Privacy Policy

Paction takes your privacy very seriously. Our privacy policy is guided by our privacy values and at the core of that is transparency.

Privacy

We value your privacy. It’s your data, not ours. We all deserve to have our private data kept private. We value the trust that our users place in us by sharing their information with us and appreciate the responsibility we have to maintain that trust.

Protection

You deserve to have your personal data and content protected. We’re dedicated to protecting the information you share with us and invest significant resources to ensure your data is kept secure. Paction believes that each user deserves to have their personal data kept private and confidential without fear of misappropriation or bullying and be free from unwanted targeting by third parties.

Privacy Policy

Last updated: September 14, 2026

This Privacy Policy explains how Paction Inc. (“Paction”, “we”, “us” or “our”) collects, uses, shares and protects personal information when you visit paction.ca, create an account, or use any feature of the Paction platform (together, the “Platform”). It applies to Buyers, Breeders and visitors alike. Personal information means information about an identifiable individual.

We are subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and, for residents of Quebec, the Act respecting the protection of personal information in the private sector. The person in charge of the protection of personal information at Paction can be reached at privacy@paction.ca.

Contents

1. 1. What information we collect
2. 2. How we use your information
3. 3. Consent
4. 4. Who we share information with
5. 5. Where your information is stored and processed
6. 6. Cookies and analytics
7. 7. Automated processing
8. 8. How long we keep your information
9. 9. How we protect your information
10. 10. Children
11. 11. Your rights and choices
12. 12. Third-party websites
13. 13. Changes to this policy
14. 14. How to contact us

1. What information we collect

Information you give us

• Account details: your name, email address, phone number, password, and the province or city you are in.
• Buyer details: what you are looking for (breeds, location, timing, budget and similar preferences), the messages and applications you send to Breeders, and information about your home and household that you choose to share with them.
• Breeder details: your business or kennel name, address, website and social-media links, the dogs, litters and waitlists you list, health-testing and registration information, photos and videos, and your bank or payout details, which are collected by Stripe when you enable payments.
• Identity verification: for Breeders, a photo of a government-issued identification document. See “Sensitive information” below.
• Handbook answers: if you buy a personalized breed handbook, the answers you give to personalize it — such as who lives in your home, your home type and outdoor space, other pets, your province, your daily schedule and time alone, the activities you plan, dogs you have had, and whether anyone in your home has dog allergies — and a record of your purchase. These answers are used to personalize your handbook and are not shared with Breeders.
• Payments: when you pay a subscription, deposit, handbook or other amount through the Platform, your card details are collected and stored by Stripe, not by us. We receive confirmation of the payment, the last four digits of the card, the country where the card was issued, and billing address information. When you buy a Digital Product such as a handbook, you also give us the billing address of your card before you pay.
• Communications: messages you send through the Platform, reviews, applications, visit requests, survey answers, and emails or support requests you send us.
• Contest and promotion entries, where you take part.

Sensitive information

A photo of a government-issued identification document is sensitive personal information. Breeders must provide one to use the core features of the Platform. Buyers may provide one if they choose, so that other Members can see their identity has been confirmed. We collect it only to confirm identity, and only with your express consent, which you give when you upload it. These images are stored on servers located in Canada, are not displayed on the Platform or shared with other Members, and within Paction are used only to confirm identity, including confirming it again if a question about an account arises later, such as a suspected duplicate or fraudulent account. We keep the image while your account exists so that this remains possible. You may ask us to delete your identification image at any time by emailing privacy@paction.ca; we may then be unable to keep your account verified. If you personalize a breed handbook, we ask whether anyone in your home has dog allergies; that answer is health-related, and we use it only to personalize your handbook. We do not otherwise ask for sensitive information such as health, financial or biometric data.

Information we collect automatically

When you use the Platform we collect technical and usage information: your IP address, the approximate location derived from it (country and province), browser and device characteristics, the pages you view and the actions you take, the search terms you use, referring pages, and error reports if something goes wrong. Where you arrive from one of our online advertisements, we record the advertising click identifier so that we can measure which advertisements work.

Information from other sources

We receive information from Stripe about payments you make or receive, and from Google about how our advertisements and website perform.

2. How we use your information

We use personal information to:

• create and administer your account and verify your identity;
• run the marketplace: publish Breeder profiles and Listings, match Buyers’ interests with Breeders, introduce them to each other, and enable messaging, applications, visit scheduling and video calls;
• process subscriptions, deposits and payments, calculate taxes, and issue invoices and refunds;
• sell and deliver Paction’s own digital products, calculate their taxes from your billing address, confirm that people who buy them live in Canada by checking the country of their card and that its billing address matches the one they gave us, and personalize the breed handbooks you buy;
• operate the certification program and display reviews;
• send service messages — new-message alerts, introductions and lead notifications for Breeders, visit confirmations, verification codes and billing notices — by email, in-app notification and SMS;
• alert our staff to activity that needs attention, such as a new purchase, by email or SMS, which can include the Member’s name and email address;
• send marketing messages where you have consented, and let you opt out;
• provide support, investigate reports, disputes and suspected fraud, and keep the Platform and its Members safe;
• provide AI-assisted features, such as suggested message drafts for Breeders and tools that help our support team understand a conversation;
• understand how the Platform is used, fix problems, and improve it;
• measure the performance of our website and advertising; and
• comply with our legal obligations and enforce our Terms.

3. Consent

We collect, use and share personal information with your consent, or as otherwise permitted or required by law. Consent may be express — for example when you tick a box, upload an identification document or accept cookies — or implied from your actions, for example when you send a message to a Breeder and thereby ask us to deliver it. You can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us; withdrawing consent may mean we cannot provide some or all of the Platform to you.

In limited circumstances the law allows us to collect, use or disclose personal information without consent — for example to investigate a breach of an agreement or a contravention of the law, to respond to a subpoena, warrant or court order, to collect a debt, or where it is clearly in your interests and consent cannot be obtained in a timely way.

4. Who we share information with

Other Members

The Platform is a marketplace, so some sharing between Members is the point of it. A Breeder’s profile, Listings, photos, reviews and certification status are public. When a Buyer expresses interest in a breed or a Breeder, sends an application or books a visit, we share the Buyer’s name, contact details and the information in their message or application with the Breeder or Breeders concerned so that they can respond. Reviews you write are published with the name on your account. Members must use each other’s information only for the purpose it was shared for; if a Member misuses it, tell us.

Service providers

We share personal information with the companies that provide services to us, only to the extent needed for them to do so. At the date of this policy they are:

• Amazon Web Services — hosting, databases, file storage, email delivery, logs and monitoring (Canada Central region).
• Stripe — subscription billing, payments, payouts to Breeders, tax calculation and refunds.
• Mailgun — sending email.
• Twilio — SMS, phone verification and video calls.
• Google — Google Analytics (website analytics), Google Ads (advertising measurement) and Google Calendar and Meet (calendar invitations and video links for confirmed visits).
• Anthropic — the AI model behind our AI-assisted features, such as message drafting for Breeders and tools that help our support team understand a conversation. Content sent to these features, which can include the text of messages between Members, is processed to generate the result and, under Anthropic’s commercial terms, is not used to train its models.
• Sentry — error monitoring, which receives technical details about errors, including your device and browser information and the page you were on.
• LocationIQ — converting addresses and postal codes into map locations.

Other situations

• Legal requirements: to comply with a law, regulation, subpoena, warrant or court order, or a lawful request from a public authority.
• Protecting rights and safety: to enforce our Terms, investigate fraud or misuse, or protect the rights, property or safety of Paction, our Members, animals or the public.
• Business transfers: if Paction or substantially all of its assets are sold, merged or reorganised, personal information may be transferred to the successor, who will be bound by this policy.

5. Where your information is stored and processed

Our servers and databases are located in Canada (Amazon Web Services, Canada Central region). Some of the service providers listed above process information outside Canada, mainly in the United States: Stripe, Mailgun, Twilio, Google, Anthropic, Sentry and LocationIQ. While your information is outside Canada it is subject to the laws of that country, including laws that may allow authorities there to access it. We use contractual and technical safeguards designed to give your information a level of protection comparable to that in Canada.

6. Cookies and analytics

We use cookies and similar technologies for three things: to keep you signed in and remember your settings (essential cookies); to understand how the Platform is used, through Google Analytics (analytics cookies); and to measure our advertising (advertising cookies).

Outside Quebec: analytics cookies are active by default and your continued use of the Platform indicates your consent to them, as PIPEDA permits for non-sensitive information collected for an apparent purpose. Advertising cookies are off by default.

In Quebec: we show you a consent banner before any analytics or advertising cookies are set, and none are set unless you accept. If you accept all cookies, both analytics and advertising cookies are enabled.

We determine whether you are in Quebec from the approximate location our hosting provider derives from your connection. You can change or withdraw your cookie choice at any time by clearing the site data your browser stores for paction.ca, which will show the banner again if you are in Quebec, and you can block cookies in your browser settings. To opt out of Google Analytics everywhere, use Google’s opt-out tool. We do not respond to browser Do-Not-Track signals, because no common standard for them has been adopted.

7. Automated processing

We use automated rules to match Buyers’ stated interests with Breeders, to decide which Breeders receive an introduction, to prioritise and route messages, and to suggest next steps and message drafts. Where a decision about you is based exclusively on automated processing, we will inform you of it, and you may ask us about the personal information used and submit observations. To do so, contact privacy@paction.ca.

8. How long we keep your information

We keep personal information for as long as you have an account and for as long afterwards as we need it for the purposes described in this policy, to meet legal obligations (for example tax and payment records, which tax law requires us to keep for at least six years), to resolve disputes and to enforce our agreements. Messages between Members are retained so that both parties can refer back to them. When information is no longer needed we delete it or make it anonymous. Where deletion from a backup is not immediately possible, the information is isolated from further use until the backup expires.

9. How we protect your information

We protect personal information with technical and organisational measures appropriate to its sensitivity, including encryption in transit and at rest, access controls, logging and monitoring, and payment handling delegated to Stripe so that card numbers never reach our systems. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the relevant privacy regulators as the law requires.

10. Children

The Platform is for adults. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.

11. Your rights and choices

You may, subject to the limits set by law:

• access the personal information we hold about you and learn how we have used and shared it;
• correct information that is inaccurate or incomplete;
• withdraw consent to a use or disclosure, and opt out of marketing at any time using the unsubscribe link in any marketing email, by replying STOP to a marketing SMS, or by contacting us;
• request deletion of your account and personal information, which we will carry out except for information we must keep by law or to resolve a dispute;
• receive a copy of the computerised personal information you provided to us in a structured, commonly used technological format (portability);
• if you are in Quebec, be informed about and ask questions of any decision based exclusively on automated processing, and ask that your information no longer be disseminated or be de-indexed where the law provides; and
• complain to us, and to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information, if you are not satisfied with our response.

To exercise any of these rights, email privacy@paction.ca from the address on your account, or write to us at the address below. We may ask you to confirm your identity first. We respond within thirty days, and will tell you if we need longer or cannot fulfil a request.

12. Third-party websites

The Platform links to websites we do not control, such as Breeders’ own websites and social-media pages. This policy does not apply to them, and we are not responsible for their privacy practices. Read their policies before giving them information.

13. Changes to this policy

We will update this policy when our practices change. The date at the top tells you when it was last revised. If we make a material change, we may notify you by posting a notice on the Platform or by contacting you directly.

14. How to contact us

Privacy questions and requests: privacy@paction.ca. General support: support@paction.ca.