ODX Privacy Policy

Privacy Policy

Last Updated: April 27, 2026

Solutions Otonomi Inc.

This Privacy Policy explains how Solutions Otonomi Inc. ("Solutions Otonomi", "we", "us") handles personal information.

We work with two kinds of people:

  • End Users — individuals (typically homeowners) who fill out our project form to get a solar proposal from their installer; and
  • Installer Staff — employees of solar professionals who use the Otonomi DX platform to manage solar projects.

We follow Québec's Act respecting the protection of personal information in the private sector (the "Québec Privacy Act", as amended by Law 25), the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), and other applicable Canadian privacy laws.

If you have any privacy question, write to our Privacy Officer:

Théo Germain, Privacy Officer Solutions Otonomi Inc. 218 avenue Redfern, app. 17, Westmount (Québec) H3Z 2G3, Canada Email: privacy@solutions-otonomi.com

1. Scope and Definitions

1.1 Who this Policy applies to

This Policy applies to all personal information we process in connection with the Otonomi DX platform and the white-labelled solar project form, whether you are an End User, Installer Staff, or someone who interacts with our website.

1.2 Definitions

"Personal Information" means any information about an identifiable individual, including name, email address, phone number, postal address, energy consumption data, photos of property, IP address, and similar data.

"End User Data" means Personal Information about End Users that we collect through our project form.

"Installer" means a Solar Professional that subscribes to Otonomi DX. Installers are our paying business customers.

"End User" means an individual using the project form (typically a homeowner considering a solar installation).

"Service" means the Otonomi DX platform and the white-labelled project form.

2. Information We Collect

2.1 Information You Provide as an End User

When you fill out the project form, we collect what you give us:

  • Identity and contact: name, email address, phone number;
  • Location: postal address, country, province/state, postal code;
  • Project information: roof characteristics (orientation, slope, materials), size of property, electrical appliances and consumption patterns, type of project (off-grid, grid-tied, hybrid, storage);
  • Documents and uploads: utility bills, photos of your roof, electrical panel, or other parts of your property, any other document you choose to upload;
  • Communications: any messages or content you send us by email, phone, or through the form.

2.2 Information We Collect When You Use the Service

Whether you're an End User or Installer Staff, we automatically collect technical information when you use the Service:

  • IP address;
  • approximate location (country, province/state, city, postal code) derived from your IP address;
  • operating system and device identifier;
  • browser configuration;
  • device make and model;
  • pages visited, paths taken, dates and times of interactions;
  • referring URL.

2.3 Information from Cookies and Similar Technologies

We use cookies and similar technologies to make the Service work and to understand how it's being used. Some cookies are erased when you close your browser (session cookies); others remain longer (persistent cookies).

We use:

  • Strictly necessary cookies to operate the Service (authentication, security, form state);
  • Analytics cookies to understand how the Service is used and to improve it (e.g., Google Analytics);
  • Functional cookies to remember your preferences.

You can adjust cookie settings in your browser. Disabling some cookies may prevent parts of the Service from working.

2.4 Information from Analytics Tools

We use analytics tools (such as Google Analytics) that may provide us with aggregated demographic information (estimated age range, interests). This information is not associated with you personally and is provided to us in aggregate form.

2.5 Information You Provide as Installer Staff

If you are Installer Staff using Otonomi DX, we collect your:

  • name, email, phone, professional role;
  • account credentials and authentication data;
  • billing information processed via our payment processor;
  • content you create or upload in the Service (proposals, branding assets, customer reviews, portfolio photos).

For information about how Installers handle End User Data after we share it with them, please ask the Installer directly — once data leaves our Service, the Installer becomes responsible for it under their own privacy practices.

2.6 Information We Don't Collect

We don't ask for information unrelated to your solar project. We don't ask for social insurance numbers, government IDs, or banking information beyond what's needed for Installer Staff to pay their subscription (handled by Stripe).

3. Why We Collect Your Information (Legal Basis)

We process Personal Information based on the following legal grounds:

(a) Contract performance — we need to process some Personal Information to provide the Service you requested (e.g., generating a proposal recommendation, sending it to your Installer);

(b) Specific consent — for some uses (e.g., marketing emails), we ask for your specific consent, which you can withdraw at any time;

(c) Legitimate interests — for some uses (e.g., security, fraud prevention, improving the Service), we rely on legitimate interests that don't override your fundamental rights; and

(d) Legal obligations — for some uses (e.g., tax records, responding to lawful requests), we are required by law.

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal. To withdraw consent, write to privacy@solutions-otonomi.com.

4. How We Use Your Information

We use Personal Information to:

(a) deliver the Service — generate solar project recommendations, share lead information with your chosen Installer, send confirmation emails, and let you and your Installer track project progress;

(b) operate and improve the Service — fix bugs, monitor usage and performance, prevent fraud and abuse, conduct research and analysis;

(c) personalize your experience — remember your form progress, language preference, and similar settings;

(d) communicate with you — respond to your inquiries, send service-related messages (account confirmation, password reset, important updates);

(e) send marketing and product communications from Solutions Otonomi — when you have opted in or where permitted by law, send our newsletter, product updates, and promotions about Solutions Otonomi's services. You can unsubscribe at any time using the unsubscribe link in our emails or by contacting us at privacy@solutions-otonomi.com; and

(f) comply with legal obligations — respond to lawful requests from authorities, protect our rights, and comply with applicable law.

Communications from your Installer are separate. Once your information is shared with your Installer, your Installer becomes an independent controller of your Personal Information for their own communications with you (including project follow-up, service reminders, newsletters, and promotions). Solutions Otonomi is not responsible for the content of, or compliance with applicable law for, those communications. To unsubscribe from your Installer's emails, use the unsubscribe link in the Installer's email or contact the Installer directly. Your Installer is required by Canadian anti-spam law (CASL) and Québec privacy law (Law 25) to identify themselves and offer an unsubscribe mechanism in every commercial electronic message.

We do not use Personal Information to make automated decisions that produce legal effects or similarly significant effects about you. As of the Last Updated date of this Policy, the Service does not include any automated decision-making system within the meaning of Section 12.1 of the Québec Privacy Act. If we add such a feature in the future (for example, AI-assisted equipment recommendations that meaningfully affect what you are offered), we will update this Policy and notify you.

We do not use End User Data to train artificial intelligence models in any form that would expose your identifiable information.

5. Who We Share Your Information With

5.1 Your Installer

If you are an End User, the central purpose of our Service is to share your project information with the Installer whose link you used. Without this sharing, we cannot deliver the Service. By submitting the form, you understand and agree that your project information and contact details will be transmitted to your Installer so they can prepare a proposal and contact you.

Once your information is shared with the Installer, the Installer becomes an independent controller of that information and is responsible for handling it in accordance with their own privacy practices and applicable law. You should ask your Installer how they handle your data, including how long they keep it, how to access or correct it, and how to ask them to delete it.

5.2 Solutions Otonomi Employees

Our employees may access Personal Information only when needed to perform their job, under confidentiality obligations and security policies.

5.3 Sub-Processors (Service Providers)

We engage third-party service providers ("Sub-Processors") to help us deliver the Service. We make sure each Sub-Processor:

  • has a written contract requiring them to protect Personal Information at a level equivalent to ours;
  • only processes Personal Information on our instructions; and
  • implements appropriate security measures.

The current categories of Sub-Processors include:

  • Backend platform and primary database — provided by Xano, Inc. (United States), with data stored in Montréal, Québec, Canada;
  • Frontend application and content delivery network ("CDN") — frontend application provided by WeWeb SAS (France), with origin servers in the United States, and content delivery through Amazon CloudFront (global edge network, primary edge location for our users in Toronto);
  • Transactional email — Twilio SendGrid (United States);
  • Marketing email — Brevo (European Union: France, Germany, Belgium);
  • Payment processing — Stripe, Inc. (United States; for Installer subscription payments only);
  • Analytics — Google Analytics (United States).

A current list of Sub-Processors, with full details about each provider, is maintained at odx-subprocessors. We update this list as Sub-Processors change.

5.4 Legal and Regulatory Disclosures

We may disclose Personal Information when required by law, court order, or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, our users' safety, or the public interest. We may also disclose Personal Information to investigate fraud or other unlawful activity.

5.5 Business Transfer

If Solutions Otonomi is involved in a sale, merger, acquisition, restructuring, or similar transaction (including discussions of such a transaction), Personal Information may be transferred to the persons or organizations involved before and after the transaction, whether it closes or not. Any recipient will be required to keep Personal Information confidential and use it only to evaluate the transaction or in accordance with this Policy.

5.6 With Your Specific Consent

We may share Personal Information for purposes not described in this Policy where you have given specific consent.

6. Where Your Information Is Stored (Cross-Border Transfers)

We are transparent about where Personal Information lives:

  • Stored data (your project information, account data, proposals, uploaded documents): stored at rest in Montréal, Québec, Canada — through our backend platform provider Xano, Inc., which hosts the data on Google Cloud Platform's northamerica-northeast1 region.
  • Frontend application (the pages you load and interact with in your browser): served from origin servers located in Virginia, United States (through our frontend application provider WeWeb SAS), with content cached globally through Amazon CloudFront — for users in Canada, the primary edge cache is in Toronto, Canada.
  • Transactional emails (form confirmations, account notifications): sent through Twilio SendGrid, which operates from the United States.
  • Marketing emails (newsletters and product updates, when you have opted in): sent through Brevo, which operates from the European Union (France, Germany, Belgium).
  • Payment processing for paying business customers: handled by Stripe, which operates from the United States. End Users do not pay Solutions Otonomi.
  • Analytics: Google Analytics, which operates from the United States.

When Personal Information is transferred outside Québec and Canada, the laws of those jurisdictions may not provide protections equivalent to Canadian and Québec law. Authorities in those jurisdictions may, in certain circumstances, request access to Personal Information.

We have assessed the privacy implications of these transfers as required by Section 17 of the Québec Privacy Act, and we apply contractual and technical safeguards (such as data processing agreements, encryption in transit and at rest, and access controls) to protect Personal Information.

A complete and current list of Sub-Processors, including each one's location, is published at odx-sub-processors.

By using the Service, you understand and agree that your Personal Information may be transferred to and stored in the jurisdictions described above.

7. How Long We Keep Your Information (Retention)

We do not keep Personal Information forever. We retain it only as long as necessary for the purposes described in this Policy or as required by law. Our standard retention periods are:

End User project form data — when the End User has not been converted into a project by the Installer: 24 months from form submission, then deleted from active systems.

End User project form data — when converted into an active project by the Installer: For the duration of the Installer's subscription, plus the post-termination Retention Window described in the Installer Terms of Service (currently 90 days).

Installer Account data (Installer Staff identity, billing, account activity): Duration of the subscription, plus 90 days after termination.

Billing and tax records: 7 years (Canadian tax law requirement).

Marketing email preferences (opt-outs): Until you ask us to delete them — we keep opt-out records to honour your choices.

Server and security logs: 12 months, unless needed longer for an active investigation.

Backup archives: 35 days from backup creation.

Aggregated and anonymized data (no longer personal): No fixed limit — this data does not identify you.

After the retention period ends, we delete or anonymize the information, except where the law requires us to keep it longer (e.g., during an active legal proceeding). Backup deletion may take place over a rolling cycle.

If you ask us to delete your data sooner (see Section 8), we will honour your request unless we are legally required to keep it.

8. Your Rights

You have rights regarding your Personal Information. To exercise any of them, write to privacy@solutions-otonomi.com. We will respond within 30 days of receiving a request (or sooner if required by law). We may need to verify your identity before responding.

8.1 Right of Access

You may ask for a copy of the Personal Information we hold about you and information about how we use it, who we share it with, and how long we keep it.

8.2 Right of Correction

You may ask us to correct Personal Information that is inaccurate, incomplete, or out of date. For some information (like your contact details), you can update it yourself in the Service.

8.3 Right of Deletion / Withdrawal of Consent

You may ask us to stop processing your Personal Information or to delete it. Note:

  • if processing is necessary to deliver the Service you requested, withdrawing consent may mean we can no longer provide the Service;
  • once we have shared your information with your Installer, you must contact the Installer directly to ask them to delete the information they hold about you (we cannot do that for them, but we are happy to help you find their contact information);
  • we may keep some information where required by law (e.g., billing records).

8.4 Right to Data Portability (Québec Privacy Act, Section 27)

If you are an End User or Installer Staff, you have the right to receive a copy of the Personal Information you provided to us in a structured, commonly used technological format, and to ask us to send it directly to another organization where technically feasible.

8.5 Right to Object to Automated Decision-Making

As of the Last Updated date, we do not use automated decision-making to make decisions about you that produce legal or similarly significant effects. If we adopt such a process in the future, you will have the right to be informed and to ask for human review.

8.6 Right to File a Complaint

If you have a complaint about how we handle your Personal Information, please tell us first. Write to privacy@solutions-otonomi.com and we will respond within 7 business days.

If you are not satisfied with our response, you may file a complaint with:

  • Commission d'accès à l'information du Québec (for matters under Québec law) — https://www.cai.gouv.qc.ca; or
  • Office of the Privacy Commissioner of Canada (for matters under federal law) — https://www.priv.gc.ca.

8.7 Identity Verification

We may ask for reasonable proof of identity before responding to a request, to make sure we are giving information only to the right person. Information collected for identity verification is used only for that purpose.

9. How We Protect Your Information

We use technical and organizational security measures appropriate to the sensitivity of the information, including:

  • encryption in transit (HTTPS/TLS) for all data exchanges;
  • encryption at rest for stored Personal Information;
  • access controls limiting access to Personal Information to authorized employees and Sub-Processors;
  • logging and monitoring of access to detect unusual activity;
  • regular security reviews and updates;
  • employee training on confidentiality and privacy practices;
  • contractual safeguards with all Sub-Processors.

No system is perfectly secure. If we become aware of a confidentiality incident affecting your Personal Information that creates a risk of serious harm, we will notify you and the Commission d'accès à l'information du Québec without undue delay, as required by Section 3.5 of the Québec Privacy Act.

10. Privacy Officer

In accordance with Section 3.1 of the Québec Privacy Act, we have designated a Privacy Officer responsible for the protection of Personal Information at Solutions Otonomi. You can contact our Privacy Officer for any privacy-related question, request, or complaint.

Théo Germain, Privacy Officer Solutions Otonomi Inc. 218 avenue Redfern, app. 17 Westmount (Québec) H3Z 2G3 Canada Email: privacy@solutions-otonomi.com

11. Children

The Service is not directed at children under 14. We do not knowingly collect Personal Information from children under 14. If you believe we have collected such information, please contact us so we can delete it.

12. Third-Party Links and Social Media

The Service may include links to third-party websites or social media platforms. Those sites have their own privacy practices, which we don't control and aren't responsible for. Please read their privacy policies before sharing your Personal Information with them.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. The "Last Updated" date at the top of this Policy tells you when the most recent version took effect.

For material changes (changes that significantly affect your rights or how we use Personal Information), we will give you notice by email — to the address associated with your Account or, where you don't have an Account, where reasonably practical — at least 30 days before the change takes effect.

For non-material changes (such as clarifications or corrections), we may update the Policy without prior notice.

You can always view the current version of this Policy at odx-privacy-policy.

14. Language

This Policy is made available in English and French. In case of conflict, the French version prevails for individuals residing in Québec, in accordance with the Charter of the French Language.

15. Contact

For any privacy-related question, request, or complaint:

Théo Germain, Privacy Officer Solutions Otonomi Inc. 218 avenue Redfern, app. 17 Westmount (Québec) H3Z 2G3 Canada

Email: privacy@solutions-otonomi.com General inquiries: info@solutions-otonomi.com Web: https://solutions-otonomi.com

This Privacy Policy was last updated on April 27, 2026.

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