Privacy Policy

1. Introduction

This Privacy Policy explains how Sun Cluster Inc. ("Sun Cluster", "we", "our", or "us") collects, uses, discloses, and protects personal information when you visit suncluster.ca (the "Site") or use our software, products, and services (collectively, the "Services").

We are a Canadian software engineering company offering custom software development and productized services for automated trading systems and single-client deployments of a private trading web application. We are not a broker, dealer, or investment adviser, and we do not take custody of client funds. This policy is about privacy, not financial performance.

2. Accountability and Contact

• Sun Cluster Inc.
• Address: 1338 Wellington Street West, Unit 10, Ottawa, Ontario, K1Y 3B7, Canada
• Website: suncluster.ca
• Contact email: contact@suncluster.ca
• We are responsible for personal information under our control and designate a Privacy Officer to handle privacy questions and requests, consistent with PIPEDA’s accountability principle.

3. What We Collect

We collect personal information that you choose to provide and certain information collected automatically when you use the Site or Services.

3.1 Information you provide

• Contact information (such as name, email address, phone number, company name).
• Project and support communications (messages, attachments, and related metadata).
• Account information (such as username and authentication details) if you create an account for a product or private deployment.
• Billing information (such as billing name and address). Payment card details are generally handled by our payment processor and not stored by Sun Cluster.

3.2 Information collected automatically

• Device and log data (IP address, browser type, device identifiers, pages viewed, referring pages, timestamps).
• Cookie and similar technology data (see Section 8).

3.3 Information from third parties

• If you choose to connect third-party services (for example, a broker/exchange API, cloud provider, or analytics tool) we may receive limited data needed to provide the integration, depending on what you authorize with that third party.
• We may receive payment status information from our payment processor (e.g., successful payment or charge failure) for billing and account management.

4. How We Use Personal Information

We use personal information for the following purposes (and only as necessary for those purposes):

• To provide and operate the Site and Services, including responding to inquiries and delivering agreed project deliverables.
• To authenticate users, manage accounts, and provide customer support.
• To process payments, invoices, and subscriptions, and to prevent fraud and misuse.
• To maintain, secure, debug, and improve our Services (including monitoring performance and reliability).
• To communicate with you about service updates, security notices, and administrative messages.
• To comply with legal obligations and enforce our agreements.

We do not use your personal information to provide investment advice or to recommend buying or selling any financial instrument.

5. Consent and Legal Basis

Under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), the knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate or otherwise permitted by law.

We generally obtain consent when you provide information to us, sign up for an account, purchase Services, or configure integrations. For certain optional features (such as non-essential cookies), we provide choices as described in Section 8.

6. How We Disclose Personal Information

We do not sell personal information. We may disclose personal information to the following categories of recipients:

• Service providers that help us operate the Site and Services (e.g., hosting, email delivery, analytics, customer support tooling).
• Payment processors to process transactions and manage subscriptions.
• Professional advisers (lawyers, accountants) where necessary for legitimate business purposes.
• Authorities or other parties where required by law, or to protect our rights, users, and systems.

We only disclose what is reasonably necessary for the intended purpose, and we expect service providers to protect personal information through contractual and security safeguards consistent with PIPEDA’s accountability approach.

7. Cross-Border Processing

Some service providers we use may process or store personal information outside of Canada. The Office of the Privacy Commissioner of Canada has published guidance explaining that organizations remain accountable for personal information transferred to third parties for processing, including across borders.

Where personal information is processed in another jurisdiction, it may be accessible to law enforcement or national security authorities according to the laws of that jurisdiction.

You can contact us to ask where our service providers are located and to request additional information about our safeguards.

8. Cookies and Similar Technologies

We use cookies and similar technologies for essential website operation (for example, security and basic functionality) and, if enabled, for analytics to understand how visitors use the Site. PIPEDA emphasizes meaningful consent for the collection, use, and disclosure of personal information, including in online tracking contexts.

You can manage non-essential cookies through our cookie preferences tool (if available) or through your browser settings. Blocking cookies may affect site functionality.

9. Retention

We retain personal information only as long as necessary to fulfill the purposes described in this policy, to provide the Services, to comply with legal and accounting requirements, and to resolve disputes. When information is no longer needed, we securely delete or anonymize it, consistent with PIPEDA’s limiting retention principle.

10. Safeguards

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. Safeguards may include access controls, encryption in transit where appropriate, least-privilege access, logging, and secure development practices. No system is perfectly secure, and you use the Internet at your own risk.

11. Your Rights and Choices

Depending on your location and applicable law, you may have the right to:

• Request access to the personal information we hold about you.
• Request corrections to inaccurate or incomplete personal information.
• Withdraw consent (subject to legal or contractual restrictions and reasonable notice).
• Request information about our privacy practices and complain if you believe we have not complied with this policy.

To make a request, email contact@suncluster.ca. We may need to verify your identity before fulfilling a request.

12. Children’s Privacy

Our Services are not directed to children under the age of majority in their jurisdiction. We do not knowingly collect personal information from children. If you believe a child has provided us personal information, contact us and we will take appropriate steps to delete it.

13. Third-Party Sites and Services

The Site and Services may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of third parties. Review their policies before providing personal information.

14. Updates to This Policy

We may update this Privacy Policy from time to time. If we make changes, we will post the updated policy on the Site and update the "Last updated" date. Your continued use of the Services after the update takes effect means you accept the updated policy.

15. Contact Us

If you have questions, requests, or complaints about privacy, contact our Privacy Officer at:

Sun Cluster Inc.
1338 Wellington Street West, Unit 10
Ottawa, Ontario, K1Y 3B7, Canada
Email: contact@suncluster.ca