Privacy Policy

1. Introduction

Kapsule Pro Inc. ("we," "our," or "us") values your privacy and is committed to protecting your personal information. This Privacy Policy describes how we collect, use, share and protect personal information when you use the Agentic Swarm website or any related services (collectively, the "Service"). It also explains the choices available to you regarding your personal information and how you can exercise your rights.

We operate in Canada and adhere to the Personal Information Protection and Electronic Documents Act (PIPEDA). Where applicable, we also comply with privacy laws in other jurisdictions, including the General Data Protection Regulation (GDPR) for users located in the European Economic Area and similar regulations in the United Kingdom, as well as the Children's Online Privacy Protection Act (COPPA) in the United States. This Policy is written in clear, plain language and is intended to be accessible and comprehensive, as recommended under GDPR guidelines.

2. Information We Collect

2.1. Information you provide

When you create an account, contact us or otherwise interact with the Service, you may provide personal information such as:

• Contact details: name, email address, postal address and phone number;
• Account credentials: username, password and any authentication details;
• Profile information: optional details you add to your profile (e.g., job title or organization);
• Content and communications: information you post, upload or communicate through the Service, including User Content, messages and support inquiries.

2.2. Information we collect automatically

When you access or use the Service, we automatically collect certain information about your device and usage, including:

• Usage data: IP address, browser type and version, device identifiers, operating system, referring and exit pages, clickstream data, and dates and times of access;
• First-party request data: requested page, timestamp, browser User-Agent, a query-free referrer, allowlisted UTM campaign fields, and confidence-aware crawler or security-probe classification. Routine direct page requests are sampled to reduce service use, while AI discovery, AI referral, UTM, agent-resource, and suspicious-security signals are retained. For supported crawler providers, an IP address may be checked transiently against official published ranges, but it is discarded before the traffic record is saved. This traffic log does not contain IP addresses, cookies, request bodies, form contents, account data, or arbitrary query parameters, and detailed records are retained for approximately 90 days;
• Cookies and similar technologies: small data files stored on your device for preferences, authentication, security, and core functionality. We also use Google Analytics 4 to understand aggregate site usage; Google Analytics may use cookies and similar identifiers. Our separate first-party traffic source reporting does not use cookies.

2.3. Information from third parties

We may receive information about you from third‑party service providers that assist us with hosting, payment processing, communications or customer support. We only obtain such data where those providers are legally entitled to share it with us.

3. Purposes and Legal Basis for Processing

We collect and use personal information only for legitimate purposes. The purposes and legal bases for processing include:

• Providing the Service: We use your personal information to register accounts, authenticate users, deliver features, respond to inquiries and provide customer support. The legal bases are performance of a contract (GDPR Art. 6(1)(b)) and legitimate interest in operating our Service.
• Improving and personalizing the Service: We analyse usage data to understand how users interact with the Service, troubleshoot issues, develop new features and improve user experience. The legal basis is our legitimate interest in maintaining and improving our Service.
• Communications: We may send administrative or transactional messages (e.g., service updates, security alerts) by email or through the Service. These communications are necessary for the Service. We may also send marketing communications where you have consented to receive them or where permitted by law.
• Compliance and legal obligations: We may process personal information to comply with legal obligations (e.g., tax and accounting requirements, lawful requests), to protect our rights or the rights of others, and to enforce our Terms of Service.
• Consent: Where required by law (e.g., for certain cookies or marketing communications), we rely on your consent to process personal information. You may withdraw your consent at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal.

4. How We Share Information

We do not sell your personal information. We may share your information in the following circumstances:

• Service providers: We use third‑party vendors to host and maintain the Service, process payments, send communications, and provide other administrative or technical services. We require these vendors to protect your information and use it only for the purposes for which we disclose it.
• Business transfers: If we are involved in a merger, acquisition, financing, restructuring or sale of some or all of our assets, your information may be transferred as part of that transaction, subject to applicable laws and your rights.
• Legal requirements: We may disclose personal information if required by law or if we believe in good faith that disclosure is necessary to comply with legal obligations, protect our rights or the rights, property or safety of others, detect or prevent fraud, or respond to government requests.
• With your consent: We may share your information for any other purpose disclosed to you at the time of collection or with your consent.

5. International Data Transfers

We are based in Canada but may process and store information in other countries. When personal information crosses provincial or national borders in the course of commercial activities, it is subject to PIPEDA and other applicable laws. We implement safeguards to ensure that transfers of personal information outside of your jurisdiction are protected to a similar standard. If you are in the European Economic Area or the United Kingdom, we use approved legal mechanisms to transfer your data, such as standard contractual clauses.

6. Data Retention

We retain personal information only as long as necessary to fulfil the purposes set out in this Policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. When the information is no longer required, we securely destroy or anonymize it in accordance with applicable laws and our data retention policies.

7. Security Measures

We implement appropriate administrative, technical and physical safeguards to protect personal information against loss, theft, unauthorized access, disclosure or modification. These measures include encryption, access controls, network monitoring and secure development practices. While we strive to protect your information, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your location and applicable law, you may have rights regarding your personal information, including:

• Access and correction: You can request access to the personal information we hold about you and ask us to correct inaccuracies.
• Deletion: You may request that we delete your personal information, subject to legal requirements.
• Objection and restriction: You may object to our processing of your personal information or request that we restrict processing in certain circumstances.
• Portability: Where applicable, you may request a copy of your personal information in a structured, commonly used, and machine‑readable format and have it transferred to another controller.
• Withdraw consent: Where processing is based on consent, you may withdraw your consent at any time.
• Lodge a complaint: If you are in the European Economic Area or another jurisdiction that provides a right to lodge complaints, you can contact your data protection authority regarding our handling of personal information.

To exercise your rights, please contact us using the information provided in Section 12. We may need to verify your identity before responding to your request.

9. Children's Privacy

We do not knowingly collect personal information from children under 13 years of age. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you believe that we might have information from a child under 13, please contact us. If our Service becomes directed toward children, we will provide parental consent mechanisms and comply with COPPA's privacy policy requirements, including clear disclosure of data collection, usage, sharing and retention and making such disclosures easily accessible.

10. Third‑Party Services and Links

Our Service may contain links to third‑party websites or services that are not controlled by us. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third‑party services before providing personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or industry standards. We will post the updated Policy on our website and indicate the effective date. If the changes are significant, we will provide a more prominent notice or seek your consent where required by law. Your continued use of the Service after the effective date constitutes your acceptance of the updated Policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy, your personal information or our privacy practices, please contact us at support@agenticswarm.com or by mail at Kapsule Pro Inc., Montreal, Quebec, Canada. You can also contact the Office of the Privacy Commissioner of Canada or your local data protection authority if you have unresolved concerns.