Privacy Policy

Last Updated: July 8, 2026

This Privacy Policy ("Policy") explains how Heirly Inc. ("Heirly," "we," "us," or "our") collects, uses, discloses, and safeguards personal information of users ("you" or "User") of the Heirly platform, website, applications, and related services (collectively, the "Platform"). By accessing or using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Policy. If you do not agree with this Policy, you must not use the Platform.

Heirly operates in Canada and the United States. This Policy is intended to comply with Canadian privacy law, including the Personal Information Protection and Electronic Documents Act ("PIPEDA") and Quebec's Act respecting the protection of personal information in the private sector ("Law 25"), and with applicable United States privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA") and comparable U.S. state privacy laws. If you access the Platform from outside Canada or the United States, additional rights may apply under your local law; you may contact us to exercise them. This Policy should be read together with our Terms of Use and Cookies Policy.

"Personal information" (also called "personal data" or "personal information" under U.S. state laws) means information about an identifiable individual, or information that identifies, relates to, or could reasonably be linked with a particular individual or household. It does not include de-identified, aggregated, or publicly available information.

1. Collection of Personal Information

1.1 Account Information

  • (a) We collect personal information necessary to establish and maintain your account, including your name, email address, telephone number, and password.
  • (b) We collect business information, including company name, registration number, and credentials, as applicable to your role.
  • (c) Role-specific information may be collected as follows:
    • (i) Buyers: preferences and investment parameters;
    • (ii) Sellers: business listings, strategic business information;
    • (iii) Advisors: professional credentials and areas of expertise.
  • (d) Sensitive personal information, including government-issued identification or financial records, is collected only with your explicit consent and is stored securely.
  • (e) Other registration information may be collected to the extent necessary to create and maintain your account.

1.2 User Contributions and Platform Interactions

  • (a) We collect information you submit to the Platform, including but not limited to listings, messages, documents, survey responses, and onboarding information.
  • (b) We collect usage data, including clicks, searches, session duration, and interactions with Platform features.
  • (c) We collect activity and notification data, including records of interest expressions, deal stage progressions, disclosure level changes, document access events, advisor invitations, and messaging activity, to operate the Platform, provide relevant notifications, and maintain audit trails.

1.3 Technical Information

  • (a) We collect device information, such as type of device, operating system, and browser; IP addresses; connection information; and cookies or similar technologies for authentication, analytics, and personalization of your experience.

1.4 Third-Party Data and Service Providers

  • (a) We may collect personal information from third-party service providers in connection with Platform functionality, verification of business credentials, or delivery of Platform features.
  • (b) We use the following categories of third-party service providers to operate the Platform:
    • (i) Cloud infrastructure and hosting providers;
    • (ii) Payment processing providers;
    • (iii) Email delivery providers;
    • (iv) File storage providers;
    • (v) Marketing and analytics providers;
    • (vi) Artificial intelligence service providers.
  • (c) These service providers process data on our behalf pursuant to data processing agreements and are contractually bound to protect personal information in accordance with applicable privacy laws.
  • (d) A current list of specific service providers may be requested by contacting info@heirly.co.

2. Use of Personal Information

2.1 Purposes of Use

We may use personal information only as necessary to:

  • (a) Provide, operate, maintain, and improve the Platform and its features;
  • (b) Verify identities, credentials, and business information. Verification may involve contacting third parties, consulting public or private databases, and using Cookies and other tracking mechanisms in accordance with the Cookies Policy;
  • (c) Enable communication and transactions between Buyers, Sellers, and Advisors;
  • (d) Prevent, detect, and respond to fraud, abuse, security incidents, or violations of the Terms of Use;
  • (e) Analyze Platform usage and generate insights, summaries, or rankings in anonymized or aggregated form. "Anonymized" means that personal identifiers are irreversibly removed to prevent identification;
  • (f) Comply with legal obligations, enforce agreements, and resolve disputes;
  • (g) Provide AI-generated outputs for informational purposes only, which do not constitute legal, financial, valuation, tax, or investment advice.

2.2 Artificial Intelligence and Automated Processing

  • (a) Certain Platform features use artificial intelligence technologies to enhance your experience, including generating match recommendations, improving listing quality, and providing personalized insights.
  • (b) When you use AI-powered features:
    • (i) Relevant data you provide may be processed by third-party AI service providers on our behalf;
    • (ii) Our AI service providers are contractually prohibited from using your data to train their models;
    • (iii) AI service providers may retain data for limited periods for safety monitoring purposes before automatic deletion;
    • (iv) We implement data minimization practices to limit transmission of sensitive personal information where practicable.
  • (c) Heirly's own models and Platform features. We may use information you submit to operate, secure, and improve the Platform, including to develop and improve our own matching, ranking, and verification models. Where we use information to train or improve our own models, we use de-identified or aggregated information wherever practicable; we do not use the content of your private Deal Room communications or documents to train models for use outside your own transaction without your consent.
  • (d) AI-generated outputs are provided for informational purposes only and do not constitute recommendations, valuations, or professional advice.

2.3 Automated Decision-Making

  • (a) The Platform uses automated processing, including AI-assisted matching, ranking, and verification.
  • (b) Where a decision that produces a legal or similarly significant effect on you is based exclusively on automated processing, we will inform you of that fact and, on request, provide information about the personal information used and the principal factors that led to the decision.
  • (c) You have the right to:
    • (i) request general information about the categories of data used in automated recommendations;
    • (ii) request human review of significant automated decisions that materially affect your use of the Platform; and
    • (iii) contest an automated decision, submit observations, and request correction of inaccurate personal information.
  • (d) Requests may be submitted to info@heirly.co. Heirly reserves the right to protect proprietary algorithms and methodologies as trade secrets, and is not obligated to disclose specific logic, weighting, or technical implementation details, subject to your rights above.

3. Disclosure of Personal Information

3.1 Sharing with Other Users

Personal information may be shared with other Users only to the extent necessary for marketplace interactions, including business names, listing information, and professional contact details. Sensitive personal information will not be disclosed.

3.2 Service Providers and Partners

Personal information may be disclosed to third-party service providers and partners who process data on our behalf. These third parties are bound by contractual obligations to protect personal information and to use it only for the purposes for which it was disclosed.

3.3 Legal Obligations

We may disclose personal information to comply with applicable laws, regulations, or legal processes, or to respond to lawful requests from authorities.

3.4 Corporate Transactions

In the event of a corporate transaction, including but not limited to a merger, acquisition, or sale of assets, personal information may be transferred to the successor entity. Users will be notified of such transfers where feasible.

3.5 Aggregated or Anonymized Information

We may disclose information in aggregated or anonymized form that does not identify any individual personally.

3.6 No Sale of Personal Information

Heirly does not sell your personal information, and does not "share" it for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA and comparable U.S. state laws. If this practice changes, we will update this Policy and provide any opt-out mechanism required by law.

4. User Rights and Choices

4.1 Access and Correction

You may request access to and correction of your personal information. We will respond within a reasonable timeframe, and in any event within thirty (30) days (or within the timeframe required by applicable law).

4.2 Deletion

You may request deletion of your account and personal information. Certain information may be retained where necessary to comply with legal obligations, resolve disputes, enforce agreements, or protect legitimate business interests (see Section 5). Retained information will be minimized and stored securely.

4.3 Data Portability

You may request a copy of the personal information you have provided to us in a structured, commonly used, and machine-readable format, and, where technically feasible, ask that it be transmitted to another organization.

4.4 Withdrawal of Consent

You may withdraw consent for specific uses of your personal information, including AI processing, at any time, without affecting the lawfulness of prior processing. Withdrawing consent may limit your ability to use certain features.

4.5 Communication Preferences

You may opt out of non-essential marketing communications by following the unsubscribe instructions in those communications.

4.6 Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your privacy rights.

4.7 How to Exercise Your Rights

Requests may be submitted to info@heirly.co. We will verify your identity before responding, using measures proportionate to the sensitivity of the information. You may use an authorized agent to submit a request where permitted by law. If we decline a request, we will explain why to the extent permitted by law.

4.8 Complaints

If you have a privacy concern, please contact us first. You also have the right to complain to a supervisory authority: in Canada, the Office of the Privacy Commissioner of Canada (and, for Quebec residents, the Commission d'accès à l'information du Québec); in the United States, the California Privacy Protection Agency or your state Attorney General, where applicable.

5. Data Retention

5.1 General Retention Principles

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and protect legitimate interests.

5.2 Specific Retention Periods

  • (a) Account Information: Retained for the duration of your account plus two (2) years following account closure, unless earlier deletion is requested.
  • (b) Transaction Records: Deal room communications, documents, activity logs, and related transaction records are retained for seven (7) years following transaction completion or termination for legal, regulatory, tax, and dispute resolution purposes.
  • (c) Failed Transaction Records: Records relating to transactions that do not proceed to completion are retained for three (3) years following termination.
  • (d) Notifications: Read notifications are automatically deleted after ninety (90) days. Unread notifications are retained until read or account closure.
  • (e) Inactive Accounts: Accounts with no activity for two (2) years will receive ninety (90) days notice before deletion.

5.3 Survival of Retention Obligations

Transaction record retention periods survive account deletion. Upon account closure, personal profile information will be deleted within thirty (30) days, but transaction records required for compliance purposes will be retained for the applicable retention period.

5.4 Secure Deletion

Information that is no longer required will be securely deleted or anonymized in accordance with industry standards.

6. Security and Breach Notification

6.1 Heirly implements technical, administrative, and organizational safeguards appropriate to the sensitivity of personal information, including encryption, multi-factor authentication for administrative access, access controls, and regular security audits.

6.2 Breach Notification. In the event of a breach of security safeguards involving personal information that poses a real risk of significant harm (or that otherwise triggers a legal notification obligation), Heirly will notify affected Users and the applicable regulators without undue delay. This includes, as applicable, the Office of the Privacy Commissioner of Canada under PIPEDA, the Commission d'accès à l'information under Quebec Law 25, and the notifications required under applicable U.S. state breach-notification laws. Heirly maintains a record of breaches as required by law.

7. Data Storage and Cross-Border Transfers

7.1 Heirly operates in Canada and the United States. Your personal information may be stored and processed in Canada, the United States, or other countries where Heirly or its service providers operate. As a result, your information may be subject to the laws of those jurisdictions, including lawful access requests by courts or government authorities.

7.2 Where personal information is transferred across borders, Heirly uses contractual and organizational measures intended to provide a comparable level of protection, including data processing agreements with service providers. You may contact us for more information about our transfer safeguards.

8. Cookies and Tracking

8.1 Heirly uses Cookies and similar technologies as described in the Cookies Policy for authentication, Platform performance, personalization, analytics, and verification purposes.

8.2 Consent is obtained for non-essential Cookies where required by law. Users may manage Cookie preferences via browser settings or platform-provided tools, without affecting essential functionality.

9. Children and Minors

9.1 The Platform is intended for users eighteen (18) years of age or older.

9.2 If we discover that we have inadvertently collected personal information from a person under eighteen (18), such information will be deleted promptly.

10. Third-Party Services

10.1 The Platform may include links or integrations with third-party services. Heirly is not responsible for the privacy practices or content of such services. Users' interactions with third-party services are governed by the privacy policies of those services.

11. Region-Specific Privacy Rights

11.1 Canada (PIPEDA and Quebec Law 25). If you are located in Canada, you have the rights described in Section 4, including the rights to access and correct your personal information, to withdraw consent, to data portability, and to the automated-decision protections in Section 2.3. You may direct any privacy question or complaint to our Privacy Officer (Section 13) and, if unsatisfied, to the Office of the Privacy Commissioner of Canada or, for Quebec residents, the Commission d'accès à l'information du Québec.

11.2 United States (California and other states). If you are a resident of California or another U.S. state with a comprehensive privacy law, you may have the right to:

  • (a) know and access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients;
  • (b) delete personal information, subject to legal exceptions;
  • (c) correct inaccurate personal information;
  • (d) opt out of the "sale" or "sharing" of personal information and of targeted advertising (note: as stated in Section 3.6, Heirly does not sell or share personal information in this sense);
  • (e) limit the use of sensitive personal information to permitted purposes; and
  • (f) not be discriminated or retaliated against for exercising these rights.

We will acknowledge requests and respond within the timeframe required by applicable law (for example, within forty-five (45) calendar days under the CCPA/CPRA, extendable as permitted). You may use an authorized agent to submit a request. To exercise these rights, contact info@heirly.co.

12. Changes to this Privacy Policy

12.1 Heirly may update this Policy from time to time. Material changes will be communicated via email where appropriate and posted on the Platform. Continued use of the Platform after such updates constitutes acceptance of the revised Policy.

13. Contact Information and Privacy Officer

13.1 Heirly has designated a Privacy Officer who is accountable for our compliance with this Policy and applicable privacy laws. For questions, concerns, requests, or complaints regarding this Policy or your personal information, please contact:

  • Heirly Inc. — Attn: Privacy Officer
  • 103-2727 Steeles Ave W, Toronto, ON M3J 3G9, Canada
  • Email: info@heirly.co