LEGAL

PRIVACY POLICY

Effective date: September 23, 2026 · Version 2026-09-23

This policy explains what personal data Chukwu collects, why, how long we keep it, who we share it with, and your rights under Quebec Law 25, PIPEDA, and the GDPR.

01 — WHO WE ARE

About Chukwu

Chukwu ("we", "us", "our") is Obinna Chukwu, a sole proprietor operating a custom software studio in Quebec, Canada. Our website is chukwu.studio.

Privacy Officer: Obinna Chukwu. Quebec Law 25 requires every organization to designate a person responsible for the protection of personal information. All access, correction, and deletion requests go to sales@obinnachukwu.org.

This policy covers our public website. If you are a client using Chukwu Core, Floor, or Pick, the handling of data inside those systems is governed by your Master Service Agreement and the Data Processing Addendum, under which we act as your processor rather than as the controller.

02 — WHAT WE COLLECT

Data We Collect

Contact form

Name, email address, the service you select, and the message you write. Submitted through web3forms, which relays it to our inbox. We also record which version of our Terms and Privacy Policy you accepted, in which language, and when.

Booking data

Name, email address, and anything you enter when booking a call. Handled by Calendly. The Calendly embed does not load until you have answered our cookie notice.

Advertising measurement

If and only if you consent, the Meta (Facebook) Pixel and the X (Twitter) Axon Pixel record that you visited a page or submitted the contact form, and associate that with your Meta or X profile where one exists. Neither loads before consent.

Server logs

Our hosts record IP address, request time, and user agent to serve pages and to detect abuse. This is ordinary web server operation and cannot be switched off without the site ceasing to function.

What we do not collect

We run no analytics product. There is no Google Analytics on this site. We do not use session recording, heatmaps, or fingerprinting, and we do not buy data about you from anyone.

03 — WHY WE COLLECT IT

Legal Basis and Purpose

Consent

Advertising and measurement cookies run only on your consent, which you give through our cookie notice and can withdraw at any time from the "Cookie preferences" link in the footer. Nothing non-essential loads before you choose.

Necessary to respond to you

Contact form and booking data are processed to answer your enquiry and, where it goes further, to prepare or perform a contract for services.

Legitimate operation of the site

Server logs and the cookie that remembers your consent choice are necessary for the site to work and to stay secure. These are not used to profile you.

What we never do

We do not sell or rent your personal data. We do not use it for automated decision-making that produces legal effects for you. We do not use it for any purpose beyond what this page describes.

04 — COOKIES

Cookies and Tracking Technologies

Under Quebec Law 25 s.8.1, technology that identifies, locates, or profiles a person must be deactivated by default, and we must tell you it exists and how to turn it on. Our advertising pixels are off until you switch them on.

Where you are in Quebec, the European Economic Area, or the United Kingdom — or where we cannot determine your region — you are asked before anything non-essential runs. The specific cookies are:

chukwu_consent_v1 — strictly necessary

Browser local storage, not a cookie sent to any server. Remembers the choice you made so we do not ask again. Expires after 12 months, after which we ask again. Cannot be disabled, because it is what records your decision.

_fbp, _fbc — advertising, requires consent

Set by Meta. Identify your browser so Meta can report whether an ad led to your enquiry, and recognise you on other sites that run the same pixel. _fbp lasts 90 days. Set only after you accept.

_twclid — advertising, requires consent

Set by X (Twitter) for the equivalent purpose. Set only after you accept.

Calendly cookies — requires consent

Set by Calendly when the booking embed loads, which only happens after you answer the notice. If you decline, you can still book through a direct link that opens on Calendly, where their own notice applies.

To change or withdraw your choice, use "Cookie preferences" in the footer of any page. Withdrawal takes effect immediately and we expire the advertising identifiers we can reach. You may also email sales@obinnachukwu.org.

05 — RETENTION

How Long We Keep Your Data

Contact form submissions

Retained in our email system for 24 months from submission, then deleted.

Acceptance records

Records of which Terms version you accepted are kept for 7 years, because they are the evidence of an agreement and a limitation period can run that long.

Calendly booking data

Governed by Calendly's retention policy. We keep no separate copy beyond what our email retains (24 months).

Consent record

Stored in your browser for 12 months. We hold no server-side copy — it never leaves your device.

Advertising pixel data

Once transmitted, governed by Meta and X respectively under their own policies. We cannot delete data held on their systems on your behalf, but you can control it in your Meta and X account settings.

Server logs

Retained by our hosts on their standard cycle, typically 30 days.

06 — THIRD-PARTY PROCESSORS

Who We Share Data With

We do not sell or rent your personal data. We share it only with the processors below, each engaged under their standard data protection terms:

Netlify — website hosting

Serves this website and processes server logs including IP addresses. netlify.com/privacy

Railway — application hosting

Hosts the Chukwu Core, Floor, and Pick application servers and their databases. Relevant to clients rather than website visitors. railway.app/legal/privacy

web3forms — contact form delivery

Receives contact form submissions and relays them to our inbox. web3forms.com/privacy

Calendly — scheduling

Receives booking details. calendly.com/privacy

Meta — advertising measurement, consent only

Receives page view and enquiry events if you consent. facebook.com/privacy/policy

X (Twitter) — advertising measurement, consent only

Receives page view and enquiry events if you consent. x.com/en/privacy

A current list is maintained in our Subprocessors document, which clients are notified of before we add anyone new.

07 — CROSS-BORDER TRANSFERS

International Data Transfers

We are based in Quebec, Canada. Every processor listed above is headquartered in the United States and processes data on servers outside Canada.

Quebec Law 25 s.17 requires that before transferring personal information outside Quebec we assess whether it would receive adequate protection, having regard to the sensitivity of the information, the purpose, the protections in place, and the legal framework of the destination. We have carried out that assessment for each processor above and rely on their contractual data protection terms, including Standard Contractual Clauses where applicable.

Where your data reaches a US processor only because you consented — the advertising pixels — declining consent prevents that transfer entirely.

08 — YOUR RIGHTS

Your Privacy Rights

Under Quebec Law 25, PIPEDA, and the GDPR where it applies to you, you have the following rights:

Access

Obtain a copy of the personal information we hold about you, and be told how it is used and who it has been shared with.

Correction

Have inaccurate or incomplete information corrected.

Deletion

Have your information deleted where we no longer have grounds to keep it. We action deletion requests within 30 days.

Portability

Receive the computerised personal information you provided in a structured, commonly used technological format. This is the Law 25 s.27 right, in force since September 2024.

Withdraw consent

Withdraw consent to advertising cookies at any time, as easily as you gave it, through the footer link. Withdrawal does not affect what was lawful before it.

Complain

Raise a complaint with us, and escalate to a regulator if our answer does not satisfy you.

To exercise any of these, email sales@obinnachukwu.org. We respond within 30 days and charge nothing for access requests. We may ask you to confirm your identity before releasing information, so that we do not disclose your data to someone else.

09 — SECURITY AND INCIDENTS

Security and Confidentiality Incidents

We protect personal information with measures proportionate to its sensitivity: encryption in transit, access controls and per-tenant isolation in our applications, hashed credentials, and restricted administrative access.

Quebec Law 25 s.3.5 to 3.8 requires us to keep a register of confidentiality incidents and, where an incident presents a risk of serious injury, to notify both the Commission d'accès à l'information and each affected person promptly. We maintain that register and will do so.

No system is perfectly secure. If you believe your information has been exposed, contact us immediately at sales@obinnachukwu.org.

10 — AUTOMATED PROCESSING

Automated Processing

Our client applications include automated extraction that reads purchase order documents and converts them into structured order data, including optical character recognition. This operates on our clients' business documents rather than on website visitors, and a person reviews and confirms extracted orders before they are acted on.

We make no decision about you based solely on automated processing that produces a legal effect or similarly significant effect. If that ever changes, this section changes with it and you will be told what logic is involved.

11 — CHILDREN

Children

This is a business-to-business website and is not directed to children. We do not knowingly collect personal information from anyone under 14, the threshold at which Quebec Law 25 requires parental consent. If you believe a child has provided us information, contact us and we will delete it.

12 — CHANGES

Changes to This Policy

We may update this policy. The version and effective date at the top of this page identify the current revision.

Where a change materially affects how we handle your personal information, we will ask for your consent again rather than relying on your continued use of the site.

13 — CONTACT

Contact and Complaints

For any privacy matter, including access and deletion requests:

Obinna Chukwu, Privacy Officer

sales@obinnachukwu.org

If our response does not satisfy you, you may complain to the Commission d'accès à l'information du Québec (cai.gouv.qc.ca), to the Office of the Privacy Commissioner of Canada (priv.gc.ca), or to your local supervisory authority if you are outside Canada.

Questions about this policy?

Email sales@obinnachukwu.org