Privacy Policy

Fangtooth Analytics Inc., a corporation incorporated under the laws of Ontario, Canada (Business Number: 1001593792) (“Fangtooth”, “Company”, “we”, “us”, or “our”), respects your privacy and is committed to protecting Personal Information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

This Privacy Policy describes how we collect, use, disclose, process, and protect information when you access or use:

• the Website (defined below);
• Fangtooth software applications, including Excel add-ins and related tools;
• AI-enabled functionality provided through Fangtooth; and
• related services, support, and communications (collectively, the “Services”).

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Definitions

a. "AI Content"

• means information, prompts, files, spreadsheets, text, or other content submitted to AI-enabled functionality within the Services (“Inputs”); and
• means analyses, summaries, formulas, recommendations, generated text, or other responses produced by the Services (“Outputs”).

b. "Customer Financial Data"

means spreadsheets, accounting records, trial balances, general ledger exports, financial statements, transactional records, reports, prompts, uploaded files, formulas, and other business or financial data submitted to or processed through the Services.

c. "Personal Information"

means information about an identifiable individual, including information that can directly or indirectly identify a person.

d. "Website"

Refers to Fangtooth Analytics Inc. accessible at: www.fangtooth.tech

2. Privacy Contact

Fangtooth is responsible for Personal Information under its control.

If you have questions about this Privacy Policy, want to access or correct your Personal Information, withdraw consent, or make a privacy complaint, you may contact us at:

Privacy Contact
Fangtooth Analytics Inc.
Email: legal@fangtooth.tech
Subject line: Privacy Request

Fangtooth has a designated Privacy Officer responsible for overseeing privacy compliance.

3. Information We Collect

a. Information You Provide Directly

We may collect Personal Information that you voluntarily provide to us, including:

• name;
• email address;
• business name;
• telephone number;
• account credentials;
• support inquiries;
• demo requests;
• communications with us; and
• billing or subscription-related information.

b. Account and Authentication Information

When you create or access an account, we may collect:

• login credentials (username/user id);
• account identifiers;
• subscription or licensing information;

c. Usage and Diagnostic Information

We may automatically collect limited technical and diagnostic information relating to the operation and security of the Services, including:

• user Identifiers;
• crash reports;
• performance metrics;
• access timestamps; and
• software version information.

Crash reports contain only hashed identifiers for engagement and company names, file names, and timestamp data. Customer Financial Data is never included. Hashing is performed using a random salt unique to each identifier, ensuring that even if crash reports are intercepted, individual engagement or company names cannot be reverse engineered.

4. Customer Financial Data Processing

Fangtooth is designed as a financial analysis and productivity platform that enables users to transform, analyze, retrieve, summarize, and work with Customer Financial Data.

Customer Financial Data may include:

• spreadsheets;
• financial statements;
• accounting exports;
• trial balances;
• transactional records;
• prompts;
• formulas;
• reports; and
• uploaded files.

Fangtooth processes Customer Financial Data locally (on user machines only) for purposes such as:

• transforming and organizing data;
• generating formulas and reports;
• retrieving and analyzing financial information;
• identifying patterns and trends;
• supporting financial analysis workflows;
• generating AI-assisted outputs; and
• enabling user-requested calculations and analyses.

Customers retain all ownership rights in and to Customer Financial Data, Inputs submitted to the Services, and Outputs generated through the Services, subject to any rights applicable under third-party software or AI provider terms.

Except as necessary to provide the Services, comply with applicable law, enforce our agreements, or respond to customer-authorized requests, Fangtooth does not claim ownership of Customer Financial Data or AI Content.

Fangtooth does not intentionally store Customer Financial Data on Fangtooth-controlled servers.

5. Local Processing and Customer-Controlled Infrastructure

Fangtooth is designed to process Customer Financial Data locally on the user’s device wherever possible.

Certain AI-enabled features may utilize cloud infrastructure, AI models, or Services configured and controlled by:

• the customer;
• the customer’s designated cloud service provider; or
• third-party AI providers selected or integrated by the customer.

Fangtooth may facilitate interactions between the Services and customer-managed cloud or AI environments, including environments hosted through providers such as:

• Microsoft Azure

Customers remain responsible for:

• configuring their own cloud environments;
• determining what data is processed through third-party AI systems;
• ensuring appropriate permissions and consents; and
• complying with applicable laws and contractual obligations relating to Customer Financial Data.

6. AI Processing and AI Content

Certain features of the Services may use artificial intelligence (“AI”), machine learning models, optical character recognition, or automated analytical technologies.

When using AI-enabled functionality:

• users may submit Inputs, including prompts, spreadsheets, text, financial data, PDFs, or other content;
• the Services may generate outputs based on those Inputs; and
• AI Content may be processed transiently to provide requested functionality.

AI-generated Outputs are produced automatically and may:

• contain inaccuracies;
• contain omissions;
• produce incomplete or misleading information; or
• require human review and verification.

Users are solely responsible for reviewing Outputs before relying on them.

Fangtooth does not provide accounting, financial, legal, tax, investment, valuation, audit, or other professional advice through AI-generated Outputs.

Unless explicitly disclosed and authorized by the customer, Fangtooth does not use Customer Financial Data or AI Content to train, fine-tune, or improve general-purpose artificial intelligence or machine learning models.

Fangtooth retains all rights, title, and interest in and to the Services, including the underlying software, models, algorithms, interfaces, workflows, and related intellectual property used to provide the Services.

7. Local Processing and Limited Data Retention

Fangtooth is designed to not retain or store Customer Financial Data within Fangtooth-controlled infrastructure.

Unless explicitly enabled by the customer or required to provide specific functionality requested by the user, Customer Financial Data is not transmitted to, stored on, or retained within Fangtooth-controlled servers or infrastructure.

Certain functionality may involve temporary or transient processing through:

• customer-managed cloud infrastructure;
• third-party AI providers configured by the customer;
• local caching;
• temporary memory usage; or
• diagnostic systems required for operation, support, or security purposes.

Fangtooth does not intentionally maintain permanent copies of Customer Financial Data within Fangtooth-controlled infrastructure except where required for:

• legal compliance;
• security;
• fraud prevention;
• troubleshooting;
• customer-requested support; or
• specifically enabled cloud-based features.

Fangtooth personnel do not routinely access Customer Financial Data. Limited access may occur where necessary to provide customer-requested technical support, troubleshoot issues, comply with legal obligations, or maintain the security and integrity of the Services.

8. Excel Integration Permissions

Fangtooth integrates with Microsoft Excel and related Microsoft services.

The Services may require access to:

• spreadsheets;
• workbook contents;
• formulas;
• tables;
• worksheets;
• workbook metadata; and
• user-authorized Microsoft account functionality

for purposes of providing requested features and functionality.

Fangtooth accesses such information solely to provide the Services requested by the user.

Certain features or formulas within the Services may retrieve publicly available or licensed reference data from Fangtooth-controlled infrastructure or third-party data providers, including financial market or currency exchange rate data. These requests are limited to the query needed to return the requested reference data and do not include Customer Financial Data, workbook contents, username, or user ID. Fangtooth may log limited anonymous operational information, such as timestamp and query type.

9. Consent

Fangtooth collects, uses, and discloses Personal Information with consent or as otherwise permitted or required by applicable law. Consent may be express or implied, depending on the sensitivity of the information and the circumstances.

By creating an account, using the Services, connecting data sources, submitting Customer Financial Data, using AI-enabled functionality, or contacting Fangtooth for support, you consent to the collection, use, and disclosure of information as described in this Privacy Policy.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, withdrawing consent may limit our ability to provide some or all the Services.

10. How We Use Information

We may use Personal Information and related data to:

• provide and maintain the Services;
• authenticate users;
• manage subscriptions and licensing;
• provide customer support;
• improve functionality and performance;
• analyze usage trends;
• protect against fraud, abuse, or security threats;
• comply with legal obligations;
• communicate with users regarding updates, security notices, or support matters; and
• develop and improve our products and Services.

We may also use aggregated or anonymized information for analytics, research, security, and product improvement purposes. Except where explicitly authorized by the customer, Fangtooth does not use Customer Financial Data or AI Content for product training, generalized model improvement, or unrelated analytical purposes.

We may also use limited diagnostic, telemetry, and operational information to maintain software reliability, detect security incidents, prevent abuse, and improve system performance.

11. Sharing and Disclosure of Information

We do not sell Personal Information.

We may share information:

• with service providers assisting us in operating the Services;
• with cloud, hosting, authentication, analytics, or AI providers;
• where required by law;
• to protect the rights, security, or property of Fangtooth or others;
• in connection with mergers, acquisitions, or business transfers; or
• with your consent.

Service providers are authorized to process information only as necessary to provide Services to Fangtooth.

Fangtooth currently uses Kinde for authentication and credential management. Kinde may process limited account information, such as username, user ID, and authentication credentials, for the purpose of enabling secure access to the Services.

A current list of significant third-party service providers or sub-processors used to support the Services may be made available upon request.

12. Third-Party AI Systems

Customers may choose to integrate Fangtooth with third-party AI systems, models, or platforms not operated by Fangtooth.

Fangtooth does not control and is not responsible for:

• the operation;
• outputs;
• security;
• availability; or
• privacy practices

of third-party AI systems configured or selected by customers.

Customers are responsible for reviewing the terms, privacy policies, data retention practices, and AI model training policies of third-party AI providers before transmitting Customer Financial Data or AI Content to such systems.

13. Data Retention

We retain Personal Information only as long as reasonably necessary for:

• the purposes described in this Privacy Policy;
• managing accounts and subscriptions;
• legal and regulatory compliance;
• dispute resolution;
• security;
• fraud prevention; and
• enforcement of our agreements.

Retention periods may vary depending on:

• the nature of the information;
• legal obligations;
• operational requirements; and
• customer relationships.

Customer Financial Data and AI Content are retained only where necessary to provide requested functionality, support customer-authorized requests, maintain security, troubleshoot issues, comply with legal obligations, or support customer-enabled cloud-based features. Fangtooth is designed to minimize the storage and retention of Customer Financial Data within Fangtooth-controlled infrastructure.

When information is no longer reasonably required, Fangtooth will delete, anonymize, or securely dispose of it, where feasible and subject to applicable legal, contractual, technical, and backup-related limitations.

14. International Data Transfers

Information processed through the Services may be transferred to or processed in jurisdictions outside Canada, including the United States or other locations where Fangtooth or its service providers operate. Privacy laws in those jurisdictions may differ from Canadian privacy laws, and information may be accessible to courts, law enforcement, national security authorities, or regulators in those jurisdictions.

Where Fangtooth transfers Personal Information to service providers outside Canada, Fangtooth remains responsible for Personal Information under its control and uses contractual, technical, organizational, and other safeguards designed to provide a comparable level of protection.

15. Security Safeguards

Fangtooth uses administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, misuse, or destruction.

Such safeguards may include:

• encryption in transit using TLS where applicable;
• authentication and access controls;
• role-based or least-privilege access principles;
• secure software development and deployment practices;
• logging and monitoring;
• infrastructure security controls;
• customer-controlled infrastructure configurations where supported; and
• security review and incident response procedures.

Fangtooth maintains procedures designed to detect, investigate, and respond to suspected security incidents involving Personal Information.

Where required by applicable law, Fangtooth will notify affected individuals and applicable regulatory authorities of reportable breaches involving Personal Information.

Fangtooth maintains records of breaches of security safeguards as required by law. However, no method of electronic transmission, processing, or storage is completely secure, and Fangtooth cannot guarantee absolute security.

16. Your Privacy Rights

Subject to applicable law, you may have rights to:

• access Personal Information;
• request correction of inaccurate information;
• withdraw consent;
• request deletion of certain information; or
• inquire about our information handling practices.

Deletion requests are permanent and irreversible. Once Fangtooth deletes Personal Information at your request, the information cannot be recovered. Fangtooth does not maintain backups of deleted authentication or account information. Customers are responsible for retaining their own copies of any data they wish to preserve before submitting a deletion request. Deletion of authentication or account information may also result in loss of access to the Services and to any Customer Financial Data, AI Content, or local data dependent on that account.

Requests may be submitted using the contact information below.

We will respond to privacy requests within a reasonable time and in accordance with applicable law. In some cases, we may not be able to provide access to certain information, such as where disclosure would reveal confidential commercial information, disclose another individual’s Personal Information, compromise security, interfere with an investigation or legal proceeding, or be prohibited by law.

If we determine that Personal Information is inaccurate or incomplete, we will correct it where appropriate. Customers remain responsible for ensuring the accuracy of Customer Financial Data submitted to or processed through the Services.

Fangtooth may need to verify your identity before responding to a request.

17. Children’s Privacy

The Services are not intended for individuals under the age of 16, and Fangtooth does not knowingly collect Personal Information from children under 16.

18. Third-Party Websites

The Services may contain links to third-party websites or services.

Fangtooth is not responsible for the privacy practices or content of third-party services. Users should review the privacy policies applicable to those third-party services.

19. Quebec Privacy Rights

If you are located in Quebec, additional rights and requirements may apply under Quebec privacy laws, including the Act respecting the protection of Personal Information in the private sector, as amended.

Subject to applicable law, Quebec residents may have additional rights regarding their Personal Information, including rights relating to access, correction, withdrawal of consent, de-indexing, data portability, and information about automated processing or transfers outside Quebec.

Where required by Quebec privacy laws, Fangtooth will provide additional information about its privacy practices and respond to Quebec privacy requests in accordance with applicable legal requirements.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

For material changes, Fangtooth will endeavour to provide reasonable advance notice to active subscribers, which may be provided by email, through the Website, or through the Services.

Updates to this Privacy Policy will be posted on the Website with a revised “Last Updated” date.

Continued use of the Services after the revised Privacy Policy becomes effective constitutes your acceptance of the updated Privacy Policy. If you do not agree to the revised Privacy Policy, you should discontinue use of the Services.

21. Contact Us

If you have questions regarding this Privacy Policy or our privacy practices, you may contact us at legal@fangtooth.tech.

If you have a concern or complaint about Fangtooth’s privacy practices, you may contact us with the subject line “Privacy Complaint.”

Fangtooth will review privacy complaints, investigate where appropriate, and respond within a reasonable time. We may contact you for additional information if needed to understand or resolve your complaint.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada or another applicable privacy regulator.