Privacy Policy

Effective Date: June 22, 2026

1. Introduction & Scope

Akuntsu Inc. (“Akuntsu”, “we”, “us”) is the sole operator of the Services and the Data Controller of your personal information.

Butterfly Innov (“Butterfly”), an independent company based in Serbia, provides software development and technical processing services to Akuntsu and acts strictly as a Data Processor on behalf of Akuntsu.

This Privacy Policy explains how Akuntsu collects, uses, and discloses personal information through the Attractr platform and Audience Lab.

2. Compliance With Applicable Laws

We are committed to complying with applicable data protection laws, including Quebec’s Law 25, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and the European Union’s General Data Protection Regulation (GDPR), when processing the personal information of individuals located in the relevant jurisdictions.

3. Our Privacy Officer

We have appointed Yuko Nakamura as our Person in Charge of the Protection of Personal Information (Privacy Officer). The Privacy Officer is responsible for overseeing our compliance with Law 25, handling data subject requests, and responding to any confidentiality incidents.

You can contact our Privacy Officer at:

Yuko Nakamura · Akuntsu Inc. · 4060 Boulevard St-Laurent, Suite 703, Montreal, QC H2W 1Y9, Canada · privacy@attractr.live

4. Information We Collect

a. Identity & Role-Based Data

For all users: name, email address, verified date of birth (to confirm 18+ eligibility), and phone number.
For Suppliers: tax IDs (GST/HST/QST), business registration details, and banking information for payouts.
For audience members: interests and creators supported.

b. Audience Lab Data

Forum posts, community comments, and educational progress tracking.
Interaction data from WordPress and WooCommerce plugins.

c. Automated Technical Data

IP addresses, device information, and usage metrics from your interaction with the Services.

d. AI-Generated Insights

Predictive “Cultural Intelligence” signals derived from aggregated user interactions by the Clara AI (ClaraLive.ai) engine.
We design our systems to avoid identifying specific individuals and do not use these outputs for individual-level profiling or decisions with legal or similarly significant effects.

5. Age Restrictions

The Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information as soon as possible.

We reserve the right to use third-party identity verification services to confirm that users are 18 years of age or older. Verification providers act as data processors and are contractually obligated to protect your information and delete it once verification is complete.

6. How We Use Your Information

To provide and maintain the Services, including the Attractr marketplace, Audience Lab forum and educational content, and Clara AI cultural intelligence features.
To process payments and payouts in connection with the Services.
To communicate with you about your account, respond to your inquiries, and provide customer support.
To personalize your experience on the Services, such as by tailoring content and recommendations to your interests.
To generate anonymized, aggregated insights through the Clara AI engine to improve the Services and support performing arts market research.
To detect, prevent, and address fraud, security issues, and technical problems.
To enforce our Terms of Service and other policies governing use of the Services.

7. Sharing Your Information

With Suppliers: Where necessary to deliver a Supplier’s paid or interactive offering, we may share limited participant information with that Supplier. Suppliers are required to handle this information in compliance with Law 25 and the GDPR.
With our service providers: We may engage third-party companies to facilitate the Services. Our approved sub-processors are: Brevo SAS (newsletter and email communications), Airtable Inc. (CRM and member database management), Automattic Inc. / WordPress.com (website hosting and blog publishing), Sharetribe (marketplace infrastructure), Google Cloud (data storage), Sendbird (in-platform chat), Whereby (video streaming), and Stripe (payment processing). Each sub-processor has access to your personal information only to the extent needed to perform their functions and is obligated to maintain its confidentiality and security.
With your consent: We may share your information with third parties when you have given us consent to do so.
For legal reasons: We may disclose your information when necessary to comply with applicable laws, regulations, legal processes, or governmental requests.

8. International Data Transfers

Akuntsu and Butterfly have entered into a Data Processing Agreement (DPA) and Transfer Impact Assessment (TIA) to ensure that any transfers of personal data from Canada to Serbia are conducted in compliance with Law 25 and provide an adequate level of protection. The DPA incorporates the EU Standard Contractual Clauses (Module Two: Controller to Processor).

Additionally, transfers of personal data to sub-processors located in the United States (Airtable Inc. and Automattic Inc.) are governed by executed Standard Contractual Clauses (SCCs) ensuring an equivalent level of data protection. You can request copies of relevant DPAs by contacting our Privacy Officer at privacy@attractr.live.

9. Your Rights

Depending on your location, you may have rights under Law 25, PIPEDA, or the GDPR, including:

The right to access and obtain a copy of your personal information.
The right to request rectification of inaccurate personal information.
The right to request deletion of your personal information.
The right to data portability.
The right to object to the processing of your personal information for certain purposes.
The right to withdraw your consent to the processing of your personal information.
The right to lodge a complaint with a supervisory authority.

To exercise any of these rights, please contact our Privacy Officer at privacy@attractr.live. We will respond within 30 days, as required by Law 25.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your use of the Services. We use essential cookies (necessary for functionality) and analytics cookies (to measure and improve performance).

You can control cookies through your browser settings. For users in the European Economic Area, we obtain consent before setting non-essential cookies.

11. Data Retention and Deletion

Account data: Retained until account deletion.
Financial data: Retained for 7 years for tax compliance.
Security logs: Retained for 12 months for incident investigation and prevention.
CRM records (Airtable): Member and contact data retained for the duration of active membership plus 24 months, unless earlier deletion is requested.

Content you have shared publicly on the Services, such as forum posts or comments, may remain visible after your account is deleted — see Section 7 of the Terms of Service for details on anonymization.

12. Security and Incident Response

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

Mandatory Multi-Factor Authentication (MFA) across all administrative access layers.
Encryption of data at rest and in transit.
Continuous cryptographic logging of system initializations and access events.

If we become aware of a security breach that compromises your personal information and creates a high risk to your rights and freedoms, we will notify the Commission d’accès à l’information (CAI) of Quebec and all affected data subjects within 72 hours of breach detection, as required by Law 25. We maintain an internal register of all confidentiality incidents.

13. Future Artificial Intelligence and Machine Learning Training

Our proprietary artificial intelligence engine, ClaraLive.ai, is currently under active technical development and is not operational, deployed, or active within the current launch phase of the Audience Lab platform.

By default, your user content and personal data are not used to train our AI models. Any utilization of your data for machine learning training strictly requires your separate, explicit, and affirmative opt-in consent. This option is completely disabled and unchecked by default upon registration.

Before any future AI model training takes place, all data is subjected to irreversible cryptographic anonymization protocols, removing all Personally Identifiable Information (PII). You maintain the absolute right to withdraw this processing authorization at any time via a self-service toggle within your account privacy settings, without penalty to your core platform access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post any changes on this page and indicate the date of the last revision. If we make material changes that affect your rights, we will provide additional notice and seek your consent as required by law.

15. Language

This Privacy Policy is available in both English and French. For users located in Quebec, the French version shall prevail where required by applicable law.

16. Contact Us

If you have any questions about this Privacy Policy, please contact: privacy@attractr.live