TL;DR — The honest version
Privilio is an end-to-end encrypted contact manager. Your contacts, notes, and vault are encrypted on your device with a key derived from a passphrase only you know, then synced across your devices. We store only ciphertext — we cannot read your contacts, and we never receive your passphrase. We don't sell your data and we don't advertise. We comply with valid Canadian legal orders, but all we could ever produce is encrypted bytes that are mathematically useless without your passphrase.
1. Who we are
Privilio is published by Adapting Services Limited, a company incorporated in Ontario, Canada. References to "Privilio", "we", "us", or "our" in this policy refer to Adapting Services Limited. Our principal address is in Ontario, Canada. You can reach us at smartin@adapting-services.ca.
2. What data we collect
The key point: we store only ciphertext. Your contacts, tags, notes, and vault are encrypted on your device with a key derived from your passphrase before they are sent to us. We never receive your passphrase or your unencrypted data, and we cannot decrypt what we store.
Account data
To sync your encrypted data across your devices, we store:
- Your email address or account identifier (used to sign in)
- Authentication data needed to verify it's you — we never store your passphrase in a form we can read
- Sync metadata such as record timestamps and device/sync identifiers
Your encrypted contacts
What we actually hold for sync is the encrypted ciphertext of your contacts, tags, and notes (including anything in your vault). This ciphertext is unreadable without your passphrase, which we never have. We cannot see names, companies, notes, or any other contact content.
Operational data
- IP addresses (retained briefly for security and abuse prevention, then deleted)
- Error logs (no contact content included)
In the app, we do not collect: your unencrypted contacts or notes, device fingerprints, advertising identifiers, location data, or analytics about how you use the app beyond what's stated here. Data collected on this website is described separately below.
This website (privilio.ca)
This section covers visitors to privilio.ca. It does not cover the Privilio app, which is described above.
- Email updates (optional). If you type your email address into the "Get Privilio news by email" form, we receive that address and the time you submitted it. Nothing else is asked. Our website host (Netlify) also records the IP address and browser details sent with a form submission, as part of delivering the form and filtering spam.
- Visit counts (no tracking). We count visits with a small first-party counter that runs on our own website host. It uses no cookies, writes nothing to your browser's storage, and does not use any third-party analytics service. It records only aggregate daily counts: which page was viewed, the website you came from (domain name only), the
utm_sourcetag if a link has one, and how many people submitted the email form. It does not store or hash your IP address or browser details, does not build a profile or identifier for you, does not follow you across sites, and does not fingerprint your device. If your browser sends Do Not Track or Global Privacy Control, or looks like an automated bot, the visit is not counted. - Hosting logs. Like any website, our host (Netlify) handles your IP address and browser details when it serves a page, and may keep standard server logs. We do not use those logs for analytics or advertising.
3. How we use your data
We use the limited data we hold only to:
- Authenticate you and sync your encrypted contacts across your devices
- Operate, secure, and maintain the service
- Respond to support and privacy requests
- Detect and prevent abuse
If you join the email list, we use your email address only to send you Privilio product updates and launch news. We won't use it for anything else, and we won't share or sell it. Every email tells you how to unsubscribe, and you can also write to us at any time at smartin@adapting-services.ca to be removed. We use the aggregate visit counts only to understand how many people visit the site and join the list.
We do not use your data for advertising, profiling, or sale — and because your contacts are encrypted, we couldn't read them for those purposes even if we wanted to.
4. Data sharing
We don't sell, rent, or share your personal information with advertisers or data brokers. The only third parties involved are:
- Netlify — hosts privilio.ca, serves its pages, and stores email-list submissions for us. Our visit counter also runs on Netlify, so no separate analytics company receives your data
- Our hosting/infrastructure provider — stores your encrypted ciphertext and account data on our behalf (they cannot read it either)
- Clerk — our authentication provider, which handles sign-in. Your passphrase and encryption keys are never sent to Clerk
- RevenueCat — manages iOS subscriptions for us. It receives an anonymous app user ID and your purchase status. It does not receive your contacts, your contact data, or your passphrase
- Apple App Store / Google Play — distribute the app and process any purchases under their own policies
- Legal authorities — only when required by valid Canadian legal process (see Section 7)
AI connections (optional, off by default, coming soon)
We are building an optional connector that lets an AI tool you choose look up your contacts. It is coming soon and is not available yet. It is off by default. When it ships, this is how it will work:
- You can create a read-only access token in Settings. It cannot change or delete anything.
- We store tokens only as a hash, so we cannot show a token again after you create it.
- A token on its own only gives access to your encrypted data, which is unreadable without your passphrase.
- A connected AI tool may see whatever contacts you let it retrieve. Once it does, that information is handled under that AI provider's own privacy policy, not ours.
- The connector excludes your Vault.
- You can revoke a token at any time. Tokens are also revoked automatically when you change your passphrase or recover your account.
- We keep an audit log of when a token was used. It records access times, not contact content, and is kept for 90 days.
5. Data retention
- Encrypted contacts, notes & vault: Retained (as ciphertext) until you delete them or close your account.
- Account data: Retained until you delete your account.
- IP logs: Retained briefly for security, then automatically deleted.
- Email-list addresses: Kept until you unsubscribe or ask us to remove you, then deleted from our list.
- Website visit counts: Kept as aggregate daily totals. They contain no personal information.
When you delete your account, your encrypted data is permanently deleted within 30 days. You can also export your data to a JSON file at any time from Settings.
6. Your rights (Canadian and international)
Under PIPEDA (Canada's federal privacy law), applicable provincial laws, and the GDPR (for EEA residents), you have rights to access, correct, delete, and port your personal data. In Privilio's case these rights are largely satisfied by the app itself:
- Access & portability: export all your data to a JSON file from Settings
- Correction: edit any contact directly in the app
- Deletion: delete contacts individually, or wipe everything from the "Danger zone"
- Complaints: you may contact the Office of the Privacy Commissioner of Canada
To exercise any of these rights, contact us at smartin@adapting-services.ca. We aim to respond to privacy requests within 5 business days (and in any case within the 30 days allowed under PIPEDA). Note that because your contacts are end-to-end encrypted, we can act on your account and ciphertext but cannot read or alter the contents ourselves.
7. Law enforcement requests
The honest answer: We comply with valid court orders issued by Canadian courts. But because of our zero-knowledge design, the only data we could ever produce is your account identifier and your encrypted contacts — ciphertext that is mathematically unreadable without your passphrase, which we never receive. If you lose both your passphrase and the one-time recovery code you were given at setup, even you cannot recover your data. This is not a limitation — it is the point.
8. Security
Privilio's security comes from end-to-end encryption — we store only what we can't read. Specifically:
- Your contacts, notes, and vault are encrypted on your device with a key derived from your passphrase, before anything is synced
- Our servers store only ciphertext; your passphrase and encryption keys never reach us
- Vault contacts are additionally locked in the app by a 4-digit PIN you set (changeable or removable in Settings). The PIN is an app-level lock, not a separate layer of encryption: Vault contacts use the same encryption key as everything else
- All data in transit is protected with TLS
- You can export a JSON backup and delete all your data at any time
Keeping your passphrase safe is essential — together with the one-time recovery code you were given at setup, it is the only way to unlock your data, and we cannot reset or recover either one. If you discover a security vulnerability, please report it to smartin@adapting-services.ca — we aim to respond to security reports within 3 business days. See also our Security page.
9. Children
Privilio is not directed to children under 13 (or under 16 in the EEA). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact smartin@adapting-services.ca and we will delete it.
10. Changes to this policy
We may update this policy from time to time. We will post significant changes within the app or on this page at least 30 days before they take effect. Your continued use of Privilio after the effective date constitutes acceptance of the updated policy.
11. Contact
For privacy-related questions or requests:
- Email (privacy, security and general enquiries): smartin@adapting-services.ca
- Company: Adapting Services Limited, Ontario, Canada