrangements.

SECTION 5 HOW WE USE YOUR INFORMATION

5.1 Primary Purposes

(a) Account creation, identity verification, and compliance verification;

(b) Marketplace operations: facilitating connections between Clients and Service Providers; processing Job Requests; managing At-Door Verification;

(c) Payment processing: processing Client payments; calculating and remitting Contractor and Agency Earnings through Stripe;

(d) Photo Documentation System: operating the three-layer photographic record; transmitting Post-Completion photos to Clients; maintaining the evidentiary record for dispute resolution;

(e) Dispute resolution using the Photo Documentation System and all available evidence;

(f) Safety and security: investigating misconduct, theft, and safety incidents;

(g) Customer support: responding to inquiries, appeals, and complaints;

(h) Legal compliance: complying with laws, court orders, and government requests;

(i) Platform improvement: analyzing aggregate usage patterns and developing features.

5.2 Marketing Requires Separate Express Consent Under CASL

With your explicit, separately obtained consent via an unchecked opt-in checkbox at account registration, iCleanGo may send commercial electronic messages about its services, updates, and offers. You may withdraw consent at any time by clicking "Unsubscribe" in any marketing email or by contacting privacy@icleango.com. Withdrawal of marketing consent does not affect transactional messages (Job confirmations, payment receipts, dispute communications), which are necessary for Platform operation and do not require CASL consent.

5.3 Automated Decision-Making Disclosure Required by Law 25

iCleanGo uses automated processes for:

(a) AI-generated pricing (Instant Quotes automated, no human review before generation);

(b) Commission tier calculation based on Job completion and ratings (automated, reviewed by dashboard);

(c) Compliance document expiry alerts and automatic access suspension (automated safety system).

Quebec residents have the right to be informed of any significant decision made solely through automated processing and to request human review of any such decision. To request human review of any automated decision affecting your account, contact support@icleango.com.

SECTION 6 HOW WE SHARE YOUR INFORMATION

6.1 Between Platform Users

(a) Clients: Service address and Digital Checklist shared with confirmed Service Provider upon Job acceptance. Client full contact details not directly shared all communication through in-app messaging;

(b) Service Providers: First name, profile photo (if provided), Platform rating, and verification status visible to Clients;

(c) Post-Completion photographs automatically transmitted to Clients upon upload.

6.2 Third-Party Service Providers

(a) Stripe, Inc. payment processing and earnings remittance;

(b) Background check provider criminal background checks;

(c) Identity verification provider (e.g., Veriff or Persona) government ID and optional biometric verification;

(d) AWS or Google Cloud Platform cloud hosting and data storage;

(e) Brevo CASL-compliant marketing email management;

(f) Analytics providers aggregate, anonymized usage analytics.

iCleanGo does not sell personal information to any third party for commercial purposes ever.

6.3 Cross-Border Transfers

Some third-party providers (including Stripe, AWS, Veriff, and Brevo) may process personal information outside Canada. iCleanGo ensures all cross-border transfers comply with PIPEDA's accountability principle. For Quebec residents, Law 25 requires a Privacy Impact Assessment for transfers to jurisdictions with less privacy protection than Quebec iCleanGo will conduct such assessments as required. Details of cross-border transfer practices: privacy@icleango.com.

6.4 Legal Disclosures

iCleanGo may disclose personal information without consent as required or permitted by law: in response to a valid court order or legal process; to comply with a legal obligation; to protect safety; to investigate fraud; or to enforce legal rights. Where permitted by law, iCleanGo will notify you before disclosing information in response to a legal demand.

SECTION 7 DATA RETENTION

After the applicable retention period, personal information is securely deleted or anonymized. Anonymized aggregate data (from which individuals cannot be identified) may be retained indefinitely.

SECTION 8 SECURITY MEASURES

(a) Encryption in Transit: All data transmitted between devices and the Platform is encrypted using TLS (Transport Layer Security);

(b) Encryption at Rest: Personal information stored on iCleanGo's servers, including compliance documents, is encrypted at rest;

(c) Access Controls: Access to personal information is restricted to authorized personnel. Administrative access requires multi-factor authentication;

(d) Secure Document Storage: Government IDs and background check results are in an encrypted, access-controlled system accessible only to iCleanGo's compliance team;

(e) Payment Security: Payment data processed by Stripe (PCI-DSS compliant). iCleanGo does not store full payment card numbers;

(f) Third-Party Standards: All processors are required to maintain security measures consistent with or exceeding iCleanGo's standards;

(g) Breach Response PIPEDA and Law 25: iCleanGo maintains a data breach response plan. In the event of a breach creating a real risk of significant harm:
(i) affected individuals will be notified without unreasonable delay;
(ii) the Office of the Privacy Commissioner of Canada will be notified;
(iii) for Quebec residents, the Commission d'accès à l'information du Québec will be notified within 72 hours of becoming aware of the breach, as required by Law 25;

(h) Privacy Impact Assessments: iCleanGo conducts PIAs for all new technology systems involving personal information, as required by Law 25 for Quebec-related processing.

SECTION 9 YOUR PRIVACY RIGHTS

9.1 Rights Under PIPEDA and Law 25

(a) Right of Access: Request a copy of personal information iCleanGo holds about you — response within 30 days (PIPEDA) or 30 days (Law 25);

(b) Right to Correction: Request correction of inaccurate or incomplete information;

(c) Right to Withdraw Consent: Withdraw consent at any time, subject to legal and contractual restrictions. Note: withdrawal of consent for information necessary for Platform operation results in Platform access termination;

(d) Right to Data Portability (Law 25 Quebec Residents): Receive your personal information in a structured, commonly used technological format, and request its communication to authorized persons;

(e) Right to Be Forgotten (Law 25 Quebec Residents): Request that iCleanGo cease disseminating personal information, subject to iCleanGo's legal retention obligations;

(f) Right to Human Review of Automated Decisions (Law 25 Quebec Residents): Request human review of any significant decision made solely through automated processing (e.g., account suspension, tier demotion);

(g) Right to Complain: File a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca), or for Quebec residents, the Commission d'accès à l'information du Québec (cai.gouv.qc.ca).

9.2 How to Exercise Rights

Contact: privacy@icleango.com. Provide your full name, account email, and description of the request. Identity verification may be required before processing. iCleanGo will respond within the timeframes required by applicable law.

SECTION 10 COOKIES AND TRACKING

iCleanGo uses cookies and tracking technologies for: Platform functionality and security; session management; and aggregate analytics. Types used: essential cookies (necessary for Platform function cannot be disabled); functional cookies (preference memory); and analytics cookies (aggregate usage). Cookie settings may be managed through browser or device privacy settings. Disabling essential cookies may affect Platform functionality.

SECTION 11 CHILDREN'S PRIVACY

The Platform is not directed at individuals under eighteen (18). iCleanGo does not knowingly collect personal information from anyone under eighteen (18). If you believe iCleanGo has collected information from a person under eighteen (18), contact privacy@icleango.com immediately.

SECTION 12 UPDATES TO THIS POLICY

iCleanGo may update this Policy to reflect changes in practices, technology, or legal requirements. Material changes will be communicated by email to your registered address and through a prominent in-app notification at least thirty (30) days before the effective date. The updated Policy will be posted at icleango.com/privacy. Continued use constitutes acceptance.