Privacy

Privacy Policy

Last updated: August 23, 2026

1. Person in charge of the protection of personal information

The Béluga Platform is operated by Technologies Shelter-Bay inc., located at 900-585 boul. Charest E., Québec (QC) G1K 3J2, Canada.

The person in charge of the protection of personal information is Émile Gauvreau. For any question or request about your personal information: rprp@beluga.quebec.

2. Personal information we collect

2.1 Account information

  • First name, last name and display name
  • Email address and, if you provide one, recovery email address
  • Password (stored in encrypted form by our identity provider)
  • Profile photo, date of birth and phone number (if voluntarily provided)
  • Language, time zone, and display and notification preferences

2.2 User content

  • Files uploaded to Béluga Files and documents created in Béluga Docs
  • Email sent and received through Béluga Mail
  • Messages sent through Béluga Conversations (end-to-end encrypted by default)
  • Calendar events and contacts
  • Audio and video recordings of meetings and their transcripts

Where your data lives

100% of personal information is stored on hardware owned by Technologies Shelter-Bay inc., in Québec. We do not use AWS Canada, GCP Canada or Azure Canada. Daily backups are encrypted on our machines before any transfer, and their off-site copy stays in Québec.

Limited international processing

We are transparent about residual non-Québec dependencies:

  • Stripe (payment processing) — only the payment metadata required to charge a card. Béluga never sees your card number.
  • Mistral API (France — meeting transcription) — a meeting's audio is sent to Mistral AI only when the host turns on recording. This processing is covered by a privacy impact assessment. We are actively working to bring it back to Québec.
  • Cyberimpact (Québec — transactional emails such as password resets).

2.4 Billing data

Billing name and address, subscription history and invoices (with GST/QST). Payment information (credit card) is never stored on our servers; it is processed exclusively by our PCI-DSS-certified payment provider, Stripe.

3. Purposes of collection

  • Creating and managing your user account
  • Providing the Platform's services
  • Managing organizations and their members
  • Sending transactional email (confirmations, invitations, notifications)
  • Sending our newsletter, only if you have opted in (you can unsubscribe at any time, in accordance with Canada's Anti-Spam Legislation)
  • Billing and subscription management
  • Platform security, abuse prevention and anti-bot verification at sign-up
  • Improving the Platform and fixing technical errors
  • Complying with our legal obligations

4. Consent

By creating an account on the Béluga Platform, you consent to the collection and use of your personal information in accordance with this policy. You may withdraw your consent at any time by deleting your account.

5. Sharing of information

Your personal information is never sold to third parties. It may be shared only in the following cases:

5.1 Within your organization

If you are a member of an organization on Béluga, some information (name, professional email) is visible to the other members and administrators of that organization. Your personal email address is never exposed to the other members of the organization. Your organization's administrators also have the capabilities described in section 8.

5.2 Service providers

  • CyberImpact (Canada — Québec) — notification email relay and newsletter: email address, subject and content of notifications.
  • Stripe (United States) — payment processing: email, billing name and address, payment information.
  • Mistral AI (France — EU) — meeting transcription: audio of recorded meetings, at the host's request.
  • hCaptcha / Intuition Machines (United States) — anti-bot verification at sign-up: IP address, browser signals.
  • Element (United Kingdom) — mobile push gateway for Béluga Conversations: message metadata only, never the content (see section 12).
  • OVHcloud (Canada — Québec) — off-site backups: copies encrypted before transfer, keys held by us alone.

The current list of our subprocessors is published on the Subprocessors page.

5.3 Communication outside Québec

Some providers above process information outside Québec: Stripe and hCaptcha (United States), Mistral AI (France) and Element (United Kingdom). Meeting audio is only transmitted to Mistral AI when the host requests a transcription. In accordance with the Act respecting the protection of personal information in the private sector (Law 25), each of these communications has undergone a privacy impact assessment. All other data remains in Québec.

5.4 AI assistant connectors

If you choose to connect an artificial intelligence assistant to your account, the data accessed by that assistant is transmitted to the AI provider you have chosen, under that provider's privacy policy. You control the access scopes granted and can revoke the connection at any time; organization administrators can block these connectors for their entire organization.

5.5 Legal obligation

We may disclose your information if required to do so by law or by order of a court of competent jurisdiction.

6. Data hosting and security

The Platform is hosted on infrastructure we own and operate in Québec — no third-party cloud provider hosts your data. Only backup copies, encrypted before they leave our servers, are kept off-site at OVHcloud in Québec.

  • Encryption of data in transit (TLS 1.2+) and at rest
  • End-to-end encryption enabled by default on Béluga Conversations
  • Authentication delegated to a dedicated identity provider; no tokens kept in the browser
  • Two-factor authentication (TOTP, passkeys) available to everyone and enforceable by an organization
  • Separate, encrypted app passwords for external email clients
  • Brute-force protection and request rate limiting
  • Data isolation between organizations (multi-tenant), covered by automated tests
  • Administrative access restricted to a private network (VPN)
  • Access logs and error monitoring on our own tooling, with no third-party sharing
  • Automatic encrypted backups

7. Data retention

  • Active account: your data is kept for as long as your account is active.
  • Deleted files: files placed in the trash are permanently deleted after 30 days.
  • Meeting recordings: automatically deleted 90 days after the meeting.
  • Account deletion: when you delete your account, your data is erased within 90 days. This delay allows recovery in case of accidental deletion; after it, deletion is permanent.
  • Technical logs: kept for a maximum of 12 months, then deleted automatically.
  • Backups: kept for 30 days, then rotated automatically.
  • Invoices: kept in accordance with applicable tax obligations (6 years).

8. Organizations: what your administrators can access

When you use Béluga within an organization (for example, your employer), that organization's administrators may: view audit logs of administrative actions; apply data loss prevention (DLP) rules that scan the organization's outgoing email and file shares; place a member's data under legal hold during legal proceedings; require two-factor authentication; restrict access by IP address; and export the organization's data. These capabilities apply to organizational data — your personal account is not subject to them.

9. Your rights

Under Law 25, you have the following rights:

  • Right of access: obtain a copy of your personal information
  • Right of rectification: correct inaccurate or incomplete information
  • Right of deletion: request the deletion of your information
  • Right to portability: receive your information in a structured, commonly used technological format — the Platform also offers a built-in export of your data (contacts, calendar, documents, files, email)
  • Right to withdraw consent: withdraw your consent at any time
  • Right to de-indexing: request that the dissemination of your information cease

To exercise any of these rights, contact our person in charge of the protection of personal information at rprp@beluga.quebec. We will respond to your request within 30 days.

10. Minimum age

The Béluga Platform is restricted to persons aged 14 or older. We do not knowingly collect information from persons under 14; any account created in violation of this rule will be deleted.

11. Cookies

The Béluga Platform uses cookies that are strictly necessary for the service to work: authentication tokens and session preferences. We use no advertising tracking cookies and no third-party analytics cookies. The hCaptcha anti-bot service, used only on the sign-up form, may set its own technical cookies.

12. Mobile notifications (Béluga Conversations)

If you use a Matrix-compatible mobile application (such as Element X) for Béluga Conversations, push notifications transit through the Element provider's gateway in the United Kingdom. Only metadata passes through it (room and sender identifiers, counters) — never message content, which is also end-to-end encrypted. We plan to replace this gateway with sovereign infrastructure.

13. Confidentiality incidents

In the event of a confidentiality incident presenting a serious risk of injury, we will notify the Commission d'accès à l'information du Québec and the persons concerned as soon as possible, in accordance with Law 25.

14. Changes

We reserve the right to modify this policy. Any change will be published on this page with its update date. In the event of a substantial change, we will inform you by email.

15. Complaints

If you believe your rights have not been respected, you may file a complaint with the Commission d'accès à l'information du Québec: 525, boul. René-Lévesque Est, bureau 2.36, Québec (Québec) G1R 5S9 · 1-888-528-7741 · www.cai.gouv.qc.ca