Privacy Policy

This Privacy Policy explains how Aneurin Advisory, operated by Every Ingredient Gourmet Spices LLC (a Wyoming, USA limited liability company), collects, uses, stores, and protects personal information provided by individuals in Canada visiting our website or engaging with our services.

By using our website at ca.aneurinadvisory.com, communicating with us via WhatsApp, or submitting an application, you acknowledge that you have read and understood this policy. If you do not agree, please do not use our website or submit your personal information.

1. Who We Are

Business name: Aneurin Advisory

Operating entity: Every Ingredient Gourmet Spices LLC

Registered state: Wyoming, United States of America

Canadian website: ca.aneurinadvisory.com

Contact: info@aneurinadvisory.com

Aneurin Advisory provides done-for-you cross-border business infrastructure services to new and early-stage entrepreneurs across all Canadian provinces. We help clients establish Canadian corporations, U.S. LLCs, business banking, payment processing, and related operational infrastructure for operating across the Canada-USA corridor.

As our operating entity is a Wyoming LLC, personal information collected from Canadian residents may be transferred to, stored, and processed in the United States. Please see Section 6 for more information on cross-border data transfers.

2. Information We Collect

We collect personal information only when you voluntarily provide it to us. This occurs primarily through our application form, direct email communications, and WhatsApp messaging.

Information You Provide Directly

• Full name
• Email address
• Contact telephone number
• Province and city of residence
• Business description and goals
• Preferred start date and communication preferences
• Any additional information you choose to share in your application or messages

Information Collected Through WhatsApp

When you contact us via WhatsApp, the content of your messages, your WhatsApp display name, and your phone number are accessible to us. This communication is facilitated through Meta Platforms, Inc. Please see Section 8 for full details on WhatsApp and Meta data handling.

Information Collected Automatically

When you visit our website, certain technical information may be collected automatically by our hosting provider and analytics tools, including:

• IP address and general geographic location
• Browser type and version
• Pages visited and time spent on site
• Referring website or source

We do not use this data to identify you personally. It is used solely for understanding how our website is used and improving our content.

Information We Do Not Collect

We do not collect payment card details through our website. All payments are processed through Stripe and are subject to their respective privacy policies. We do not collect Social Insurance Numbers (SIN) or other government-issued identification numbers through this website or via WhatsApp.

3. How We Use Your Information

We collect personal information only for purposes a reasonable person would consider appropriate in the circumstances. We use the information you provide for the following purposes:

• To review and evaluate your application for our services
• To contact you regarding your application and next steps
• To deliver the services you have engaged us to provide
• To communicate updates, progress reports, and deliverables related to your project
• To provide ongoing support through the monthly support plan where applicable
• To operate and personalise Zeni, our AI business assistant, for subscribed clients
• To comply with our legal and contractual obligations
• To maintain accurate business records

We do not use your personal information for unsolicited marketing, profiling, or any purpose materially different from those listed above without obtaining your further consent.

We collect only the minimum personal information necessary to fulfil the identified purpose, in accordance with the principle of data minimisation under PIPEDA and applicable provincial privacy legislation.

4. Legal Basis for Processing

Under PIPEDA and applicable provincial privacy legislation, we rely on the following grounds for collecting, using, and disclosing your personal information:

• Express consent: By submitting your application or contacting us via WhatsApp, you expressly consent to the collection and use of your personal information as described in this policy.
• Implied consent: In certain circumstances, your consent may be implied from your actions, such as providing contact information with a clear expectation of follow-up.
• Contractual necessity: Where you engage our services, processing your information is necessary to fulfil our obligations under our Service Agreement.
• Legal obligation: Where we are required to collect or disclose information by applicable Canadian or U.S. law.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide services to you.

5. How We Store and Protect Your Data

We implement reasonable technical and organisational safeguards to protect your personal information against unauthorised access, collection, use, disclosure, copying, modification, disposal, or destruction.

Application submissions are received via Web3Forms, a third-party form submission service. Submitted data is subsequently stored in secure internal project folders. Client communications and project files are managed through our internal tools. WhatsApp communications are stored within the WhatsApp platform operated by Meta.

Our safeguards include:

• Restricted access to personal information on a need-to-know basis
• Use of third-party platforms with their own security standards and policies
• Secure communication practices for transmitting sensitive information

While we take reasonable steps to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to treating your data responsibly and reporting any material breach in accordance with applicable law.

6. Cross-Border Data Transfers

As our operating entity is a Wyoming limited liability company and we use U.S.-based service providers, your personal information may be transferred to, stored in, or processed in the United States.

By submitting your information through our website or communicating with us via WhatsApp, you acknowledge and consent to this transfer. We take steps to ensure that any third-party service providers outside Canada provide a comparable level of protection to your personal information.

Please note that once your information is transferred to the United States, it may be subject to access by U.S. governmental authorities under applicable U.S. laws. Canadian privacy legislation such as PIPEDA may not apply to U.S.-based recipients of your data, and you may have limited recourse under Canadian law with respect to that handling.

7. Sharing Your Information

We do not sell, rent, or trade your personal information to any third party.

We may share your information in the following limited circumstances:

• Service providers: We work with a small number of trusted third-party service providers (such as form submission tools, file storage, and communication platforms) who may process your data on our behalf as our agents. These providers are bound by confidentiality obligations and are not permitted to use your data for their own purposes.
• Meta Platforms: When you communicate with us via WhatsApp, your message data is processed by Meta Platforms, Inc. under their own privacy policy. See Section 8 for full details.
• AI infrastructure providers: Where you use Zeni as a subscribed client, inputs and outputs may be processed by third-party AI providers under their own terms. See Section 9 for full details.
• Legal requirements: We may disclose your information where required by law, court order, or a regulatory authority in Canada or the United States.
• Business operations: In the course of delivering your project, certain personal information may be shared with registered agents, government agencies (such as provincial registries or the Canada Revenue Agency), banking institutions, or platform providers, strictly as necessary to complete your business setup. This is done as part of the services you have engaged us to provide and with your knowledge.

In all cases, we disclose only the minimum information necessary for the specific purpose.

8. WhatsApp and Meta Messaging

Aneurin Advisory uses WhatsApp Business as a primary communication channel with clients and prospective clients. WhatsApp is operated by Meta Platforms, Inc. (“Meta”), a U.S.-based company. By contacting us via WhatsApp, you acknowledge and agree to the following.

What Meta Collects

When you use WhatsApp to contact us, Meta collects and processes data in accordance with its own privacy policies, including but not limited to:

• Your phone number and WhatsApp account information
• Message metadata including timestamps, read receipts, and delivery status
• Device information and usage data
• Your general location based on IP address or phone settings

Meta may use this data for its own purposes, including platform security, service improvement, and advertising on its wider network of platforms (including Facebook and Instagram), subject to its own privacy policy. Aneurin Advisory does not control Meta’s data practices.

What Aneurin Advisory Accesses

Through the WhatsApp Business platform, Aneurin Advisory can access:

• The content of messages you send to our WhatsApp number
• Your WhatsApp display name and phone number
• Message timestamps and delivery status

We use this information solely to respond to your enquiry, manage your client engagement, and provide the services you have requested. We do not use WhatsApp message content for marketing profiling or share it with third parties outside the scope of service delivery.

End-to-End Encryption

WhatsApp applies end-to-end encryption to personal messages between users. However, messages sent to WhatsApp Business accounts may be handled differently. Meta may store and process business messages in accordance with its WhatsApp Business Terms of Service. You should avoid sending sensitive personal information such as government ID numbers, banking credentials, or passwords via WhatsApp.

Data Transfers

WhatsApp message data is processed by Meta’s servers, which are located primarily in the United States and Ireland. By contacting us via WhatsApp, you consent to your data being transferred outside Canada to Meta’s infrastructure. This transfer is governed by Meta’s privacy policy, not this policy.

Meta’s Privacy Policy

For full details on how Meta handles your data through WhatsApp, please review Meta’s Privacy Policy at whatsapp.com/legal/privacy-policy and Meta’s Privacy Policy at meta.com/privacy-policy.

Opting Out

If you do not wish your information to be processed by Meta through WhatsApp, please contact us by email at info@aneurinadvisory.com instead. We will accommodate email as an alternative communication channel upon request.

9. Zeni AI Assistant

As part of our monthly support plan, clients have access to Zeni, an AI-powered business operator assistant available via WhatsApp. Zeni stores and processes the following information to deliver personalised responses:

• Business profile information provided during onboarding
• Financial figures voluntarily logged by the client
• Message content submitted through WhatsApp conversations

This information is stored securely in our database and is used solely to provide business operator support. Responses are generated via OpenAI’s API, which processes data in the United States under OpenAI’s privacy policy and enterprise data protection terms. OpenAI does not use this data to train its models. No client data is sold or shared with third parties for marketing purposes.

Clients may request deletion of their Zeni data at any time by contacting info@aneurinadvisory.com.

10. Cookies and Tracking

Our website may use cookies and similar tracking technologies to improve your browsing experience and understand how visitors use our site. Cookies are small text files stored on your device.

The types of cookies we may use include:

• Essential cookies: Required for the website to function correctly.
• Analytics cookies: Used to understand traffic patterns and improve our content. We may use tools such as Google Analytics for this purpose, which may involve the transfer of data to the United States.

You may control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of our website.

We do not use cookies for advertising, behavioural profiling, or to track you across third-party websites.

11. Your Rights

Under PIPEDA and applicable provincial privacy legislation, you have the following rights with respect to your personal information:

Right of Access

You have the right to request access to the personal information we hold about you and to receive information about how it has been used and disclosed.

Right to Correction

You have the right to request that we correct any personal information that is inaccurate, incomplete, or out of date.

Right to Withdraw Consent

You may withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal and contractual limitations. We will inform you of the implications of withdrawing consent before you do so.

Right to Make a Complaint

If you believe we have handled your personal information in a manner that does not comply with applicable privacy legislation, you have the right to make a complaint. Please contact us first and we will make every effort to resolve the matter. If you are not satisfied with our response, you may escalate your complaint to the applicable authority:

• Federal (PIPEDA): Office of the Privacy Commissioner of Canada — priv.gc.ca
• British Columbia (PIPA BC): Office of the Information and Privacy Commissioner for BC — oipc.bc.ca
• Alberta (PIPA AB): Office of the Information and Privacy Commissioner of Alberta — oipc.ab.ca
• Quebec (Law 25): Commission d’accès à l’information du Québec — cai.gouv.qc.ca
• Other provinces: The Office of the Privacy Commissioner of Canada handles complaints under PIPEDA for provinces without their own substantially similar legislation.

To exercise any of these rights, please contact us at info@aneurinadvisory.com. We will respond within 30 days, as required by law.

12. Data Retention

We retain personal information only as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law.

For applicants who do not proceed to become clients, we retain application data for up to 12 months, after which it is securely deleted.

For clients, we retain project records and associated personal information for a minimum of 7 years following the completion of our engagement, in accordance with standard business and Canadian tax record-keeping requirements.

WhatsApp message history is retained within the WhatsApp platform according to Meta’s data retention policies. We do not independently archive WhatsApp messages beyond what is accessible within our WhatsApp Business account.

Data processed through Zeni is subject to the retention practices of our third-party AI infrastructure provider in addition to our own. We do not retain Zeni conversation logs beyond what is required to operate the service.

When personal information is no longer required, we destroy, erase, or de-identify it using secure methods.

You may request early deletion of your data by contacting us, subject to any retention obligations we are required to fulfil under applicable law.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or the services we offer. When we do, we will update the date at the top of this page.

We encourage you to review this policy periodically. Continued use of our website or services after any changes constitutes your acknowledgement of the updated policy.

For material changes affecting your rights or how we handle your personal information, we will make reasonable efforts to notify active clients directly prior to the change taking effect.

14. Contact and Complaints

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our handling of your personal information, please contact us.

We will acknowledge your request within 5 business days and provide a substantive response within 30 days, unless an extension is required under applicable law, in which case we will notify you accordingly.

If you are not satisfied with our response, you may file a complaint with the applicable privacy commissioner as listed in Section 11.