Privacy Policy
How We Handle Your Data
GRW Project ("GRW Project", "we", "us", "our") runs the behavioural analysis platform at grwproject.app. This policy explains what we collect. It explains how we use it. And it explains the rights you have over it.
We are incorporated in Canada. So Canada's federal privacy law covers us. Its full name is the Personal Information Protection and Electronic Documents Act (PIPEDA). Are you in the European Economic Area or the United Kingdom? Then the General Data Protection Regulation (GDPR) applies. Do you live in Illinois? Then the Biometric Information Privacy Act (BIPA) applies.
Special Category: Biometric Data
Biometric Data Processing
Our platform pulls facial landmark geometry from the video you give us. That is 468 points per frame. It also pulls body language classes. Under PIPEDA, BIPA and GDPR Article 9, that counts as biometric data. Biometric data needs explicit, informed consent before we can process it. We ask for it in our Biometric Data Consent Notice. You see that notice before any analysis begins.
What we do NOT do
Legal basis for processing (GDPR): explicit consent. A legal basis is the reason the law allows us to process your data at all. Ours is Article 6(1)(a) and Article 9(2)(a). You may withdraw consent at any time. Close your browser session, or clear your browser's local storage.
BIPA compliance: We tell Illinois residents that we are collecting their facial geometry. They give written electronic consent in our consent modal. That happens before any processing starts. Raw biometric identifiers are the facial landmark points. We do not store them. We do not sell them. We do not license them. Derived behavioural scores are not biometric identifiers under BIPA.
CCPA/CPRA compliance (California): California residents have four rights here. (a) To know what personal information we collect. (b) To ask us to delete personal data. (c) To opt out of the sale or sharing of personal information. (d) Not to be treated worse for using these rights. We do not sell personal information as the CCPA defines it. To use any of these rights, contact info@boostinnovation.ca.
What We Collect
Email address and username when you create an account. We use them to tie your subscription and your report history to you.
The context, focus area and depth you pick before a run. We store them with your session so we can build your report.
The scored analysis results, not the underlying video or raw geometry. We keep them so you can open your report after you leave the page.
Stripe handles payment and billing records. We get a confirmation token and a subscriber record. No raw card data ever touches our servers.
Anonymous group usage data. Pages visited, and how many analyses ran. We use it to improve the platform. It holds nothing that can identify you.
Data Retention
Raw biometric data is the facial landmark coordinates and the body pose keypoints. On the in-browser path it never reaches our servers. It stops existing when your browser session ends. On the server path the uploaded file is held in temporary storage only while the analysis needs it. It is deleted as soon as the analysis finishes. If an upload is abandoned or the run fails, a sweep deletes it within 60 minutes. Raw landmark data is discarded once the report is built.
Derived behavioural scores are the numbers our analysis puts out, such as composure and engagement. We store them with your report. Reports are kept for up to 365 days from creation. After that an automated job deletes them. You can delete any report yourself, at any time, from your report history.
A personal baseline stores summary statistics of your signal patterns across sessions. It exists only if you opt into long-term tracking. We delete it when you delete your account. We also delete it if you withdraw consent.
Anonymised aggregate data feeds our platform-wide percentile benchmarks. It goes in only if you opt into benchmark contribution. We strip every identifying field first. Once pooled, it cannot be traced back to one user.
We keep account data while your account is active. You may delete your account, and all the personal data tied to it, at any time. Do it from your profile settings, or email info@boostinnovation.ca. We process deletion requests within 30 days.
Your Rights
Terms of Service
Conditions of Use
1.Eligibility
You must be at least 18 to use this platform. By using GRW Project you confirm two things. You are of legal age. And you have the authority to accept these terms. You also confirm that everyone whose video you upload has given explicit consent and is at least 18. Do you plan to analyse video of a minor, under 18, in a sport or school setting? Then you confirm you hold verifiable consent from a parent or guardian, as the law requires. That law includes COPPA in the US and GDPR Article 8 in the EU.
2.Permitted Use
GRW Project is a tool for professional assessment. We built it for coaches, HR staff, talent scouts and team leaders. You may analyse video of yourself. You may analyse video of another person only if they gave explicit consent.
You may not use this platform for covert surveillance. You may not analyse a person who has not consented. You may not use it for any purpose your local law forbids. You may not use it to discriminate against people on the basis of a protected characteristic.
3.Subscription and Payment
Subscriptions are billed in Canadian dollars, monthly or yearly. Your subscription gives you unlimited analyses at the tier you bought. It renews on its own unless you cancel before the renewal date. Cancelling takes effect at the end of the current billing period. You keep access through the date you paid for.
4.Accuracy and Limitations
A GRW Project score comes from the behaviour we can see in the video you give us. It is analysis. It is not a clinical diagnosis. Video quality, lighting, camera angle and setting all move the result. You are the one who has to read a score in the right professional context.
We give no warranty that a score is right for any one person. We give no warranty that it fits your purpose or your jurisdiction. Never use a score as the only basis for a decision about a job, health, the law, or safety.
5.Intellectual Property
The software, the algorithms, the report formats and the platform design are the intellectual property of GRW Project. You may not copy any part of the platform. You may not reverse-engineer it. You may not redistribute it. Not without written permission.
6.Limitation of Liability
To the fullest extent the law allows, GRW Project is not liable for indirect damages. The same goes for incidental and consequential damages arising from use of this platform. Our total liability for any claim is capped. The cap is the sum you paid us in the 12 months before the claim.
7.Governing Law
These terms are governed by the law of the Province of Ontario. The federal law of Canada that applies in Ontario also governs them. Disputes are resolved in the courts of Ontario.
8.Changes to These Terms
We may update these terms from time to time. We will email subscribers about any material change. If you keep using the platform after that notice, you accept the change.
Sub-Processors
Third-Party Data Processors
We use the sub-processors below to run the platform. A sub-processor is an outside company that handles data for us. Each one is bound by a data processing agreement and by privacy law.
Account data (email, username, profile fields), subscription records, report metadata
Billing tokens and subscription records only. No raw card data touches our servers.
Application hosting, CDN delivery, serverless function execution
Raw video, audio and transcript text are processed here when the on-device path cannot run. That happens with large clips and unsupported formats. Content is held in memory for the length of the analysis. Modal does not keep it after the run. Only derived statistics come back to GRW to store.
Font file requests, which carry an IP address and a user-agent string. No analysis data is attached.
Want your data removed from a sub-processor? Email info@boostinnovation.ca. We will run the deletion request for you.
Contact & Requests
For privacy requests, data deletion, or legal inquiries: