Privacy policy
Custodyne Inc. (“Custodyne”, “we”, “us”, or “our”) provides a platform that documents the Chain of Custody of data-bearing media and produces disposal approvals and certificates of destruction. We treat the personal information entrusted to us as a matter of record integrity and legal defensibility. This policy explains what personal information we collect, why we collect it, how we protect it, and the choices available to you.
1. Who we are and how to reach us
Custodyne is operated by Custodyne Inc., a company with its head office in Langley, British Columbia, Canada. We are responsible for the personal information under our control.
Questions about this policy, or requests concerning your personal information, may be directed to our privacy contact:
- Privacy contact: [ privacy@custodyne.ca — owner to confirm ]
- Mailing address: [ mailing address — owner to confirm ], Langley, BC, Canada
- Privacy officer: [ named individual / role — owner to confirm ]
2. Scope, and the two roles we play
This policy applies to the Custodyne website at custodyne.ca and to the Custodyne platform (together, the “Service”). We handle personal information in two distinct roles, and the role determines who is accountable for it:
- As the accountable organization. For our own business contacts, for the administrators and staff of subscribing organizations who hold Custodyne accounts, and for visitors to our website, we determine the purposes for which personal information is used and are directly accountable for it.
- As a service provider acting for a subscriber. A subscribing organization — typically a Managed Service Provider (a “Subscriber”) — uses the Service to document media that belongs to the Subscriber’s own customers, and to collect approvals from the individuals who sign them (“Signers”). For that information, the Subscriber is the accountable organization, and we process it on the Subscriber’s documented instructions under a data processing addendum [ DPA — owner to confirm ]. Where this policy and that addendum differ for Signer or customer information, the addendum governs.
3. Personal information we collect
3.1 From website visitors
The Custodyne website loads no third-party trackers, no advertising cookies, and no externally hosted fonts or scripts. When you submit the contact or demo-request form, we collect the name, company, work email address, and field-technician count you provide. Our servers keep standard technical logs — including internet protocol (IP) address and browser user-agent — for security and diagnostics.
3.2 From Subscriber staff (account users)
When an individual is given access to a Subscriber’s Custodyne account, we collect their name, work email address, assigned role, their Microsoft Entra ID sign-in identifier, authentication metadata, and a record of the actions they take in the Service (an administrative audit log). Custodyne does not store staff passwords; staff authenticate through their organization’s Microsoft Entra ID.
3.3 Information we process on behalf of a Subscriber
In the course of documenting a media disposal, the Service records the following on the Subscriber’s behalf:
- Signer identity: the first name, last name, and email address the Signer types, together with the Signer’s attestation that the Signer is authorized to approve the disposal.
- Signature evidence: the signature (drawn or typed), a server-side timestamp recorded in Coordinated Universal Time (UTC), the Signer’s IP address, browser user-agent and device information, an explicit electronic-signature consent indicator, and a cryptographic hash of the exact document presented at signing.
- Media and custody records: drive make, model, serial number, and capacity; photographs of the drive and its label; custody-transfer events; and the recorded result of any wipe or destruction.
- Records pulled from a connected professional services automation (PSA) system: where a Subscriber connects its PSA, we retrieve the associated company, site, telephone number, contact name, and email address for the relevant ticket.
4. Why we use personal information
We use personal information to:
- provide, maintain, and secure the Service;
- create and preserve the Chain-of-Custody record and the resulting disposal approvals and certificates of destruction;
- authenticate staff users and administer accounts;
- send transactional email — specifically signature-request and signature-completed messages — in connection with a disposal;
- detect, prevent, and investigate security incidents, fraud, and misuse, and to debug and improve the Service;
- comply with legal and regulatory obligations; and
- where you have consented, send you product and service communications.
We do not sell personal information, we do not use it for third-party advertising, and we do not use Subscriber, Signer, or customer information to train external artificial-intelligence models, except as described for label extraction in section 5.
5. Automated label extraction and cross-border transfer
To reduce manual entry, photographs of a drive label may be transmitted to Anthropic PBC, a provider located in the United States, for the sole purpose of extracting text fields — manufacturer, model, serial number, and capacity — from the label. This is a transfer of personal information outside Canada. The extracted values are proposed to a technician for review; the Service does not make any automated decision that produces legal effects about an individual. Anthropic processes the images under its commercial terms, which provide that inputs are not used to train its models [ owner to confirm Anthropic terms in force ]. A Subscriber that does not wish to use automated extraction may enter label fields manually.
6. Consent and legal basis
We handle personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. We rely on consent and on legitimate business purposes appropriate to the sensitivity of the information. For Signer and customer information, the Subscriber is the accountable organization and is responsible for obtaining any consent required before that information is entered into the Service. Where other privacy laws apply to a Subscriber or its customers, we will support the Subscriber’s compliance as agreed in the applicable addendum.
7. Service providers and disclosure
We share personal information only as needed to operate the Service, and with providers bound to protect it:
- Cloud hosting and storage: Microsoft Azure, in the Canada Central region [ owner to confirm region and provider ].
- Authentication: Microsoft Entra ID.
- Label extraction: Anthropic PBC (United States), as described in section 5.
- Transactional email delivery: [ SMTP provider — owner to confirm ].
- Connected PSA: a Subscriber’s own professional services automation system, at the Subscriber’s direction.
We may also disclose personal information where required to comply with applicable law, a subpoena, or other lawful request; to enforce our agreements; to protect the rights, safety, and property of Custodyne, our Subscribers, or others; and in connection with a merger, acquisition, financing, or sale of assets, subject to this policy.
8. Where your information is stored
Personal information in the Service is stored primarily in Canada. Two flows may cross a border: label extraction, which is processed in the United States (section 5), and [ any other cross-border flow — owner to confirm ]. When personal information is located in, or accessible from, another country, it may be subject to the laws of that country, including lawful access by its courts and government authorities.
9. How we protect personal information
We apply administrative, technical, and physical safeguards appropriate to the sensitivity of the information. These include:
- encryption of personal information in transit and at rest;
- write-once, immutable (WORM) storage for signed documents and signature evidence, so a completed record cannot be altered or deleted;
- an append-only custody ledger enforced at the database level, so custody events cannot be edited or removed — corrections are recorded as new events;
- strict separation of each Subscriber’s data (tenant isolation), enforced centrally and tested;
- role-based access controls and least-privilege access for staff and administrators;
- single sign-on through Microsoft Entra ID, with no local passwords stored by Custodyne;
- cryptographic hashing (SHA-256) of documents and stored files to detect any tampering;
- rate limiting on signing and authentication endpoints, and validation of uploaded files; and
- audit logging of administrative and configuration changes.
No method of transmission or storage is perfectly secure. While we work to protect personal information, we cannot guarantee absolute security. This section describes safeguards designed into the Service; it does not assert any third-party certification or attestation.
10. How long we keep personal information
Because the purpose of a Chain-of-Custody record is to remain defensible over time, records and legal artifacts are retained for a period configured by the Subscriber, with a default of seven (7) years. Signature evidence and certificates of destruction are retained for that configured period. Information collected through the website, such as demo-request messages, is kept only as long as needed for the purpose for which it was provided and is then deleted. On termination of a Subscriber’s account, information is handled as set out in the applicable agreement or data processing addendum.
11. Your privacy rights
Subject to applicable law and to reasonable limits, you may:
- ask whether we hold personal information about you, and request access to it;
- request correction of inaccurate or incomplete information;
- withdraw consent to a use of your personal information, subject to legal and contractual restrictions and to reasonable notice; and
- make a complaint about our handling of your personal information.
If your information was entered into the Service by a Subscriber — for example, if you are a Signer or a customer of a Subscriber — the Subscriber is the accountable organization, and you should direct your request to that Subscriber. We will assist the Subscriber in responding. To exercise a right, or to complain, contact us at [ privacy contact — owner to confirm ]. You also have the right to complain to the Office of the Privacy Commissioner of Canada.
12. If a breach occurs
If a breach of security safeguards involving personal information under our control creates a real risk of significant harm to an individual, we will notify affected individuals and report to the Office of the Privacy Commissioner of Canada as required by PIPEDA, and we will keep records of breaches as the law requires. Where the affected information was processed on behalf of a Subscriber, we will notify the Subscriber without undue delay so that the Subscriber, as the accountable organization, can meet its own obligations.
13. Cookies and similar technologies
The Custodyne website does not set advertising or analytics cookies and does not load third-party resources. The Custodyne platform uses only strictly necessary cookies — for example, a secure session cookie and cross-site request forgery protection — required to sign you in and keep the Service secure. [ owner to confirm if any analytics are later added ]
14. Children
The Service is intended for use by businesses and their authorized representatives. It is not directed to children, and we do not knowingly collect personal information from children. [ owner to confirm applicable age threshold ]
15. Changes to this policy
We may update this policy from time to time. When we make a material change, we will update the “Last updated” date above and, where appropriate, provide additional notice. Continued use of the Service after a change takes effect means the updated policy applies to you.
16. How to contact us
To reach our privacy contact, or to exercise any right described above, contact [ privacy contact — owner to confirm ]. You may also contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
© 2026 Custodyne Inc.