PIPEDA compliance and Canadian data residency

Who holds what role

PIPEDA places the accountability on the organisation that collects the information for its own purposes. For a rebate programme that is the brand running the promotion. SondarLogic processes claims on that brand's behalf and under its instructions, which makes us a service provider rather than the accountable organisation.

That distinction decides everything else on this page. We do not decide what a programme collects, we do not use claim data for our own purposes, and we do not carry it from one client to another.

Consent and purpose

A claimant submits a receipt in order to be paid. That is the purpose they consented to, and the submission portal states it at the point of collection in the brand's own words.

Information collected for a claim is used to decide that claim, to pay it, and to report on the programme to the brand. Any wider marketing use of a claimant's contact details is the brand's decision to make, on the brand's own consent language, and not something that happens by default because a claim was processed.

Canadian data residency

Claim records and claimant personal information are stored on servers in Canada, and the platform that decides claims runs in Canada. This is not a preference that can drift. It is how the platform is configured.

One step leaves the country and we would rather say so than have you find it. Reading the text off the receipt is done by a specialist processing provider whose service runs outside Canada. The image is sent, read in the moment, and never stored, by them or by us. PIPEDA allows this and asks that we tell you, which is what this paragraph is for. The name of that provider is in the sub processor list, and we will put the whole thing in Canada for a programme that requires it.

It matters for two reasons. Some brands have a procurement requirement that personal information does not leave the country, and a programme that fails that test is dead before it is evaluated on anything else. And a claimant's information staying in the jurisdiction whose law protects it is simply the right answer.

What we do not do

• We do not sell, rent or trade personal information, in any form, to anyone.
• We do not use one client's claim data to inform another client's programme.
• We do not require a brand to hand over its existing customer or claimant records. Claims come from the claimant.
• We do not receive, hold or transmit money on anyone's behalf. Rewards are funded and released from the client's own account.

Sub processors, retention and access

A small number of vetted sub processors are involved. Hosting and the database are in Canada. Reading the text off a receipt is done by Anthropic, whose service runs outside Canada, in the moment and without storing the image. Reward delivery, where we handle it, is done by a gift card provider drawing on the brand's own account. Each is bound by a written confidentiality agreement, and the full current list with locations is provided to any client who asks for it during onboarding.

Retention is set per programme. Claim records are kept as long as the brand needs them for audit and dispute handling and then disposed of. A claimant who wants to know what is held about them, or wants it corrected or deleted, is directed to the brand as the accountable organisation, and we action the request on the brand's instruction.