Sir Balone is deliberately designed to minimise the retention of personal data. This policy explains what we collect, why, with whom we share it, and the rights you have.
01Data controller and jurisdiction
The controller of your data is Pixeldvx Design, a sole proprietorship registered in Ontario, Canada, operator of the “Sir Balone” brand. As a Canadian entity, we are subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) federally and, when processing data of Quebec residents, to Law 25. If you are in the European Economic Area, we afford you the equivalent rights under the GDPR.
02Data-minimisation principle
To use La Lente, the only personally identifying datum we actively collect and store is your email address, used as an authentication vector. Alongside it we keep only the technical data strictly necessary to provide the service:
- a temporary access token (“magic link”) and its expiry date, invalidated after use or expiration;
- a reference to your subscription or package (Paddle identifier) and the usage counter needed to apply daily limits.
We do not collect passwords, name, postal address or payment details within La Lente — the latter are handled by Paddle. We do not sell or rent your personal data to third parties.
03Legal basis for authentication emails (CASL)
Emails containing the “magic link” are sent as transactional communications required to provide a service you have requested, and contain no promotional content. They are therefore exempt from the express marketing-consent requirement of Canada’s Anti-Spam Legislation (CASL). These emails are dispatched via our transactional email provider (Resend) and always identify the sender.
04Newsletter — Le Note (Beehiiv)
If you subscribe to our newsletter, you do so through express opt-in consent. Your email and newsletter engagement metrics (opens, clicks) are processed by Beehiiv as our sending processor. You may unsubscribe free of charge at any time via the link present in every email; we will action the unsubscribe within legal timeframes and, in any event, within a maximum of 10 business days.
05Store — La Galleria (Fourthwall)
Store purchases are processed through Fourthwall. The order, billing and shipping data you enter at its checkout are collected and processed by Fourthwall under its own privacy policy, acting as controller for those transactions. Sir Balone does not store your card details.
06Payments — Merchant of Record (Paddle)
La Lente payments are processed by Paddle as Merchant of Record. Paddle collects the billing data needed to complete the sale and meet its tax obligations, acting as an independent data controller for that information. See Paddle’s privacy policy for how it processes such data.
07Anonymous analytics (PostHog)
In order to permanently map and optimise the experience of our platform, we have integrated PostHog technology operating under a strict cookieless configuration (Cookieless Mode). Through this system, our server fully dispenses with cookies, local storage or persistent identifiers linked to the user.
Additionally, we have proactively disabled the capture of IP addresses at our organisation-wide level. Interaction counts are produced using irreversible hashing algorithms with daily salts that expire on 24-hour cycles. As a result, the statistical trace is generated under conditions of absolute anonymity, legally exempting this analysis from the restrictions applicable to the tracking of personal data under the GDPR, PIPEDA and Law 25.
We do not link this analytics to your email address or to any other personal identifier.
08Providers and processors
To operate the service we rely on providers that process data on our behalf or as independent controllers:
- Supabase — database (email, access token, subscription reference).
- Resend — transactional email delivery (magic link).
- Paddle — payment processing and taxation (Merchant of Record).
- Beehiiv — newsletter management and delivery.
- Fourthwall — store and physical-order fulfilment.
- Sportmonks — sports-data provider (receives no user personal data).
- PostHog — anonymous, cookieless analytics.
- Netlify — website hosting.
09International transfers
Some of our providers may process data outside Canada or the EEA. When data crosses borders, we require, through contractual safeguards, that it receive a level of protection substantially comparable to that it would enjoy in Canada, in accordance with PIPEDA and Law 25.
10Data retention
We keep your email and subscription reference while your account is active and for the legal period necessary for accounting obligations or to defend claims. Access tokens are deleted after use or expiration. When you request erasure, we remove your information from our systems except what the law requires us to retain.
11Your rights
Under PIPEDA, Law 25 and the GDPR, you have the right to access, rectify, erase and obtain the portability of your data, as well as to withdraw your consent and to lodge a complaint with the competent supervisory authority (the Office of the Privacy Commissioner of Canada, Quebec’s Commission d’accès à l’information, or your EEA authority). To exercise them, write to hola@sirbalone.com; we will respond within legal timeframes.
12Security-breach notification
In the event of a security breach posing a “real risk of significant harm” (RROSH), we will notify the Office of the Privacy Commissioner of Canada and the affected individuals as soon as feasible, in accordance with PIPEDA and applicable regulations.
13Minors
The service is intended for adults. We do not knowingly collect data from minors. If you believe a minor has provided us with data, contact us and we will delete it.
14Contact and privacy officer
Person responsible for personal-information protection: the individual with the highest authority at Pixeldvx Design (the business owner), in accordance with section 3.1 of Law 25. Email: hola@sirbalone.com. Postal address: Pixeldvx Design, 20 Bay Street, 11th Floor, Toronto, ON M5J 2N8, Canada.