Effective 9 October 2026
Updated 15 October 2026: we now count page views on the public pages of termsroom.com, without cookies and without identifying anyone. See sections 6 and 10.
Privacy notice
How Termsroom handles personal information, under Quebec’s Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1) as amended by Law 25, PIPEDA and the British Columbia Personal Information Protection Act.
1. The short version
- We collect the minimum needed to run a negotiation: who you are, which rooms you are in, and what you did.
- We do not store your organisation’s documents. They live in your own storage.
- Your actions are logged, and records we issue ourselves, such as the record of a sitting, carry a code identifying the copy and who it went to. This is deliberate and is explained in section 5.
- Where you point a costing at a payroll file, we read it and do not keep it. Section 5A is about that, and it is the section to read if you are an employee or a member rather than a user.
- We do not sell personal information, and we do not use it to train models.
2. Who is responsible for what
For the personal information of your people inside a negotiation, your organisation is the controlling party and we act on its instructions as a service provider, under a written agreement that protects the confidentiality of the information. For the information we need to run our own business, meaning your contact details, billing records and support conversations, we are responsible ourselves.
Subscriptions are sold through Paddle, which acts as merchant of record. Paddle is responsible for the payment, invoicing and sales tax information it collects from you under its own terms and its own privacy notice (available in English only at paddle.com).
3. What we collect
| Category | Examples | Why |
|---|---|---|
| Identity | Name, job title, organisation, phone number | To create your account and attribute actions |
| Authentication | Phone number, one-time verification codes | To sign you in securely |
| Activity | Rooms joined, versions tabled, risks raised, documents opened, browser | To keep the audit record both parties rely on |
| Network address | Held by our hosting and database providers in their own request logs, not written into our audit record | To operate and secure the service |
| Content you type | Risk titles, mitigations, comments | Because it is the product |
| Distribution register | Who was sent which version, when they first opened it, when they acknowledged it | To keep the record of what each side was given |
| Document structure | Clause numbers, their depth and order, a hash of each clause, and what changed between two versions. Not the wording of any clause | To record what changed between two versions. Depending on the comparison, Termsroom either reads the text of the versions in server memory or works from the clause index already on record. Either way, only the findings are kept, never the text |
| Storage pointers and fingerprints | The location of a file in your own storage, its SHA-256, its size and its type | To find a document you tabled, and to prove it has not changed since |
| Roster facts, not the roster | Where a payroll file sits in your storage, its SHA-256 and the number of rows in it. Never the file, and never any row of it | To cost an offer against a real population. Section 5A |
| Grievance records | The reference the parties use for a case, the articles relied on, the remedy sought, and the dated events in it. The person grieving is held as a reference the two sides agree, such as an employee number, and never as a name | To run the steps and the deadlines both sides are held to |
| Your own working material | Your mandate and its limits, your costing assumptions and cost lines, your risks. Held for your organisation alone and never disclosed to the other party | Because it is the product, and because it is the half of it that must stay sealed |
| Credentials you give us | For S3 compatible storage, the access key and secret you supply, held encrypted while the connection is active. For a Teams channel, the notification address. For SharePoint, no credential at all | To read and write in the storage you connected |
| Billing | Billing contact name and email, subscription and invoice records | To sell and renew a subscription, through Paddle as merchant of record |
We do not keep document content, and we do not hold card numbers. Indexing a version or comparing every version reads the text in server memory only; the quick comparison with the previous version works from the clause index already on record and reads no file. Either way, nothing about the text is stored beyond the structure and findings described above. There is no column in our database that is permitted to hold the content of a document, and an attempt to add one fails. See termsroom.com/trust for the full inventory of what is stored, column by column.
3A. If you write to us before you are a customer
Two forms on this site can be used by somebody with no account: the request for a quotation on the purchasing page, and the request for our evidence pack on the trust page. Both record what you typed, and this notice did not previously say so. It does now.
Each records your name, the organisation you are asking for, an email address and, if you give one, a telephone number and your role. It records what you asked for, and anything you wrote in the free-text box. It does not record your network address; that sits in our providers’ request logs, on the same footing as every other page you visit here.
We use it to reply to you, and we count what was asked for so we know what buyers and reviewers actually gate on. We do not use it for anything else, we do not add you to a mailing list, and we do not sell or share it. Nobody signed in to Termsroom can read it: every access policy on both tables is a plain refusal, and a standing assertion runs daily against our production database asserting that this is still true.
A request sits with us for two years unless you ask us to remove it sooner, which you may do at any time by quoting the reference you were given. Nothing deletes these on a schedule today, and section 7 says so rather than implying a job that does not exist.
4. Why we may collect it
To provide the service you or your organisation asked for; to keep the service secure and detect misuse; to keep records we or you are required to keep; and to comply with law. We rely on your organisation’s agreement with us, and on your consent where consent is required.
Where we rely on consent, it must be clear, free and informed, given for specific purposes, and asked for separately for each of those purposes. You may withdraw it at any time.
5. Logging and the distribution record (please read this one)
Termsroom records who did what. It also records who was sent which version of a document, when they first opened it, and when they acknowledged receiving it. Records that Termsroom itself produces, such as the record of a sitting, carry a code identifying that copy and the person it was issued to.
This is monitoring of identifiable individuals, and we would rather you heard it from us plainly. It exists because both sides of a negotiation need to trust that confidential material is traceable, not because we are interested in what any individual is doing. The record is available to your own organisation and to the other party where it concerns shared material; it is not used for any other purpose.
Under Quebec law, the distribution record and the per-recipient code are technological means that allow a person to be identified. We are telling you about them here, before they are used, and section 8 explains how to exercise your rights.
What we do not do. Termsroom does not hold your documents, so it does not stamp them and cannot trace a leaked page of one back to a recipient. Per-recipient watermarking of documents is on the roadmap at termsroom.com/trust and is not in the product today. If it ships, this notice will say so before it is switched on.
5A. Payroll rosters, and the people who are in one
This section is for a different reader from the rest of this notice. If you are an employee or a member whose pay appears in a file your employer or your union used to cost an offer, you are not a Termsroom user, you never agreed to anything with us, and you should still be told what happens to that file.
What happens. The organisation points Termsroom at a payroll file sitting in its own storage. Our software opens it once, computes a fingerprint of it, counts how many rows it has, and reads one column of earnings figures in order to run each person against the annual contribution ceilings that Canadian statutory deductions impose. It then discards everything it read.
What is kept. Where the file sits, its fingerprint, the number of rows, and the resulting totals for the whole group: headcount, payroll before and after, and statutory cost before and after. No row, no name, no individual figure and no identifier is retained, and no column other than the single earnings column is parsed at all.
Who is responsible. The organisation that pointed us at the file is the controlling party for it. It decided what to put in the file and whether it was entitled to use it that way. We act on its instruction, and we are responsible for handling it as described here and for nothing wider.
Why we do it this way. An accurate costing needs the shape of a real population, because statutory ceilings apply per person and a total divided by a headcount gives the wrong answer. It does not need the population itself to be uploaded to us, so it is not.
If you believe a file about you has been used this way and you want to know more, the request goes to your employer or your union, because it is their file and their instruction. Section 8 explains why, and we will help them answer it.
6. Who we share it with
| Who | What they get | Where |
|---|---|---|
| The other party in your negotiation | Your name and role in the shared room, and what you tabled there. Never your private room. | n/a |
| The other party’s own storage | A version you tabled at the shared table, where you instruct us to place a copy of it there. Only what you tabled, and only on your instruction | Their tenant |
| Supabase | The record: accounts, membership, findings, audit trail | Canada |
| Vercel | Requests in transit, with no persistent storage; and page-view counts for the public pages of termsroom.com, with no cookies and nothing that identifies a visitor | Requests served from the region nearest the caller, which may be outside Canada |
| Twilio | Your phone number, to send a sign-in verification code and, where you are invited by text message, the invitation and its reminders: a reference and a link, never a document | United States |
| Resend | Your email address, to send the first of the two sign-in codes. Where you are invited by email, your email address, your name and a link, to send the invitation and its reminders; never a document. Where you send a request or a partner application through a form on the website, the details you enter, to deliver it to us and send you a confirmation | United States |
| Paddle, payments and merchant of record | Billing contact, payment and tax details | As per Paddle’s own terms |
| Microsoft | Your own tenant, which your documents never leave | Your tenant |
Disclosure outside Quebec: before we disclose personal information outside Quebec (Twilio and Resend in the United States, Paddle in the United Kingdom and the European Union), we carry out a privacy impact assessment and sign a written agreement that ensures adequate protection. Your phone number is processed in the United States by Twilio, for sign-in codes and for invitations and reminders sent by text message, and may be accessible to US authorities under US law. Your email address is processed in the United States by Resend for sign-in codes and for invitations and reminders sent by email. Billing and tax information is processed by Paddle in the locations set out in its own terms, which may be outside Canada. Requests may be served by Vercel from a region outside Canada, without being stored there; the page-view counts for the public pages are kept by Vercel and may be outside Canada. The record is held in Canada, and your documents stay in your own storage. Text messages, emails and payments are processed by their providers (Twilio, Resend and Paddle), as set out above. If your organisation cannot accept that, tell us before you sign. We are assessing a Canadian alternative for phone verification.
We do not sell personal information to anyone, in any circumstances.
7. How long we keep it
Each entry says whether it happens on its own or only when somebody asks. We would rather publish that distinction than let you assume a scheduler exists that does not. A job runs daily against these periods and records what is due; the entries marked as counted are ones it can see but is not yet permitted to act on, and we would rather say that than describe a deletion that has not happened.
- Storage credentials: deleted from the vault at the moment you disconnect the connection, in the same transaction. Automatic today. A retired connection that still pointed at a credential would be reported by our own
tr_orphaned_credentialscheck, which runs on every change to the database. - Channel addresses: a Teams webhook address is deleted when you unlink the channel, on the same basis. Automatic today.
- Account information: while your account is active, then 90 days, after which it is destroyed or anonymised. Applied on request. For now, that destruction happens when your organisation asks for it. This page previously said it would become automatic from 31 January 2027. That commitment is withdrawn rather than quietly missed. Deciding on our own that an account had gone quiet would mean guessing at a bargaining team between rounds, and for a product used on a cycle that is most of the year, so the organisation tells us instead.
- The audit record: for the life of the negotiation plus 7 years, because it is evidence both parties may need. Your organisation can ask for a different period.
- Discussion written in a room: retained and readable by the parties until 90 days after the negotiation is confirmed closed, and purged then. It is working conversation rather than evidence, and the audit record of who acted and when is untouched by it. You can also ask us to purge it sooner, or purge it yourself if you lead a party. Counted daily, not yet deleted automatically. The job that does it runs and records what is due; it is not yet permitted to act, and this page will say so until it is. Ninety days rather than on the day of closure because the closing record is issued at closure and usually read some days later, and a deletion has no undo.
- Roster facts: the pointer, fingerprint and row count live as long as the costing they belong to. The file itself was never kept, so there is nothing else to delete.
- Enquiries from people who are not customers: a request for a quotation or for the evidence pack, kept 2 years. Applied on request. Nothing deletes these on a schedule; ask, quoting your reference, and we will remove it. See section 3A.
- Grievance records: kept for the life of the negotiation they belong to, and deleted with it by the database rather than on a schedule of their own. Deleted with the negotiation. Nothing deletes a negotiation on a schedule either, so in practice this takes effect when the negotiation is deleted rather than on a date, and we would rather say so than imply a timer that does not exist. The person grieving is held as a reference the parties agree rather than as a name, so what is deleted here is a case file and not an identity.
- Sign-in attempts: 24 hours. Applied automatically. A one-way hash of the mobile number and the time of each request for a sign-in code, kept only to limit how often a code can be sent or tried. Deleted at the next sign-in attempt after a day. The same applies to email sign-in codes, counted against a one-way hash of the address.
- Email sign-in codes: 10 minutes. Applied automatically. A one-way hash of your email address and of the code, kept until the code is used or expires. The code itself is never stored.
- A confirmed email address waiting for the text code: 15 minutes. Applied automatically. Kept only until you enter the code we text you.
- Sessions that finished both sign-in steps: 60 days. Applied automatically. The session identifier, your account and the time, so that each request can be checked.
- The email address on your account: for as long as the account exists, as part of account information. It is visible to you, and not to other people in your negotiations.
- Support conversations: 2 years. Applied on request. They are held outside this database, so nothing here can count them or delete them.
- Billing records: 7 years, because tax law requires it. Held by our payment processor as merchant of record.
8. Your rights
You may:
- find out what we hold about you and get a copy of it;
- have it corrected;
- withdraw your consent;
- ask us to stop disseminating a piece of information, or to de-index a link that leads to it;
- receive your computerised information in a structured, commonly used technological format (portability);
- be told about any decision based exclusively on automated processing.
You may also complain if you think we have got something wrong. Where your information sits inside your organisation’s negotiation, we will usually direct your request to them, because it is their record.
Contact our Privacy Officer, Raman Kapil, at raman.kapil@markr.ca. We respond within 30 days. If you are not satisfied with our answer you may complain to the Commission d’accès à l’information du Québec, to the Office of the Privacy Commissioner of Canada or, in British Columbia, to the Office of the Information and Privacy Commissioner for British Columbia.
9. Security
Encryption in transit and at rest; access controlled at the database level rather than by application logic; an append-only, tamper-evident audit record; and no storage of your documents at all. The detail, including what we have not yet certified, is at termsroom.com/trust.
You do not have to take the audit record on trust. Your organisation can export its own record and check it on its own machine with a program that never contacts us, published at termsroom.com/verify.mjs. If any entry had been altered or removed, that check fails and names the entry.
We will tell your organisation without undue delay, and within 72 hours of becoming aware, of any confidentiality incident affecting your material. Where an incident presents a risk of serious injury, we will also notify the Commission d’accès à l’information du Québec and the people concerned, and we keep a register of confidentiality incidents. We will report to other regulators where required. We will tell your organisation by telephoning and texting the mobile number your organisation administrator verified when they created the account, and by email to that administrator where we hold an address for them. Termsroom sends email today: invitations and reminders go by text message, email or both.
10. Cookies
We use a session cookie to keep you signed in. We do not use advertising or third-party tracking cookies, and we do not run analytics that identify individuals.
On the public pages of termsroom.com (the pages you can read without signing in), we count page views with Vercel Web Analytics. It sets no cookies. It records the page address, the site that sent you, your country, and your browser and device type. To tell one visit from another it uses a value derived from the request that Vercel discards within 24 hours, so it cannot identify you or follow you across sites. It never runs inside the product, on an invitation link or on a payment page, and it never sees anything about a negotiation.
11. Children
Termsroom is a business product and is not directed at anyone under 18.
12. Changes
We will post changes here with a new date, and tell your organisation directly if a change is significant.
13. Contact
The person in charge of the protection of personal information is Raman Kapil, Privacy Officer, MarkR Management Inc., Suite 315, 1627 Fort Street, Victoria, British Columbia, Canada.
Email: raman.kapil@markr.ca