LEADERSCARTEL

Privacy Policy

LeadersCartel is a publication of Power Brand Ca, a corporation incorporated in the Province of British Columbia, Canada.

This Privacy Policy ("Policy") sets out how Power Brand Ca ("Power Brand Ca," "we," "us," "our") collects, uses, discloses, retains, and protects Personal Information in connection with the LeadersCartel platform at leaderscartel.com and related services (the "Service").

This Policy is drafted in compliance with:

1. Definitions

1.1 "Personal Information" means information about an identifiable individual, as defined in BC PIPA section 1, and includes all such information that Power Brand Ca collects, uses, or discloses in connection with the Service.
1.2 "User" means any individual who accesses or subscribes to the Service, whether on a paid plan, free trial, or as a subscriber to any Power Brand Ca mailing list or feed.
1.3 "Privacy Officer" means the individual designated by Power Brand Ca under Section 2 as accountable for compliance with this Policy.
1.4 "Service Provider" means a third party engaged by Power Brand Ca to process Personal Information on our behalf under written data-processing terms.
1.5 Capitalized terms not otherwise defined have the meaning ascribed to them in BC PIPA or PIPEDA, as applicable.

2. Accountability and Privacy Officer

2.1 Power Brand Ca is accountable for all Personal Information under its control, including Personal Information transferred to Service Providers for processing.
2.2 Power Brand Ca has designated a Privacy Officer responsible for ensuring compliance with this Policy and applicable privacy law:
Privacy Officer — Power Brand Ca Email: [email protected]
2.3 The Privacy Officer is the designated point of contact for all inquiries, requests, and complaints under this Policy. Power Brand Ca shall respond to all verified privacy inquiries within thirty (30) calendar days of receipt, in accordance with BC PIPA section 28 and PIPEDA Schedule 1, Principle 4.9.

3. Scope

3.1 This Policy applies to Personal Information collected by Power Brand Ca through:
3.2 This Policy does not apply to third-party websites or services linked from the Service, including source publications cited in editorial content. Those services are governed by their respective privacy policies, and Power Brand Ca disclaims responsibility for them.

4. Categories of Personal Information Collected

4.1 Power Brand Ca collects only the Personal Information reasonably necessary to deliver and improve the Service. The categories collected are set out in Sections 4.2 through 4.7 and no others.
4.2 Account Information
4.3 Subscription and Billing Information
4.4 Service Usage Information
4.5 Technical Information
4.6 Communications — any content You include in correspondence directed to Power Brand Ca, together with associated delivery metadata.
4.7 Power Brand Ca does not knowingly collect Personal Information in the sensitive categories defined under Quebec Law 25 and PIPEDA guidance, including health information, ethnic origin, sexual orientation, political beliefs, religious beliefs, biometric identifiers, or government-issued identification numbers.

5. Purposes of Collection, Use, and Disclosure

5.1 Power Brand Ca shall collect, use, and disclose Personal Information solely for the purposes set out in Sections 5.2 through 5.7. Any use for a purpose not listed below requires Your express consent, obtained in advance. Implied consent is not sufficient for uses outside this Section.
5.2 Service Delivery — authenticating User accounts, delivering editorial and intelligence content, processing RAVEN queries, and maintaining watchlists and preferences.
5.3 Billing and Subscription Management — processing payments through our payment processor (Stripe, see Section 6.2), managing trial and renewal cycles, and issuing billing notices.
5.4 Communications — sending transactional emails (authentication, billing receipts, service-status notices) and editorial communications to which You have subscribed.
5.5 Service Improvement — analyzing aggregated, and where practicable de-identified, usage patterns to improve the stability, relevance, and editorial quality of the Service.
5.6 Security and Fraud Prevention — detecting, investigating, and preventing unauthorized access, abuse, or fraudulent activity in relation to the Service.
5.7 Legal Compliance — responding to lawful requests from courts, regulators, or law-enforcement authorities; enforcing the Terms of Service; and establishing, exercising, or defending legal claims.
5.8 Power Brand Ca shall identify the purpose of collection at or before the time Personal Information is collected. If Power Brand Ca proposes to use Personal Information for a purpose not set out in this Section, it shall obtain Your consent before doing so.

6. Disclosure to Service Providers

6.1 Power Brand Ca does not sell Personal Information under any circumstances.
6.2 Power Brand Ca discloses Personal Information only to the Service Providers listed in this Section, and only to the extent each Service Provider requires such information to perform its contracted function:
6.3 Each Service Provider identified in Section 6.2 is bound by contractual terms requiring it to (i) process Personal Information only on our instructions, (ii) maintain confidentiality, and (iii) apply safeguards comparable to those required by BC PIPA and PIPEDA.
6.4 Power Brand Ca may additionally disclose Personal Information:
6.5 Power Brand Ca does not disclose Personal Information to advertising networks, data brokers, behavioural-analytics providers, or any third party that constructs user profiles in connection with the Terminal product. The provisions of this Section 6.5 apply to the Terminal product only; advertising on public content pages of leaderscartel.com is addressed in Sections 12.4 to 12.6 below.

7. Consent

7.1 By creating an account, subscribing to the Service, or otherwise providing Personal Information to Power Brand Ca, You consent to the collection, use, and disclosure of Your Personal Information as set out in this Policy.
7.2 Express consent is required and shall be sought explicitly where Power Brand Ca proposes to use Personal Information for any purpose beyond those set out in Section 5.
7.3 Implied consent is relied upon only for uses that a reasonable person would expect given the context of the Service, consistent with BC PIPA section 8 and PIPEDA Schedule 1, Principle 4.3.
7.4 Withdrawal of consent. You may withdraw Your consent to the collection, use, or disclosure of Your Personal Information at any time, subject to legal and contractual restrictions and upon reasonable notice. To withdraw consent, contact the Privacy Officer at [email protected]. Power Brand Ca shall inform You of the consequences of withdrawal before giving it effect, which may include the inability to provide some or all of the Service.

8. Security Safeguards

8.1 Power Brand Ca protects Personal Information with security safeguards appropriate to its sensitivity, consistent with BC PIPA section 34 and PIPEDA Schedule 1, Principle 4.7.
8.2 Current safeguards include:
8.3 No system of electronic storage or transmission can be guaranteed absolutely secure. Where Power Brand Ca becomes aware of a breach of security safeguards involving Personal Information that creates a real risk of significant harm to any individual, Power Brand Ca shall notify affected Users and the Office of the Information and Privacy Commissioner for British Columbia in accordance with BC PIPA and, where applicable, report the breach to the Office of the Privacy Commissioner of Canada under PIPEDA section 10.1.

9. Retention

9.1 Power Brand Ca retains Personal Information only for as long as reasonably necessary to fulfill the purposes set out in Section 5 or as required by applicable law.
9.2 Upon Your request for deletion under Section 10.4, Power Brand Ca shall delete Your Personal Information within thirty (30) calendar days of receipt of a verified request, except to the extent retention is required:
9.3 Where retention under Section 9.2 is required, Power Brand Ca shall inform You of the nature and expected duration of the retention.

10. User Rights

Under BC PIPA and PIPEDA, You have the following rights in respect of Your Personal Information. Power Brand Ca shall respect and give effect to these rights in accordance with the procedures set out in this Section.

10.1 Right of access. You may request a copy of the Personal Information Power Brand Ca holds about You, together with information about how it has been used and disclosed.
10.2 Right of correction. You may request correction of Personal Information that is inaccurate or incomplete. Where Power Brand Ca agrees with the requested correction, it shall make the correction. Where Power Brand Ca does not agree, it shall annotate the record with a notation of Your correction request.
10.3 Right to withdraw consent. See Section 7.4.
10.4 Right to deletion. You may request deletion of Your Personal Information in accordance with Section 9.2.
10.5 Right to challenge compliance. You may challenge Power Brand Ca's compliance with this Policy in accordance with Section 13.
10.6 Response time. Power Brand Ca shall respond to verified access and correction requests within thirty (30) calendar days of receipt, as required by BC PIPA section 29 and PIPEDA Schedule 1, Principle 4.9.1. Where a request is complex or voluminous, BC PIPA permits a single thirty-day extension, which Power Brand Ca shall notify You of in writing with reasons.
10.7 Identity verification. Power Brand Ca may require reasonable verification of Your identity before giving effect to a request under this Section, to protect Your Personal Information from unauthorized disclosure.
10.8 To exercise any right under this Section, contact the Privacy Officer at [email protected].

11. Cross-Border Transfer of Personal Information

11.1 Power Brand Ca operates infrastructure within Canada. Certain Service Providers identified in Section 6.2 operate internationally and may process Your Personal Information in the United States or other jurisdictions in the course of delivering their contracted services.
11.2 Where Personal Information is transferred outside Canada, Power Brand Ca relies on contractual terms with Service Providers requiring protection comparable to that provided under BC PIPA and PIPEDA.
11.3 Personal Information transferred outside Canada may become subject to the laws of the receiving jurisdiction, including lawful-access requests by foreign courts, regulators, or law-enforcement authorities.
11.4 Notice to Quebec residents. In accordance with Quebec Law 25, Users resident in Quebec may request further information from the Privacy Officer about the jurisdictions in which their Personal Information is processed and the safeguards applied to such processing.

12. Cookies and Session Technologies

12.1 The Service uses essential session cookies required for authentication and session continuity. Session cookies are first-party and are deleted upon log-out or session expiry.
12.2 Power Brand Ca does not use advertising cookies, cross-site tracking cookies, third-party behavioural-analytics cookies, or similar tracking technologies within the Terminal product. Advertising and related cookies on public content pages are addressed in Sections 12.4 to 12.6.
12.3 You may disable cookies in Your browser. Disabling essential session cookies will prevent authentication and the use of account-protected features of the Service.
12.4 Advertising on public content pages. Public content pages of leaderscartel.com — including without limitation the Intelligence article archive at /intelligence, the entity Index at /the-index, individual entity profile pages, and ranking pages — display third-party advertising served by Google AdSense and other advertising vendors retained by Power Brand Ca from time to time. The Terminal product is a paid subscription service and displays no third-party advertising.
12.5 Cookies and identifiers used by advertising vendors. Google, as a third-party vendor, may use cookies, web beacons, advertising identifiers, and similar technologies to serve advertisements on public content pages based on a User's prior visits to leaderscartel.com or to other websites. Such use is governed by the privacy terms of Google and any other advertising vendor engaged by Power Brand Ca, and not by this Policy.
12.6 Opt-out and further information. You may opt out of personalized advertising delivered by Google by visiting Your Google Ads Settings, and may opt out of personalized advertising delivered by participating vendors through the Network Advertising Initiative or the Digital Advertising Alliance:
Google Ads Settings — https://adssettings.google.com
Google's advertising privacy notice — https://policies.google.com/technologies/ads
Network Advertising Initiative opt-out — https://optout.networkadvertising.org
Digital Advertising Alliance opt-out — https://optout.aboutads.info

13. Challenging Compliance

13.1 If You believe Power Brand Ca has failed to handle Your Personal Information in accordance with this Policy or applicable privacy law, the following procedure applies.
13.2 Step 1 — Internal resolution. Submit Your complaint in writing to the Privacy Officer:
Privacy Officer — Power Brand Ca Email: [email protected]

Power Brand Ca shall acknowledge receipt within fourteen (14) calendar days and provide a substantive written response within thirty (30) calendar days.

13.3 Step 2 — External resolution. If Your complaint is not resolved to Your satisfaction through Section 13.2, You may refer the matter to the applicable regulator:
Office of the Information and Privacy Commissioner for British Columbia Website: oipc.bc.ca
PO Box 9038, Stn. Prov. Govt., Victoria, BC V8W 9A4
Telephone: 1-800-663-7867
Office of the Privacy Commissioner of Canada Website: priv.gc.ca
30 Victoria Street, Gatineau, QC K1A 1H3
Telephone: 1-800-282-1376
Commission d'accès à l'information du Québec Website: cai.gouv.qc.ca
13.4 The regulators identified in Section 13.3 have statutory authority to investigate complaints, issue findings and orders, and, where applicable, impose administrative penalties for non-compliance with applicable privacy law.

14. Editorial Complaints Distinguished

14.1 This Policy governs the handling of Personal Information only. Complaints respecting editorial matters — including accuracy, fairness, sourcing, and corrections — are handled under the separate Editorial Standards and Corrections Policy of LeadersCartel.

15. Children's Privacy

15.1 The Service is not directed to children under the age of sixteen (16).
15.2 Power Brand Ca does not knowingly collect Personal Information from any individual under the age of sixteen.
15.3 Where a parent or guardian believes a child under sixteen has provided Personal Information to Power Brand Ca, that parent or guardian may contact the Privacy Officer at [email protected]. Power Brand Ca shall, upon verification, promptly delete the information and terminate any associated account.

16. Changes to This Policy

16.1 Power Brand Ca may amend this Policy from time to time to reflect changes in practice or legal obligation.
16.2 Where an amendment is material — including the addition of a new purpose of collection, a new category of Personal Information, or a new category of Service Provider — Power Brand Ca shall:
16.3 Continued use of the Service after the effective date of an amendment constitutes acceptance of the amended Policy. Where You do not accept an amendment, You may terminate Your account before the effective date.

17. Governing Law and Jurisdiction

17.1 This Policy is governed by the laws of the Province of British Columbia and the federal laws of Canada applicable therein.
17.2 Any dispute arising under or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of the Province of British Columbia, and each party irrevocably submits to such jurisdiction.

18. Contact

Privacy Officer — Power Brand Ca Email: [email protected]
General and editorial inquiries Email: [email protected]