Effective date: September 24, 2026
Last updated: September 24, 2026

This policy explains how mode40 ltd. (“mode40”, “we”, “us”) handles personal information: what we collect, why, who we share it with, where it is stored, how long we keep it, and the choices you have. We are a Canadian company incorporated under the Canada Business Corporations Act, with our head office in Steinbach, Manitoba. Our software, the Singularity, gives operators a single connected view of their data, decisions and operations. We also provide the consulting and services around it.

In short:

  • We collect the business contact details you give us, and basic information about how people use our website.
  • We use it to answer you, run our business, improve the site, and send marketing you can opt out of at any time.
  • We do not sell personal information for money, and we do not license it to anyone to train AI models.
  • Analytics, marketing, and visitor-identification tools stay off until you choose Accept in our cookie notice.
  • Data our customers put into the Singularity belongs to them. We handle it only to provide the service, under their agreement with us.

We wrote this policy in plain language on purpose. If any part is unclear, or you need it in another format, email privacy@mode40.com and we will help.

1. Who is responsible for your information

mode40 ltd. is responsible for personal information under its control, including information we hand to service providers. Our Privacy Officer is our Vice President, IT and Security, who is accountable for our compliance with this policy and with the privacy laws that apply to us, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for people in Quebec, the Act respecting the protection of personal information in the private sector. You can reach the Privacy Officer at privacy@mode40.com or at the address in Section 18.

2. What this policy covers

This policy applies when you:

  • visit mode40.com or another mode40 website that links to this policy (the “Site”);
  • contact us, request a demo or assessment, subscribe to updates, or register for an event;
  • apply for a job with us;
  • deal with us as a customer, partner, or supplier contact.

It does not govern the operational data our customers load into the Singularity. For that data, the customer decides what is collected and why, and we act as their service provider under a signed agreement. Section 10 explains how that works. If you use the Singularity through your employer, your employer’s own policies apply to that data, and questions about it should go to them.

It also does not cover our own employees and contractors, who are covered by our internal policies.

3. Information we collect

Information you give us

  • Contact and business details: your name, work email, company, and how you heard about us when you fill in our contact form, and any phone number, job title, industry, or country you choose to add or that you include in an email to us.
  • What you tell us: the content of your messages, the questions you ask, and notes from calls and meetings with our team.
  • Event details: registration details and, where relevant, dietary or accessibility needs you choose to share.
  • Job applications: your résumé, work history, references, and anything else you include with an application. Applications come through our contact form or by email.
  • Preferences: your choices about marketing emails and about cookies.

Information collected automatically

When you use the Site, our systems and the service providers named in Section 8 collect technical information: your IP address, browser and device type, operating system, language, the pages you view, how you arrived at the Site, the date and time of each visit, and approximate location derived from your IP address. Some of this is collected with cookies and similar technologies, described in Section 4. Most of it is collected only after you accept optional cookies.

Information from others

We may receive business contact details from event organizers, partners who refer you to us, public professional sources such as company websites and LinkedIn, and business-contact data providers. If you interact with an email we send, our email platform records whether it was opened and which links were clicked. If you have accepted optional cookies, a visitor-identification service may tell us which organization a visit came from (Section 4).

We do not ask for, and ask you not to send us through the Site, sensitive information such as health information, government identification numbers, financial account details, or export-controlled technical data.

4. Cookies and similar technologies

Cookies are small files a website stores in your browser. We and our service providers use them, along with similar technologies such as scripts and pixels, for the purposes below.

Purpose Provider What it does When it runs
Essential mode40, our web host, and Cloudflare Delivers pages securely, protects the Site against attacks, and remembers your cookie choice (a cookie named m40_consent, kept for 12 months). Always
Forms and spam protection HubSpot, Google reCAPTCHA Displays our contact form and checks that a submission comes from a person rather than a bot. HubSpot and Google receive your IP address and browser information when a page with a form loads. reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. On pages with a form, whether or not you accept optional cookies
Fonts Google Fonts Loads the typefaces the Site uses. Google receives your IP address when your browser requests the font files. Always
Analytics Google Analytics, loaded through Google Tag Manager Counts visits and shows which pages are used, so we can improve the Site. Only after you choose Accept
Marketing HubSpot Sets a visitor cookie so that, if you later submit a form, HubSpot can link the submission to earlier visits from the same browser, and measures our emails and campaigns. Only after you choose Accept
Visitor identification Apollo.io Uses your IP address and a cookie to work out which organization a visit likely came from and, where Apollo already holds a matching business profile, who the visitor may be, so our sales team knows which companies are interested. Apollo is a business-contact data provider based in the United States. Only after you choose Accept

We ask before we set any optional cookie. Until you choose Accept in the notice shown on your first visit, Google Analytics, HubSpot tracking, and Apollo do not load. If you choose Decline, or close the notice without choosing, they stay off. We remember your choice for 12 months, and you can change it at any time with the “Cookie settings” link at the bottom of every page. Withdrawing your acceptance stops these tools from loading on your next page view; it does not delete information they already collected, which you can ask us to remove under Section 13.

You can also block or delete cookies in your browser settings, or use Google’s Analytics opt-out add-on. Blocking essential cookies may stop parts of the Site from working. The Site does not currently read Do Not Track or Global Privacy Control browser signals. Because optional tools are off until you accept them, ignoring or declining the notice gives you the same result those signals are designed to give.

5. How we use personal information

  • To respond to your enquiries and requests, and to arrange demos, assessments, and meetings.
  • To prepare proposals and manage our relationships with customers, partners, and suppliers.
  • To understand which organizations are interested in mode40, and to plan sales follow-up.
  • To send updates about mode40, our products, and our events, where the law allows and until you opt out.
  • To run, secure, and improve the Site, including detecting and preventing abuse.
  • To assess job applications and communicate with applicants.
  • To meet our legal, tax, and accounting obligations, and to establish or defend legal claims.

We use personal information only for the purposes we have identified, or for purposes a reasonable person would consider appropriate in the circumstances. If we want to use it for a new purpose, we will tell you and, where required, ask for your consent.

6. Consent

We rely on your consent to collect, use, and share personal information, except where the law allows or requires otherwise. Consent may be express, for example when you tick a box to receive emails or choose Accept in our cookie notice, or implied, for example when you send us your business card and ask us to follow up. Where the law allows, we also collect and use the business contact information of people acting in a business capacity, such as a work email and job title, in order to communicate with them about their work.

You can withdraw your consent at any time, subject to legal or contractual limits, by contacting us or, for cookies, by using the “Cookie settings” link. If you withdraw consent, we may not be able to provide some things you have asked for.

7. AI and automated decisions

We do not make decisions about you on the Site, or in our dealings with you, that are based solely on automated processing and that have legal or similarly significant effects for you. Our team may use AI-assisted tools to help draft, transcribe, and summarize our own work; a person is responsible for every decision about you. We do not sell or license personal information to anyone to train AI models. AI features inside the Singularity are governed by each customer’s agreement with us (Section 10).

8. How we share personal information

We do not sell personal information for money, and we do not rent or trade our contact lists. Some laws define “sale” or “sharing” broadly enough to cover the analytics and visitor-identification tools described in Section 4. Where such a law applies, you can opt out by declining or withdrawing cookie consent. Beyond that, we share personal information only as follows.

  • Service providers that help us run our business, under terms that limit their use of the information to the services they provide to us. They include HubSpot (customer relationship management, forms, and email), Google (analytics, tag management, reCAPTCHA, and fonts), Apollo.io (visitor identification and business-contact data), Microsoft (email, calendars, and document storage), Amazon Web Services (hosting of the Singularity), Cloudflare (delivery and protection of the Site), the provider that hosts the Site, and the agency that maintains it.
  • Professional advisers such as lawyers, accountants, auditors, and insurers, where needed.
  • Business transactions: if we are involved in a financing, merger, acquisition, or sale of all or part of our business, personal information may be disclosed to the other party under confidentiality terms and used only to evaluate and complete that transaction, as Canadian privacy law allows. If the transaction completes, we will tell you if your information becomes subject to a different privacy policy.
  • Legal reasons: where required or permitted by law, such as responding to a court order, a subpoena, or a lawful request from a public authority, or to protect the rights, safety, and property of mode40, our customers, or others.

9. Where information is stored and transferred

We are based in Manitoba. Some members of our team work in the United States, and several of our service providers store or process information in the United States, so personal information we collect through the Site is routinely transferred outside your province and, if you are in Canada, outside Canada. In particular, HubSpot, Google, Apollo.io, and Microsoft process information in the United States, and Cloudflare routes Site traffic through its global network. When information is in another country, it is subject to that country’s laws and may be accessible to its courts, law enforcement, and national security authorities under those laws.

Before we send personal information outside Canada, we consider the sensitivity of the information, the purpose, and the protections the recipient provides, and we use contracts that require our providers to protect it. If you are in Quebec, this includes the assessment the law requires before personal information is communicated outside the province. You can ask us for more information about where your information is held by writing to privacy@mode40.com.

10. Customer data in the Singularity

When an organization uses the Singularity, it controls the data it loads into the platform, including any personal information about its employees and contractors. mode40 processes that data on the customer’s behalf, only to provide and support the service and as set out in the customer’s agreement with us. In particular:

  • Location: the hosting region is chosen for each customer at onboarding. Canadian customer data is hosted in Amazon Web Services’ Canada Central region in Montreal, and United States customer data in a US region. Data does not move across a border unless the customer’s configuration or agreement provides for it.
  • AI features: customer data is not used to train third-party AI models unless the customer has agreed to it in writing.
  • Return and deletion: at the end of an agreement, customer data is returned or deleted as the agreement provides. Your data summarizes those terms.
  • Requests from individuals: if you are an employee or contractor of one of our customers and want to access or correct information about you in the Singularity, contact your organization. We will help them respond.

Security and governance describes how the platform protects customer data.

11. How long we keep information

We keep personal information only as long as we need it for the purposes in this policy, or as long as the law requires. Where we have used personal information to make a decision about you, we keep it long enough for you to ask to see it. As a general guide:

  • Contact and relationship records are kept while we have an active relationship or conversation with you. We review records with no activity for a prolonged period and delete or de-identify the ones we no longer need.
  • If you unsubscribe from marketing emails, we keep a record of your request so that we continue to honour it.
  • Job applications are kept for the hiring process and for up to 12 months afterwards, in case another suitable role opens, unless you ask us to delete yours sooner.
  • Financial and contract records are kept for as long as tax and corporate law require, generally seven years.
  • Google Analytics keeps individual-level data for no more than 14 months. Other analytics, tracking, and visitor-identification data is kept according to the retention settings of those tools, which we review periodically.

12. How we protect information

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit, access limited to the people who need it, multi-factor authentication on our systems, and monitoring. No system is completely secure, so we cannot guarantee that information will never be accessed without authorization.

If a breach of our security safeguards creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as soon as feasible, along with any other regulator or organization the law requires. We keep a record of every breach of our security safeguards for at least 24 months, as the law requires, whether or not it has to be reported.

13. Your rights and choices

You can ask us:

  • whether we hold personal information about you, what it is, how it has been used, and who it has been shared with, including which service providers and any organization outside Canada;
  • to correct information that is inaccurate, incomplete, or out of date, and to tell anyone we shared it with about the correction where that matters;
  • to delete information we no longer need, or to stop using it for marketing;
  • to withdraw a consent you have given;
  • to explain how we handle personal information, or to raise a complaint.

Send requests to privacy@mode40.com. We may ask you to confirm your identity before we act, and we will respond within 30 days. If the law permits an extension and we need one, we will tell you before the 30 days end and explain why. Access is free of charge. If we cannot grant a request in full, for example because the law requires us to keep the information or it would reveal someone else’s personal information, we will explain why in writing and tell you how to challenge our decision. We will not treat you differently for exercising your rights.

  • Canada: if you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner of Canada. Residents of Alberta and British Columbia may also contact their provincial commissioner.
  • Quebec: you may also ask for computerized personal information you gave us in a structured, commonly used technological format, ask us to stop disseminating it or to de-index it where the law provides, and complain to the Commission d’accès à l’information du Québec.
  • United States: most US state privacy laws apply only to businesses above certain revenue or data-volume thresholds, and we do not believe we meet them today. If a state law does apply to you and to us, you have the rights it provides, such as to know, correct, delete, and opt out of the sale or sharing of personal information and of targeted advertising, and you can exercise them by contacting us. You may authorize an agent to make a request for you.
  • European Economic Area, United Kingdom, and Switzerland: we do not target our products or the Site at these regions. If their data protection laws nonetheless apply to how we handle your information, you may also have rights to data portability, to object to processing, and to restrict processing, and you may complain to your local supervisory authority. Where those laws apply, our legal bases are your consent, our legitimate interests in running and marketing a business-to-business company, steps you ask us to take before entering a contract, and compliance with the law.

14. Marketing emails

We send commercial electronic messages in line with Canada’s Anti-Spam Legislation (CASL) and other applicable laws. We send them with your express consent, for example when you tick the box on our contact form, or where the law allows us to rely on implied consent, for example because you have an existing business relationship with us or you have published or given us your business email without saying you do not want unsolicited messages. We keep a record of the consent we rely on.

Every marketing email identifies mode40, includes our mailing address and a way to reach us, and includes an unsubscribe link. We process unsubscribe requests within 10 business days, and usually much sooner. You can also email privacy@mode40.com. We will still send messages you need about an active relationship, such as replies to your requests, meeting confirmations, or notices about an agreement.

15. Children

The Site is for businesses and professionals. It is not directed to children, and we do not knowingly collect personal information from anyone under 16 through it. If you believe a child has given us personal information, contact us and we will delete it.

16. Links to other websites

The Site links to websites and services we do not control, such as partner sites and LinkedIn. Their privacy practices are their own, and we encourage you to read their policies.

17. Changes to this policy

We may update this policy as our practices or the law change. We will post the updated policy on this page with a new “Last updated” date. If we make a significant change to how we use personal information, we will give more prominent notice on the Site and, where required, ask for your consent. Earlier versions are available on request.

18. Contact us

Questions, requests, and complaints can be sent to our Privacy Officer:

Privacy Officer (Vice President, IT and Security)
mode40 ltd.
385 Loewen Blvd
Steinbach, Manitoba R5G 0B3
Canada
privacy@mode40.com