Privacy Policy. Plain Language. Full Coverage. No Dark Patterns.

01. Who we are and who this covers

Upearance Inc., d/b/a Deals To Grow (“DTG,” “we”), Montreal, Quebec, Canada. Privacy contact: privacy@dealstogrow.com.

This policy covers three groups differently:

• Website visitors and prospects — you browse dealstogrow.com, use a free tool, or submit a form; we are the “controller” of that data.
• Clients — contractors who engage us; we hold your business and billing information as controller.
• Your customers and leads (homeowners) — when we run a client's CRM, ads, and AI receptionist, we process homeowners' data on the client's behalf, as a service provider/processor. The client owns that data; our handling is governed by the Data Processing Schedule in our Master Services Agreement, not by choices we make ourselves. Homeowners with questions about their data should contact the contractor they dealt with; we'll assist that contractor in responding.

02. What we collect

Forms (availability, contact, qualify, calculators, tools): name, business name, email, phone, city, trade, and whatever you type into free-text fields.

Automatically: IP address, device/browser type, pages visited, referral source — via analytics cookies.

Advertising pixels: Meta Pixel and Google tags for ad attribution and audience measurement.

Calls and messages: if you call our tracking numbers or interact with our (or a client's) AI receptionist, calls may be recorded and transcribed and SMS conversations logged. You'll hear/see a disclosure at the start. Clients are contractually required to comply with call-recording and telemarketing consent laws in their jurisdictions.

Clients: onboarding details, billing information (processed by our payment processor — we don't store full card numbers), account credentials needed to operate your stack, and performance data.

We do not collect sensitive categories (health, biometrics, government IDs) and we don't want them — please don't put them in forms.

03. Why we use it (purposes and legal bases)

• Respond to inquiries and check territory availability (consent / pre-contractual steps).
• Deliver and operate client engagements (contract).
• Billing, accounting, tax (legal obligation).
• Measure and improve the site and our ads (consent for cookies/pixels; legitimate purposes for aggregate analytics).
• Send marketing emails to prospects who asked to hear from us — every email has a working unsubscribe (consent; CASL-compliant for Canada, CAN-SPAM for the US).
• SMS only with prior express consent; reply STOP to opt out at any time (TCPA/CASL).
• Security, fraud prevention, and enforcing our terms (legitimate purposes).

04. What we don't do

We don't sell, lease, or trade personal information. Ever. We don't share it with data brokers. Pixels are used for our own ad measurement and audiences — not to monetize your data. We don't use your information for automated decisions with legal effects.

05. Who gets access

Our team — the operators running the site and client accounts, on a need-to-know basis.

Subprocessors for service delivery, under their own published policies and our contracts: hosting/CDN, CRM platform, email delivery, analytics, ad platforms (Meta, Google), payment processing, call tracking/telephony, AI transcription. Current list available on request at privacy@dealstogrow.com.

Authorities — only if legally compelled, and we'll tell you unless the law forbids it.

06. Where your data lives (cross-border transfers)

We're based in Quebec. Most of our subprocessors store data in the United States. Before transferring personal information outside Quebec, we assess (as Law 25 requires) whether it will receive adequate protection, and we bind subprocessors contractually to protections equivalent to this policy. By using our services you're informed that your information may be communicated outside Quebec/Canada.

07. How long we keep it

• Prospect form data: 24 months after last contact, then deleted or anonymized.
• Client account data: life of the engagement + 7 years for records with legal/tax retention duties.
• Call recordings/transcripts: 12 months unless needed for a dispute.
• Analytics: aggregated/anonymized after 14 months.
• Backups: purge on cycle within 90 days of deletion.

08. Your rights

Wherever you are, email privacy@dealstogrow.com — we respond within 30 days:

• Access a copy of what we hold on you;
• Correct it;
• Delete it (subject to legal retention duties);
• Withdraw consent for marketing at any time;
• Portability — computerized personal information in a structured, commonly used format (Law 25);
• De-indexing/cessation of dissemination where Law 25 applies.

Canada: you may complain to the Commission d'accès à l'information (Quebec) or the Office of the Privacy Commissioner of Canada.

US state residents (e.g., California, Texas, Colorado): where those laws apply to us, you have equivalent access/deletion/correction/opt-out rights and we honor them through the same email; we do not “sell” or “share” personal information as those laws define it, except for ad-measurement cookies you can decline (Section 09). We don't discriminate against you for exercising rights.

09. Cookies

Banner on first visit; analytics and advertising cookies load only per your choice where required. You can also opt out via browser settings, Google Ads Settings, and Meta Ad Preferences. Essential cookies (session, security) always run.

10. Security

Encryption in transit, access controls, least-privilege credentials, MFA on core systems, vendor due diligence. No system is perfect; if a confidentiality incident presents a risk of serious injury, we notify the Commission d'accès à l'information and affected individuals as Law 25 requires, and affected clients without undue delay.

11. Children

Our services are for businesses. We don't knowingly collect information from anyone under 14 (Quebec threshold); if you believe we have, tell us and we'll delete it.

12. Privacy Officer

The person in charge of the protection of personal information at DTG: Karim Tawfic, Privacy Officer · privacy@dealstogrow.com · Deals To Grow, Montreal, QC.

13. Changes

We post updates here with a new Doc ID and effective date. Material changes get a site notice; clients get an email.

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Last updated: [PUBLISH DATE] · Doc ID: DTG-PRIV-V5 · Built in Montreal, QC