Privacy Policy

Sowa Answers is a product of Lesniak Advisory, a sole proprietorship registered in the Province of Ontario, Canada (Ontario BIN 1001490274), with its registered business address at London, Ontario, Canada. The legal entity responsible for the Sowa Answers service — the website, AI receptionist, call and SMS handling, dashboard, and related features — is Lesniak Advisory. For the purposes of this Privacy Policy, "we," "us," and "our" refer to Lesniak Advisoryin its capacity as operator of Sowa Answers, and references to "Sowa Answers" identify the product offered to customers.

We are accountable for the personal information under our control. We have designated a person responsible for our compliance with this policy and with applicable privacy law:

Privacy Officer: the founder of Lesniak Advisory, reachable at privacy@sowaanswers.com, or by mail at London, Ontario, Canada.

The Privacy Officer handles access and correction requests, consent withdrawals, privacy questions, and complaints. We follow the fair-information principles below in everything we do with personal information.

We handle personal information according to the fair-information principles in PIPEDA:

• Accountability — we are responsible for the personal information in our care, overseen by our Privacy Officer (above).
• Identifying purposes— we tell you why we collect information, as described in "What We Collect" and "How We Use It."
• Consent — we collect, use, and disclose personal information with your knowledge and consent, except where the law allows otherwise.
• Limiting collection — we collect only what we need to run the service.
• Limiting use, disclosure, and retention— we use and keep information only for the purposes described here and only as long as needed (see "Retention & Security").
• Accuracy — we keep personal information as accurate and up to date as is necessary, and you can ask us to correct it.
• Safeguards— we protect information with appropriate security measures (see "Retention & Security").
• Openness — this policy makes our practices available to you.
• Individual access— you can ask what we hold about you and request a copy (see "Your Rights").
• Challenging compliance— you can challenge our handling of your information with our Privacy Officer, and escalate to a regulator (see "Your Rights Under Provincial & Federal Law").

We collect information from two groups of people:

From our customers (business owners who sign up for Sowa Answers): email address, name, business name, phone number, business address, booking link, business hours, a free-trial payment method via Stripe, subscription status, dashboard login events, and preferences you set in the dashboard (notification choices, conversion strategy, transfer phone, training URLs).

From callers and SMS senderscontacting your Sowa number: the caller's phone number, a real-time transcript of what was said, an AI-generated summary and tags, any appointment or contact details the caller shares, and any SMS content you and the caller exchange through the Sowa number. This content is stored in your dashboard so you can follow up.

When a caller reaches a phone number connected to Sowa, the AI receptionist speaks a short disclosure at the start of the call so the caller is informed that:

• they are speaking with an AI assistant, not a human;
• the call is being transcribed; and
• the call content is shared with the business owner through the Sowa dashboard.

Transcripts and AI-generated summaries are stored in your account's Sowa dashboard. Call audio is processed in real time to produce the transcript and is not retained. AI summaries and urgency tags are produced automatically and may contain mistakes; owners review them before acting. If you operate in a jurisdiction that requires all-party consent, you are responsible for understanding and complying with that requirement in how you publish your phone number and receive calls.

Caller choice.Because callers are told at the start of the call that they are speaking with an AI assistant and that the call is being transcribed, a caller who does not want to continue on those terms may decline — for example, by hanging up and reaching the business another way, or by asking to be contacted by a person. This gives callers a meaningful choice about whether to proceed, consistent with PIPEDA's consent requirements.

We use a small number of trusted vendors ("sub-processors") to run the service. They handle personal information on our behalf under contract, only as needed to provide the service. By function, they are:

• AI conversation— a large-language-model provider that receives call transcripts to generate the receptionist's real-time responses, with a fallback provider for availability.
• Speech processing — speech-to-text transcription and text-to-speech voice synthesis for live calls.
• Voice & telephony — real-time call orchestration/transport and a telephony carrier that handles inbound calls and SMS (phone numbers, call and message metadata, and audio in transit).
• Hosting & database — application hosting and the database/authentication/storage that holds your account data, caller contact records, and transcripts (Canadian regions — see below).
• Payments — a payment processor for subscription billing and tax calculation (payment details and billing address).
• Operations — transactional email delivery, application error monitoring (configured to exclude call content), and bot protection on public-facing forms.
• Website chat — an assistant on our marketing website only; it does not receive call audio, transcripts, or any data from inbound calls.

We do not use call audio, transcripts, or message content to train shared / third-party AI models; our sub-processor agreements prohibit that use. A current list of our named sub-processors is available to customers on request — email privacy@sowaanswers.com.

Our database is hosted exclusively in a Canadian region (ca-central-1), and our application servers run in Montreal (yul1). Persistent customer data does not leave Canada.

Some real-time processing sub-processors — those handling AI conversation, speech-to-text, text-to-speech, and telephony — operate primarily in the United States or on global edge networks. This means call audio in transit, transcription data, and real-time conversation data may pass through US-based infrastructure. By using Sowa Answers, you acknowledge this. We contractually require each sub-processor to apply security and confidentiality safeguards at least equivalent to what we describe in this policy.

If you have concerns about cross-border data handling for a specific deployment, email us at privacy@sowaanswers.com and we will tell you which regions apply to your account.

Sowa Answers is Canadian-operated. We handle personal information in line with applicable Canadian law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) federally, and provincial privacy legislation where applicable, including Quebec's Act respecting the protection of personal information in the private sector (Law 25), Alberta's Personal Information Protection Act (PIPA), and British Columbia's PIPA. Where a customer or caller shares health information that falls under Ontario's Personal Health Information Protection Act (PHIPA) or another provincial health privacy statute, the customer remains the health-information custodian and we act only as an information manager / electronic service provider for that customer.

Commercial electronic messages we send (account, billing, and onboarding emails) follow Canada's Anti-Spam Legislation (CASL): every message identifies us, includes a Canadian mailing address, and gives you a way to unsubscribe.

We collect, use and disclose personal information for the purposes described in this policy, or with your consent, or as otherwise permitted or required by law.

If you are a Quebec resident, additional rights apply under Quebec's Law 25. In addition to the rights described elsewhere in this policy, you may:

• access the personal information we hold about you;
• have inaccurate, incomplete, or out-of-date information corrected (rectification);
• withdraw your consent to our use of your personal information;
• receive the computerized personal information you have provided in a structured, commonly used technological format (data portability); and
• request that we stop disseminating your personal information, or that a hyperlink giving access to it be de-indexed, where the law allows.

If a confidentiality incident occurs that poses a risk of serious injury, we will take reasonable steps to reduce the risk, and we will notify the affected individuals and the Commission d'accès à l'information du Québec (CAI) as required. You may also make a complaint to the CAI about how we handle your personal information.

You can challenge our handling of your personal information at any time by contacting our Privacy Officer at privacy@sowaanswers.com. If you are not satisfied with our response, you may escalate to the relevant regulator:

• the Office of the Privacy Commissioner of Canada (OPC) under PIPEDA;
• the Commission d'accès à l'information du Québec (CAI) if you are in Quebec;
• the Office of the Information and Privacy Commissioner of Alberta or of British Columbia if you are in those provinces (provincial PIPA).

If we become aware of a breach of our security safeguards involving personal information, we will assess the breach, take reasonable steps to contain and mitigate it, and keep a record of it.

Where a breach poses a real risk of significant harm to affected individuals (PIPEDA) or a risk of serious injury (Quebec Law 25), we will notify the affected individuals and the relevant regulator — the Office of the Privacy Commissioner of Canada and, for Quebec residents, the Commission d'accès à l'information — as soon as feasible, as required by law.

We retain your data for as long as your account is active and afterwards only as needed for legal, accounting, security, and legitimate-interest reasons. Approximate retention windows:

• Account profile — kept while the account is active. On closure, deleted or anonymized within 90 days, except where we must retain billing/tax records by law.
• Call transcripts, summaries, and message history— kept for the life of the account so you can search your inbox. You can request earlier deletion (see "Your Rights").
• Billing and tax records — retained for up to seven (7) years as required by Canadian tax law.
• Operational logs (call events, webhook deliveries, push/SMS delivery receipts) — typically up to 12 months.

We protect data with access controls, row-level security at the database layer, TLS in transit, encryption at rest by our hosting providers, rate limiting on public endpoints, restricted admin surfaces, and an incident-response runbook.

You may ask us to:

• confirm what personal information we hold about you;
• correct inaccurate personal information;
• provide a copy of your personal information in a readable format;
• delete your personal information, subject to our retention obligations (e.g. billing records required by law); and
• withdraw consent where we rely on consent.

If you are a caller or SMS sender (not an account holder) and you want a business to delete the record of your call or message, contact the business owner first — they control the account. If you cannot reach them, contact us at privacy@sowaanswers.com and we will help mediate.

To exercise a right, email privacy@sowaanswers.com from the address associated with your account (or include information that lets us verify you). We will respond within a reasonable time, generally within 30 days. Our use of your data is also subject to our Terms of Service.

Our website uses cookies and similar technologies for two purposes: to keep you signed in and to operate the dashboard, and to understand how visitors use our marketing site so we can improve it. For website analytics and advertising measurement we use Google services (Google Analytics and Google Ads conversion measurement), which set cookies in your browser.

You can block or delete cookies through your browser settings. Analytics and advertising cookies are not used inside call handling or the AI receptionist — they apply to website visits only.

Questions about this policy or your data? Use our contact form or email us at privacy@sowaanswers.com. For other legal inquiries, email legal@sowaanswers.com.

Operator / data controller: Lesniak Advisory, a business registered in Ontario, Canada (the legal entity behind the Sowa Answers product).
Data subject rights and requests: direct to Lesniak Advisory via the Privacy contact email above.
Mailing address: London, Ontario, Canada.
GST/HST Registration No. 706569969 RT0001.