Mynos Privacy Policy

This Privacy Policy explains how Fincanada Financial Services Ltd, referred to as “Fincanada,” “we,” “us,” or “our,” collects, uses, discloses, protects and retains personal information in connection with Mynos.

This policy applies to:

the Mynos desktop application;
the Mynos website;
Mynos accounts and subscriptions;
customer support;
billing and payment administration; and
related services operated by Fincanada.

This policy distinguishes between:

information stored locally by Mynos on a user’s device; and
information provided to or collected by Fincanada through our website, account, subscription and support services.

1. Our privacy commitment

Fincanada is committed to handling personal information responsibly and in accordance with applicable Canadian privacy laws.

We seek to:

collect only information reasonably required for identified purposes;
explain how information will be used;
use appropriate safeguards;
limit access to authorized persons;
retain information only as long as reasonably necessary;
provide an appropriate process for access and correction requests; and
respond appropriately to privacy questions, complaints and security incidents.

2. Privacy Officer

Fincanada has designated responsibility for privacy compliance to its Privacy Officer.

Questions, requests and complaints may be directed to:

Privacy Officer
Fincanada Financial Services Ltd
British Columbia, Canada
Email: privacy@fincanada.ca

3. Client information stored locally in Mynos

Mynos is designed primarily as a local desktop application.

Information entered into the Mynos client vault may include:

client names and contact information;
preferred names and business information;
family and relationship information;
financial information;
insurance and investment information;
existing coverage;
beneficiaries;
client needs and objectives;
advisor or broker notes;
meeting and interaction records;
client responses;
attachments;
exported records; and
other information entered by the user.

This information is referred to as “Client Record Data.”

Client Record Data is stored locally in an encrypted vault on the user’s device.

Under Mynos’s current architecture:

Client Record Data is not routinely uploaded to Fincanada;
Fincanada does not have routine access to the local client vault;
Fincanada cannot view client notes merely because a user has a Mynos subscription;
cancelling a subscription does not automatically transfer Client Record Data to Fincanada; and
deleting a Mynos account does not necessarily delete data stored locally on a user’s device.

The Mynos user, and where applicable the user’s brokerage, agency, employer or organization, is responsible for determining the lawful basis for entering and retaining Client Record Data.

4. Information Fincanada may collect

4.1 Account information

When a user creates or manages a Mynos account, we may collect:

name;
email address;
account identifier;
authentication information;
account status;
subscription status;
account creation and update dates; and
communications preferences.

We use this information to create and administer accounts, authenticate users, provide subscription features, prevent abuse and communicate about the service.

4.2 Subscription and transaction information

When a user purchases or manages a subscription, we or our payment provider may process:

billing name;
billing email;
billing address where required;
subscription plan;
subscription start, renewal and cancellation dates;
payment status;
transaction identifiers;
payment-provider customer identifiers;
card brand;
partial card details;
card expiry information; and
applicable tax information.

Fincanada does not ordinarily receive or store a user’s complete payment-card number or security code.

4.3 Support and communications

When a user contacts us, we may collect:

name and contact details;
account information;
the contents of the request;
troubleshooting information;
screenshots or files voluntarily provided;
correspondence history; and
information needed to investigate or resolve the request.

Users should not send Client Record Data to support unless it is reasonably necessary and appropriately protected.

Before sharing a screenshot or diagnostic file, users should remove or obscure unnecessary client information.

4.4 Technical and security information

When a user accesses our website, subscription service or account systems, we may collect limited technical information such as:

IP address;
date and time of access;
browser or application version;
operating-system type;
device or installation identifier;
authentication events;
error information;
security events; and
service-request logs.

We may use this information to operate the service, maintain security, investigate errors, prevent fraud and improve reliability.

We do not use local Client Record Data for advertising.

4.5 Website information

Our website may collect information submitted through:

account-registration forms;
contact forms;
subscription forms;
support requests; and
billing-management pages.

The website may also use cookies or similar technologies that are necessary for security, authentication, session management, payment processing or basic website operation.

Any optional analytics or marketing technology should be described in an updated cookie or privacy notice before it is enabled.

5. Purposes for collecting and using personal information

Fincanada may collect and use personal information for the following purposes:

creating and administering Mynos accounts;
authenticating users;
providing subscription functionality;
processing and reconciling payments;
managing renewals, cancellations and account status;
delivering software updates;
responding to support requests;
diagnosing errors;
maintaining security;
detecting fraud, misuse or unauthorized access;
communicating service-related notices;
maintaining transaction and business records;
complying with legal requirements;
enforcing our agreements;
protecting users, Fincanada and third parties; and
improving the reliability and usability of Mynos.

We will not use personal information for an unrelated new purpose without obtaining consent or otherwise having lawful authority.

6. Local AI processing

Mynos may provide optional rewriting features using locally installed third-party software such as Ollama.

When a feature is identified as local:

the selected note text is sent from Mynos to the local AI service operating on the user’s device;
processing is intended to occur on that device;
Fincanada does not receive the note text merely because the local rewriting feature is used; and
the generated result is returned to Mynos for the user to review.

Users are responsible for reviewing the privacy, security and licensing implications of any third-party AI software or model they install.

Users must also ensure that using AI with Client Record Data is permitted by their organization and professional obligations.

Mynos should clearly disclose before introducing any future AI feature that sends Client Record Data to a remote or cloud-based provider.

7. Encrypted backups

Mynos may allow users to create encrypted backup files protected by a recovery password.

Backup files are created and controlled by the user.

Fincanada does not ordinarily:

select where a backup is stored;
receive a copy of the backup;
know the recovery password;
have the ability to decrypt the backup; or
guarantee recovery of a lost or damaged backup.

A user may choose to store a backup with a third-party cloud-storage provider. In that case, the cloud provider’s privacy and security practices apply independently.

Users are responsible for securing backup files and recovery passwords.

8. Disclosure of personal information

Fincanada may disclose personal information in the circumstances described below.

8.1 Service providers

We may use service providers to support functions such as:

payment processing;
website or subscription hosting;
email delivery;
security monitoring;
customer support;
software distribution; and
business administration.

Service providers may receive only the information reasonably required to perform their services.

We require service providers to handle personal information in a manner consistent with their contractual and legal obligations.

8.2 Payment processors

Subscription payments may be processed by Stripe or another payment provider.

Payment providers collect and process payment information under their own privacy policies and terms.

8.3 Legal requirements

We may disclose personal information where we reasonably believe disclosure is permitted or required by law, including:

responding to a court order, warrant, subpoena or lawful demand;
investigating fraud or security incidents;
enforcing an agreement;
protecting legal rights;
responding to an emergency; or
cooperating with an authorized regulator or law-enforcement agency.

8.4 Business transactions

Personal information relating to Mynos accounts or business operations may be disclosed as part of a proposed or completed financing, reorganization, merger, acquisition, sale or transfer of all or part of the Mynos business.

Where required, appropriate confidentiality and privacy protections will be used.

A business transaction involving Fincanada does not automatically provide access to encrypted Client Record Data stored solely on users’ devices.

8.5 With consent

We may disclose personal information for another purpose with the individual’s consent or as otherwise permitted by law.

9. No sale of personal information

Fincanada does not sell Client Record Data or account personal information.

We do not use Client Record Data stored in the local Mynos vault for third-party advertising.

10. Cross-border processing

Some service providers, including payment, hosting, email or software-distribution providers, may process personal information outside British Columbia or outside Canada.

When information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, governments or law-enforcement authorities in accordance with applicable law.

Fincanada remains responsible for personal information under its control and uses contractual or other reasonable measures when engaging service providers.

Client Record Data stored only in the local Mynos vault is not transferred to Fincanada’s service providers merely because the user has a Mynos subscription.

Where consent is required, Fincanada will seek consent appropriate to the nature and sensitivity of the information and the reasonable expectations of the individual.

Consent may be provided through:

account registration;
subscription purchase;
acceptance of an in-app notice;
selection of an optional feature;
written or electronic communication; or
another appropriate action.

An individual may withdraw consent, subject to legal, contractual and technical restrictions and reasonable notice.

Withdrawing consent may prevent us from providing certain services.

Service-related processing that is necessary to perform a contract, maintain security, comply with law or administer an existing transaction may continue where permitted.

Mynos users determine what Client Record Data they enter into the local vault.

The user or the organization on whose behalf the user operates is responsible for:

identifying the purposes for collecting client information;
providing required privacy notices;
obtaining meaningful consent where required;
limiting collection to appropriate information;
controlling access;
maintaining accurate records;
responding to client requests;
establishing retention periods; and
securely disposing of information.

Fincanada does not obtain consent directly from an advisor’s clients merely by licensing Mynos to the advisor.

13. Retention

Fincanada retains account, subscription, support, security and transaction information only for as long as reasonably necessary for the identified purpose, including:

providing the service;
maintaining business and tax records;
resolving disputes;
preventing fraud;
meeting legal requirements; and
enforcing agreements.

Retention periods may vary according to the type of information and applicable requirements.

Client Record Data stored locally remains on the user’s device until it is deleted, overwritten, restored or otherwise managed by the user.

Fincanada does not control the user’s local retention schedule.

14. Security safeguards

Fincanada uses administrative, technical and physical safeguards appropriate to the nature and sensitivity of personal information under its control.

Safeguards may include:

access controls;
authentication;
encryption in transit where appropriate;
restricted administrative access;
security logging;
software updates;
contractual confidentiality requirements;
incident-response procedures; and
employee or contractor access restrictions.

Mynos is designed to protect local Client Record Data using encrypted storage and operating-system security mechanisms.

No security measure can eliminate all risk. Users must also secure their devices, accounts, backups and recovery credentials.

15. Security incidents

Fincanada maintains procedures for responding to suspected privacy and security incidents involving personal information under our control.

Where required by applicable law, we will:

assess the incident;
take reasonable containment and remediation steps;
maintain required records;
notify affected individuals;
notify applicable privacy regulators; and
notify other organizations that may reduce the risk of harm.

Users should promptly report suspected account or service security incidents to:

privacy@fincanada.ca

A compromise limited to a user’s own device or local vault may require action by the user or the user’s organization, even where Fincanada’s systems were not involved.

16. Access and correction requests

Individuals may request access to personal information about them that is under Fincanada’s control and may request correction of information that is inaccurate or incomplete.

Requests should be sent to privacy@fincanada.ca.

We may need to verify identity before responding.

Access may be limited where permitted or required by law, including where disclosure would reveal another person’s personal information, confidential commercial information or legally privileged information.

For Client Record Data stored solely in a user’s local Mynos vault, the advisor, brokerage, agency or organization controlling the vault is normally responsible for responding to the client’s request.

Fincanada may not possess or be able to retrieve that locally stored information.

17. Account deletion

A user may request deletion of their Mynos account by contacting support or using an available account-management function.

Subject to legal and operational requirements, account personal information will be deleted, anonymized or scheduled for deletion.

We may retain limited information where reasonably necessary to:

complete transactions;
maintain tax or financial records;
prevent fraud;
establish or defend legal claims;
enforce agreements; or
comply with law.

Deleting a Mynos account does not automatically delete the Mynos application, the local encrypted vault, exported documents or backups stored by the user.

Users must separately delete local data and backup copies where appropriate.

18. Children

Mynos is intended for adult professionals and is not intended for use by children.

We do not knowingly permit individuals under 18 to create Mynos subscription accounts.

Mynos users may record information concerning minors where doing so is lawful and professionally appropriate. The user remains responsible for consent, authority, necessity, safeguards and access rights concerning that information.

19. Commercial electronic messages

We may send service-related messages concerning:

account security;
payments;
subscription status;
software changes;
legal notices;
support requests; and
important operational information.

Where we send promotional electronic messages, we will obtain consent where required and provide an unsubscribe mechanism.

Unsubscribing from promotional messages will not prevent necessary transactional or service communications.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in:

Mynos features;
our data practices;
service providers;
legal requirements;
security practices; or
business operations.

The revised policy will display an updated effective date.

We will provide additional notice or seek consent where required for a material change.

Future cloud synchronization, cloud AI processing or remote storage of Client Record Data will require an updated privacy disclosure before introduction.

21. Complaints

Privacy concerns should first be directed to our Privacy Officer at: