This policy explains what personal information CoFiles collects, why, who it is shared with, how long it is kept, and how to exercise your rights. It is written in plain language and applies to the website, the application and the public pages of CoFiles, together with the Terms of Use and the tool's addendum.
1. Who is responsible for what
Exode Immigration Canada ("we") provides CoFiles. There are two distinct roles:
- Your account information (you are the professional or a team member using the tool): we are responsible for it.
- The information of a professional's clients and of the people whose documents the professional handles: the professional using the tool is responsible for it; they decide why and how it is collected, how long it is kept and to whom it is disclosed. We act on their behalf (service provider/processor) and do not use it for our own purposes. If you are the person concerned, contact the professional first; we help them respond, and you may also write to us.
2. Information collected
2.1 All tools: the account
Name or business name, e-mail, password (never stored in clear), team role, language, plan and billing history, security logs (IP address and time of sign-in attempts, kept temporarily), history of acceptance of the terms and policy (date, version, language), consent preferences. If you sign in with Google or Facebook: see 2.5.
2.2 By tool: what the professional may place in it
| Tool | Information processed on behalf of the professional |
|---|---|
| CoFiles | Documents uploaded by the professional or their clients, folder and file names, statuses, rejection reasons, retention rules, access log. |
2.3 Payment
Cards are processed by the payment provider (Stripe). We do not keep card numbers; we keep the amount, payment status, transaction identifiers and billing data. For payments a professional collects from their own clients, the professional is the controller. The providers are listed in section 6.
2.4 Technical information
IP address and time on sign-ins and sign-ups to limit abuse (deleted after a short time); log of important actions; visit counters without personal information.
2.5 Sign-in with Google or Facebook
If you choose to sign in with Google or Facebook, we ask that provider only for your name, your e-mail address and an identifier specific to CoFiles, after your authorization. We do not ask for access to your content (e-mails, contacts, posts, photos, calendar or files). This information is used only to create your account, authenticate you and secure access; we do not use it for advertising, we do not sell it, and we disclose it to third parties only where the law requires or with your authorization. CoFiles's use of information received from Google complies with the Google API Services User Data Policy, including its Limited Use requirements. You can unlink this sign-in method in your settings or remove CoFiles in your Google or Facebook settings; to have your data deleted, see the Data deletion page.
3. Why we use it (purposes)
- create and secure your account, authenticate you, prevent abuse;
- operate the tool for the professional (see 2.2);
- bill the subscription and manage payments;
- send you messages necessary for the service (confirmations, password reset, security notices, notices about the terms);
- provide technical support at your request;
- meet our legal obligations and defend our rights.
We do not use information to sell it or to profile you for advertising. We use collected information only for the purposes for which it was collected, unless you consent or the law provides an exception (Private Sector Act, s. 12).
4. Your consent
Your consent must be manifest, free and informed, and given for specific purposes (s. 14 of the Private Sector Act). It is requested separately for each purpose and in plain terms; it is valid only for the time necessary. You may withdraw it at any time. Consent to receive promotional messages is always separate, optional and distinct from accepting the terms (see 14).
5. Cookies and similar technologies
CoFiles sets only the cookies below. No advertising cookie and no third-party audience measurement is used.
| Name | Purpose | Duration | Necessary? |
|---|---|---|---|
drvsid | Keep you signed in, protect forms | browser close | Yes |
drvlang | Remember French or English | 1 year | No (preference) |
drvview | Remember the chosen display (list or thumbnails) | 1 year | No (preference) |
cf_invite_off | Remember that the invitation banner was closed | 1 year | No (preference) |
Tracking, identification, location or profiling technologies. CoFiles uses none. If the tool or the professional enables such a technology, users are informed beforehand and given the means to activate it (s. 8.1); confidentiality settings offered to the public are at the highest level by default (s. 9.1).
6. Disclosure to third parties and subcontractors
We do not sell personal information. We disclose it only:
- to the professional (and their team, per the roles they set) whose client you are;
- to our subcontractors and providers, whom we choose for the safeguards they offer: list below;
- to tools the professional connected themselves (other tools in our range, webhooks, integration API): they are responsible for them;
- to authorities, where the law requires it.
List of subcontractors and providers (kept current and published with this policy):
| Provider | Role | Information sent | Processing location |
|---|---|---|---|
| Host of CoFiles | Hosting of the tool | all | Specified on request |
| Transactional e-mail sending service | Transactional e-mail | e-mail, content | Specified on request |
| Stripe | Payment of the subscription | amount, e-mail, name | Specified on request |
| Google, Facebook | Social sign-in | name, e-mail | Specified on request |
7. Hosting and disclosure outside Québec
We choose providers that offer adequate safeguards; the hosting location is specified on request: write to confidentialite@dossilia.com.
The law provides that, before disclosing personal information outside Québec, a business must assess the privacy-related factors (s. 17). We choose providers that offer adequate safeguards. Some providers in the list above (payment, e-mail, Google or Facebook sign-in) may process information outside Québec or Canada; the information may then be subject to the laws of those places.
8. Retention
The periods below are set per tool; no default period is a legal period.
- Account: while the account is active; then deleted through two-step deletion (30-day grace period, then erasure), except what the law requires us to keep (for example accounting records).
- Information of the professional's clients: for the period the professional chooses in the tool, based on their obligations (profession, professional body, law). Suggested starting value: 5 years, or the value of the selected professional pack's rules; it is only a starting point that the professional sets (per firm and per file type), never a legal period or a requirement of their professional body. At expiry, if the professional enabled automatic destruction: prior notice, ability to freeze destruction (dispute, audit), then destruction.
- After a subscription ends unpaid: read-only; no deletion solely because of non-payment (Terms, section 9).
- Security logs and audit log: kept for the time needed for the security of the service and for our obligations.
- Backups: overwritten on their normal cycle.
- Share links and stored documents: documents uploaded to CoFiles are kept for the period chosen by the professional. If the professional enabled automatic destruction, they are destroyed at expiry, after notice, and share links then stop working. A share link has an expiry date in any case and can be revoked at any time.
When the purposes for which information was collected are fulfilled, it is destroyed or anonymized, subject to retention periods set by law (s. 23 of the Private Sector Act).
9. Security
We take reasonable security measures suited to the sensitivity of the information (s. 10 of the Private Sector Act): secure connection (HTTPS), passwords protected by an irreversible process (hashing), separation of each professional's data, role-based access, protection against form forgery, limited sign-in attempts, activity log. No system is infallible.
The administration console is designed not to display the content of professionals' documents. This does not mean that no technical access to the infrastructure exists (see the addendum).
10. Confidentiality incidents
A confidentiality incident is the unauthorized access to, use of or disclosure of personal information, its loss, or any other breach of its protection (s. 3.6). When we have reason to believe an incident occurred, we take reasonable measures to reduce the risk of injury and prevent recurrence. If the incident presents a risk of serious injury, we will notify, with diligence, the Commission d'accès à l'information and the persons concerned (s. 3.5); for information of which the professional is the controller, we notify them without undue delay so they can meet their own obligations. To report an incident, write to confidentialite@dossilia.com.
11. Your rights
Subject to the exceptions in the law, you may:
- know whether we hold information about you and access it;
- have inaccurate, incomplete or equivocal information corrected;
- withdraw your consent to the use or disclosure of your information;
- request cessation of dissemination or deletion of your information, where the law allows;
- request that your computerized information collected from you be returned in a structured, commonly used technological format (portability);
- learn which technologies are used and the purposes of collection (s. 8).
How: write to the person responsible for the protection of personal information (section 16) or see the Data deletion page. We may ask you to confirm your identity. If you are a professional's client, contact them first.
Time limit: the business must answer in writing within 30 days of receiving the request; silence amounts to a refusal (CAI page on dispute review). A refusal or silence may be taken to the Commission d'accès à l'information within 30 days of the answer or of the expiry of the period (same page).
Complaint: Commission d'accès à l'information du Québec, www.cai.gouv.qc.ca; Office of the Privacy Commissioner of Canada, www.priv.gc.ca.
A request register is kept in the tool, with the 30-day deadline. An erasure request never causes destruction of information the professional must keep under their obligations; they answer you in writing.
12. Minors
- CoFiles is intended for people 18 or older, or professionals. We do not knowingly collect information about minors under 14. If a professional collects such information through the tool, they are responsible for obtaining the consent of the person with parental authority or the guardian (s. 4.1: consent of the holder of parental authority is required, unless the collection is manifestly for the minor's benefit).
13. Recording of online sessions
CoFiles does not record any audio or video session.
14. Promotional messages (CASL / LCAP), separate consent
E-mails, SMS and commercial messages are sent only to people who consented (or whose implied consent is valid), who can identify and reach the sender, and who have a working unsubscribe mechanism (CRTC page: three requirements: consent, identification and contact information, unsubscribe;). This box is separate from acceptance of the terms and policy, never pre-ticked, and withdrawing it does not limit use of the service. The professional is responsible for the validity of consent from their own recipients.
15. Changes to this policy
We may change it. The date and version appear at the top of the page. For a material change we notify you by e-mail or in the service and may ask you to accept it again. Earlier versions are kept and available on request.
16. PPI Officer and contact
Person responsible for the protection of personal information: Agnes Takoukam, Exode Immigration Canada · E-mail: confidentialite@dossilia.com · Terrebonne (Québec) J7M 2H8
(The law requires that the person with the highest authority exercise this function, which they may delegate in writing, and that their contact details be published on the website: s. 3.1.)
Our rules on retention, destruction, roles and responsibilities are summarized in this policy (sections 1, 8 and 16) and in the Terms of Use (sections 5 and 13). To complain about how we handle personal information, write to confidentialite@dossilia.com; you may also contact the Commission d'accès à l'information du Québec.
See also: Data deletion · Contact us.