Privacy Policy
Last updated June 23, 2026 · v0.1
Privacy isn't a setting here — it's how the product is built. This policy explains what we collect, what we don't, and the control you have. It applies to our website and to the Vinci app.
The short version
By default, your conversations are not stored on our servers and are never used to train our models. Memory and model improvement are separate choices you opt into — both are off unless you turn them on. Everything runs on Canadian infrastructure.
Who we are
The service is operated by Alpine Pacific Trading Inc., operating as SimpleDirect®, based in Toronto, Ontario, Canada. "We", "us" and "our" refer to this company. For privacy questions, contact our Privacy Officer (below).
Privacy Officer
We have appointed a Privacy Officer responsible for our handling of personal information under PIPEDA and Quebec's Law 25. You can reach them at: Privacy Officer, Vikas Grover — support@getsimpledirect.com.
What we collect
We collect as little as we can to run the service. Most of it is technical, not personal.
Technical & telemetry data
Your IP address, device and browser type, and crash logs — used to operate, secure, and debug the service.
Website form data
The name and email you submit through our contact or newsletter forms, used only to reply or send what you asked for.
Account information (optional)
If you choose to create an account, your email and basic preferences. The chat works without an account; an account is your choice.
Conversation content (only with memory on)
Your chats are processed to answer you and then discarded by default. They are retained only if you turn on memory — see below.
Cookies
A small number of essential cookies to run the site, plus optional analytics cookies that load only if you consent.
Your conversations (zero data retention)
By default, the content of your conversations is processed in memory to generate a response and is not written to our logs, analytics, or any datastore — and is never used to train our models. This is our default for everyone. Two separate, optional choices can change this, and only if you turn them on: memory and model improvement.
Memory and model improvement (both opt-in, off by default)
These are two independent choices. Turning on one never turns on the other, and both are off unless you choose them.
Memory
Lets the app remember your conversations so it gets to know you across sessions. Off by default. When on, your saved data is viewable, exportable, and deletable by you at any time.
Model improvement (training)
Lets us use a conversation to help improve future models. A separate choice from memory, off by default, and granular. We never train on your conversations unless you explicitly contribute them.
Why we use data, and our legal basis
We use the data above for the following purposes:
To provide the service
Process your request and return a response. Legal basis: performance of our terms with you, and your consent.
To keep it secure and reliable
Prevent abuse, diagnose crashes, and keep the service available. Legal basis: our legitimate interests in a safe, working service.
To communicate with you
Reply to your messages and, if you subscribe, send updates you asked for. Legal basis: your consent.
To improve our models
Only using conversations you explicitly opt in to contribute. Legal basis: your consent, which you can withdraw at any time.
Where your data is processed
Processing and model inference run on Canadian infrastructure — GPU inference in Rimouski, Quebec, and server workloads in Montreal, Quebec. We chose Canadian residency deliberately so your data stays in Canada rather than transiting foreign infrastructure by default.
Who else processes data for us
We rely on a small set of service providers, by category. We do not sell your personal information.
Cloud & inference infrastructure
Canadian infrastructure providers that host the service and run model inference.
Email delivery
A transactional email provider that sends account and contact-form emails.
Newsletter
An email marketing provider that handles opt-in newsletter subscriptions.
Analytics (only if enabled)
A privacy-respecting analytics provider, loaded only if you consent to analytics cookies.
How long we keep it
Conversation content is ephemeral by default — processed and then discarded. Data tied to an opt-in choice (memory or contributed training data) is kept until you delete it or close your account. Technical logs are kept only as long as needed to operate and secure the service, then deleted or aggregated.
Your rights and choices
Wherever you are, you can ask us to:
- Access the personal information we hold about you
- Correct information that is inaccurate or incomplete
- Delete your information (erasure)
- Receive your information in a portable, machine-readable format
- Withdraw consent at any time — including memory and model improvement
- Object to or ask us to restrict certain processing
Regional rights
If you're in Canada, these rights are protected under PIPEDA and, in Quebec, under Law 25. If you're in the EU, EEA, or UK, you have rights under the GDPR (and UK GDPR), including the right to lodge a complaint with your supervisory authority — we serve you the same way and do not block access by region.
To exercise any of these, email support@getsimpledirect.com or use the in-app data controls. We respond within the timelines required by applicable law. see your data controls
International data transfers
We process data on Canadian infrastructure. Where a service provider processes limited data outside Canada (for example, some email or analytics services), we use appropriate safeguards and disclose the category here.
If something goes wrong
If a privacy breach poses a real risk of significant harm, we will notify the relevant regulator(s) and affected individuals without undue delay, as required by PIPEDA, Law 25, and the GDPR.
Age requirement
The service is intended for adults. You must be at least 18 years old to create an account or use the app. We do not knowingly collect personal information from children.
Cookies and analytics
We use essential cookies needed to run the site. Any non-essential cookies (such as analytics) are off until you consent, and you can change your choice at any time from "Cookie settings" in the footer. See our cookie notice for the full list.
Changes to this policy
We'll post any changes here with a new "last updated" date and keep prior versions available. For material changes, we'll give notice through the app or website before they take effect.
Contact us
Questions about privacy? Email our Privacy Officer at support@getsimpledirect.com. For other legal matters, support@getsimpledirect.com.
Full Privacy Policy
The summary above is a plain-language guide. The complete policy follows. Where the two differ, this full text governs.
1. Scope
This Privacy Policy explains how Alpine Pacific Trading Inc., operating as SimpleDirect® ("we", "us", "our"), collects, uses, discloses, and protects personal information through our website, the Vinci application, and related services (the "Services").
2. Who we are and our Privacy Officer
The organization accountable for your personal information is Alpine Pacific Trading Inc. (SimpleDirect®), Toronto, Ontario, Canada. Our Privacy Officer is accountable for compliance with Canada's PIPEDA and Quebec's Law 25 and can be reached at support@getsimpledirect.com.
3. Information we collect
We collect: (a) technical and telemetry data such as IP address, device and browser type, and crash logs; (b) information you submit through website forms, such as your name and email; (c) account information if you choose to create an account; (d) conversation content only if you enable memory; and (e) cookie data as described in section 16. We do not seek biometric, precise-geolocation, or special-category data.
4. How we use information and our legal bases
We use personal information to provide and secure the Services, communicate with you, comply with law, and — only where you have opted in — to improve our models. Our legal bases are your consent, performance of our Terms with you, and our legitimate interests in operating a secure and reliable service.
5. Consent
We obtain consent at the point of collection and, for secondary or sensitive uses, through specific opt-in choices. You may withdraw consent at any time, subject to legal or contractual limits, by contacting us or using in-product controls; withdrawal does not affect processing already carried out.
6. Conversation content and zero data retention
By default the Services operate with zero data retention: the content of your conversations is processed transiently to generate a response and is not written to our logs, analytics, or any datastore, and is not used to train our models.
7. Memory and model improvement
Memory and model improvement are separate optional features, each off by default. Memory stores your conversations so the product can recall them; model improvement uses only conversations you specifically contribute to train future models. Enabling one does not enable the other. You may view, export, and delete memory data and withdraw either consent at any time.
8. Disclosure and service providers
We do not sell personal information. We share it only with service providers that process data on our behalf under contract — cloud and inference infrastructure, email delivery, newsletter, and, if enabled, analytics — and where reasonably required to comply with law, enforce our terms, or protect rights and safety.
9. Data residency and international transfers
We process personal information on Canadian infrastructure. Where a service provider processes limited data outside Canada, we use contractual and technical safeguards and remain accountable for its protection.
10. Retention
Conversation content is ephemeral by default. Data tied to an opt-in feature is retained until you delete it or close your account. Other personal information is retained only as long as necessary for the purposes described or as required by law, after which it is deleted or de-identified.
11. Security
We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information. No system is perfectly secure, but we work to protect personal information against loss and unauthorized access, use, or disclosure.
12. Your rights
Subject to applicable law, you may request access to, correction of, deletion of, or a portable copy of your personal information, withdraw consent, and object to or restrict certain processing. To exercise a right, contact support@getsimpledirect.com; we respond within the time required by law and may need to verify your identity.
13. Regional provisions
Canada and Quebec: under PIPEDA and Law 25 you have rights of access, correction, portability, and withdrawal of consent, and may complain to the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec. EU/EEA and UK: under the GDPR and UK GDPR you have those rights plus the right to lodge a complaint with your supervisory authority. We serve users in these regions and do not block access by region.
14. Automated decision-making
We do not use your personal information to make decisions producing legal or similarly significant effects about you based solely on automated processing. AI outputs are generated for your use and are not such decisions.
15. Children
The Services are intended for adults and you must be at least 18 years old to use them. We do not knowingly collect personal information from children; if we learn that we have, we will delete it.
16. Cookies and analytics
We use essential cookies required to operate the site. Non-essential cookies, including any analytics, load only with your consent, which you can change at any time via "Cookie settings" in the footer.
17. Breach notification
If a privacy breach creates a real risk of significant harm, we will notify the appropriate regulator(s) and affected individuals without undue delay, consistent with PIPEDA, Law 25, and the GDPR, and keep records of breaches as required.
18. Changes
We may update this policy and will post the revised version with a new effective date, preserving prior versions. We will provide additional notice for material changes.
19. Contact and complaints
To ask a question, exercise a right, or make a complaint, contact our Privacy Officer at support@getsimpledirect.com. If you are not satisfied with our response, you may contact the applicable regulator listed in section 13.