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Privacy Policy

Last updated: June 1, 2026  ·  DojoOS  ·  Version 1.1

DojoOS is committed to protecting privacy. This Policy explains how we collect, use, disclose, and protect personal information in compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector (Law 25), and other applicable Canadian privacy legislation.

Contents

  1. Who We Are
  2. Scope and Applicability
  3. Information We Collect
  4. How We Use Personal Information
  5. Legal Basis and Consent
  6. Marketing Communications
  7. Disclosure to Third Parties
  8. Third-Party Service Providers
  9. Cross-Border Data Transfers
  10. Data Storage and Residency
  11. Data Security
  12. Data Retention
  13. Your Rights
  14. Breach Notification
  15. SMS and Electronic Communications (CASL)
  16. Cookies and Tracking
  17. Children's Privacy and Sensitive Information
  18. Quebec Residents (Law 25)
  19. Changes to This Policy
  20. Contact and Privacy Officer

1. Who We Are

DojoOS ("AashCo", "we", "us", "our") is a corporation incorporated under the laws of Canada, operating the DojoOS platform. Our principal place of business is in Ontario, Canada.

For purposes of this Policy, AashCo acts as a data controller with respect to information collected directly from platform subscribers (school owners, administrators), and as a data processor with respect to personal information of End Users (members, students, staff) submitted by our subscribers. Subscribers are themselves data controllers in relation to their End Users' personal information.

2. Scope and Applicability

This Privacy Policy applies to personal information collected through: the DojoOS platform (dojoos.ca and related subdomains), our marketing website, email communications, and any other interaction with AashCo in connection with the Service.

This Policy does not apply to third-party websites or services linked from our platform. We encourage you to review their privacy policies independently.

3. Information We Collect

3.1 Account and Subscriber Information

When you create a DojoOS account, we collect:

  • Name and contact information (email address, phone number)
  • Business information (school name, address, business registration details)
  • Billing information (processed and stored by Stripe — AashCo does not store full card numbers)
  • Account credentials (email and cryptographically hashed password)
  • IP address and timestamp recorded at account creation and acceptance of Terms
  • Communications you send to us

3.2 End User Data (Member Data)

Subscribers enter personal information about their members, students, and staff into the platform. This may include:

  • Names, dates of birth, contact information
  • Emergency contact information
  • Belt rank, attendance records, and training history
  • Signed waivers and consent documents
  • Payment and billing information for memberships
  • Photo and video consent records
  • Health information voluntarily provided (e.g., medical notes on waivers) — treated as sensitive personal information subject to heightened protection as described in Section 17

AashCo processes this data on behalf of the subscribing school (our customer). The school is the data controller responsible for obtaining all necessary consents from their members, including parental or guardian consent for minors.

3.3 Usage and Technical Data

  • Log data (IP addresses, browser type, pages visited, timestamps)
  • Device information (operating system, device type)
  • Feature usage analytics (aggregated and anonymized where possible)
  • Error and performance data (processed via Sentry)

4. How We Use Personal Information

PurposeInformation UsedBasis
Providing and operating the DojoOS platformAccount info, End User data, usage dataContract performance
Processing subscription paymentsBilling information, account infoContract performance
Sending transactional service communicationsEmail address, account infoContract performance / legitimate interest
Sending marketing communications (opt-in)Email address, nameConsent (CASL express consent)
Customer supportAccount info, communicationsLegitimate interest
Security, fraud prevention, and abuse detectionLog data, account infoLegitimate interest / legal obligation
Platform improvement and analyticsAggregated, anonymized usage dataLegitimate interest
Legal compliance and enforcement of TermsAs required by applicable lawLegal obligation

We do not sell personal information to third parties. We do not use personal information for advertising, behavioural profiling, or marketing to End Users.

5. Legal Basis and Consent

Under PIPEDA, we collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise. Consent is obtained at account creation through our click-wrap acceptance mechanism, which records the date, time, and IP address of acceptance.

You may withdraw consent at any time by contacting us at hello@dojoos.ca, subject to legal or contractual restrictions. Withdrawal of consent may result in our inability to provide certain or all aspects of the Service.

We collect only the personal information reasonably necessary for the identified purposes (principle of data minimization).

6. Marketing Communications

From time to time, AashCo may send you marketing or promotional communications about DojoOS features, updates, and related services. We will only do so where we have obtained your express consent under CASL or where a business relationship exception applies.

You may unsubscribe from marketing communications at any time by: (a) clicking the unsubscribe link in any marketing email; or (b) contacting us at hello@dojoos.ca. We will process unsubscribe requests within 10 business days as required by CASL. Transactional and service-related communications (invoices, security alerts, service notices) are not subject to marketing opt-out and will continue to be sent while your account is active.

7. Disclosure to Third Parties

We do not sell, trade, or rent personal information to third parties. We may disclose personal information only in the following circumstances:

  • To service providers listed in Section 8 who assist us in operating the platform, under contractual data processing obligations
  • If required by applicable law, court order, regulatory authority, or government authority — we will notify you where legally permitted to do so
  • To protect the rights, property, safety, or security of AashCo, our customers, or the public where disclosure is necessary and proportionate
  • In connection with a merger, acquisition, reorganization, or sale of assets, provided the acquiring party agrees in writing to comply with this Policy and applicable privacy law
  • With your express prior consent for any other purpose

8. Third-Party Service Providers

We engage the following third-party processors to operate the platform. Each operates under a contract that includes data processing obligations consistent with PIPEDA and this Policy:

ProviderPurposeData ProcessedLocation
Supabase / AWSDatabase, authentication, file storage, edge functionsAll platform dataCanada (ca-central-1, Montreal)
Stripe, Inc.Payment processing and subscription billingBilling and payment informationUnited States
Twilio Inc.SMS message deliveryPhone numbers, message contentUnited States
Brevo (Sendinblue SAS)Transactional and service email deliveryEmail addresses, message contentEuropean Union (France)
Mux, Inc.Video hosting and adaptive streamingUploaded video content and playback metadataUnited States
DocusealDigital waiver signing and document storageNames, signatures, consent records, waiver contentCanada (AashCo-operated infrastructure)
Sentry (Functional Software, Inc.)Error monitoring and performance trackingTechnical logs, stack traces, anonymized session dataUnited States
Vercel, Inc.Web application hosting and edge deliveryHTTP request data, IP addressesUnited States / global edge
Upstash, Inc.Rate limiting and request cachingRequest metadata (no personal content)United States
Better StackUptime and infrastructure monitoringService availability metricsEuropean Union

We periodically review our service providers to ensure ongoing compliance with our privacy obligations. If we add or change a material processor, we will update this section and notify subscribers where required.

9. Cross-Border Data Transfers

Several of our service providers listed in Section 8 process data outside Canada, primarily in the United States and the European Union. By using DojoOS, you acknowledge and consent to these cross-border transfers where necessary to provide the Service.

For transfers to US-based processors (Stripe, Twilio, Mux, Sentry, Vercel, Upstash), we rely on the contractual data processing terms and privacy commitments of those providers, which include standard contractual safeguards. For transfers to EU-based processors (Brevo, Better Stack), we rely on the EU's adequacy framework and standard contractual clauses where applicable.

Where required by Quebec Law 25, AashCo conducts a Privacy Impact Assessment (PIA) before transferring personal information outside Quebec to a jurisdiction that does not offer an equivalent level of protection, and implements contractual measures to mitigate the risks identified.

10. Data Storage and Residency

Primary database storage for DojoOS is located in Canada (ca-central-1, Montreal region) on AWS infrastructure managed by Supabase. Docuseal (digital waivers) is self-hosted by AashCo on Canadian infrastructure.

AashCo has specifically selected Canadian data residency for primary storage as a design decision to support compliance with Canadian privacy law and to serve Canadian customers. Application-level backups are retained within the same Canadian region.

11. Data Security

AashCo implements commercially reasonable technical and organizational security measures appropriate to the sensitivity of the personal information we process, including:

  • Encryption of all data in transit using TLS 1.2 or higher
  • Encryption of data at rest on database infrastructure
  • Row-level security (RLS) policies enforcing strict tenant data isolation at the database layer — a school cannot access another school's data
  • Role-based access controls limiting internal staff access to personal data on a need-to-know basis
  • Multi-factor authentication options for administrator accounts
  • Rate limiting and brute-force protection on all authentication endpoints
  • Real-time error and security monitoring via Sentry and Better Stack
  • Cryptographic hashing of passwords (plaintext passwords are never stored)

No method of electronic storage or transmission is completely secure. While we implement strong security practices, we cannot guarantee absolute security against all threats. In the event of a security incident affecting personal information, we will act in accordance with Section 14.

12. Data Retention

We retain personal information only as long as necessary for the purposes described in this Policy or as required by law:

  • Active subscriber accounts: Retained for the duration of the active Subscription
  • Post-termination: Customer Data retained for 90 days to allow data export requests, then permanently deleted
  • Billing and financial records: Retained for 7 years as required by Canadian federal tax law (Income Tax Act)
  • Server and access logs: Retained for 90 days
  • Signed waivers and consent documents: Retained per the subscribing school's instruction and applicable legal minimum retention requirements — schools are responsible for determining appropriate waiver retention periods under their provincial regulations
  • Breach records: Retained as required by PIPEDA regulations (minimum 24 months from date of breach determination)
  • Consent records (CASL): Retained for a minimum of 3 years from the date of consent or last business transaction, as required by CASL

When personal information is no longer required, it is securely deleted or anonymized in a manner that prevents reconstruction.

13. Your Rights

Under PIPEDA and applicable provincial law, individuals whose personal information we hold have the following rights:

  • Access: Request a copy of the personal information we hold about you and an explanation of how it has been used
  • Correction: Request correction of inaccurate, incomplete, or outdated personal information
  • Withdrawal of consent: Withdraw consent to our collection, use, or disclosure of your personal information, subject to legal and contractual limitations
  • Deletion: Request deletion of your personal information where we are not legally required to retain it
  • Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC)

To exercise any of these rights, contact our Privacy Officer at hello@dojoos.ca. We will acknowledge your request within 5 business days and respond substantively within 30 days. We may need to verify your identity before processing your request. There is no charge for access requests unless the request is manifestly unfounded or excessive.

Note for End Users (members/students): If you are a member of a martial arts school using DojoOS, your personal information is controlled by that school. Please contact your school directly to exercise your privacy rights in relation to your membership data. AashCo will cooperate with schools in responding to such requests.

14. Breach Notification

In the event of a privacy breach (unauthorized access, use, disclosure, or loss of personal information), AashCo will:

  • Conduct a prompt internal assessment to determine whether the breach poses a real risk of significant harm to affected individuals
  • Where a real risk of significant harm exists, notify affected individuals as soon as feasible with sufficient information to allow them to take protective steps
  • Notify the Office of the Privacy Commissioner of Canada (OPC) as required by PIPEDA Breach of Security Safeguards Regulations
  • Where the breach involves Quebec residents, notify the Commission d'accès à l'information (CAI) within 72 hours of determining that a confidentiality incident has occurred, as required by Quebec Law 25
  • Notify affected subscribing schools promptly so they can take appropriate action in relation to their End Users
  • Maintain a record of all privacy breaches for a minimum of 24 months as required by PIPEDA regulations

15. SMS and Electronic Communications (CASL)

SMS features within DojoOS are provided in compliance with Canada's Anti-Spam Legislation (CASL). The CASL compliance framework within DojoOS operates as follows:

AashCo's responsibility: AashCo provides the technical infrastructure for sending SMS and email communications and maintains records of platform-level consent. AashCo does not send commercial electronic messages to End Users on its own behalf except where it has independently obtained consent.

Subscriber's responsibility: Subscribing schools are the senders of commercial electronic messages to their members and are solely responsible for:

  • Obtaining and maintaining express or implied consent from all recipients as required by CASL
  • Maintaining records of consent in a form that can be produced if challenged
  • Including proper sender identification in all messages
  • Including a functional unsubscribe mechanism in every commercial electronic message
  • Honouring unsubscribe requests within 10 business days as required by CASL
  • Ensuring messages comply with CASL's content requirements

AashCo provides technical controls within the platform to support CASL compliance. However, legal responsibility for CASL compliance in relation to End User communications rests with the subscribing school as the sender.

16. Cookies and Tracking

DojoOS uses the following limited categories of cookies and similar technologies:

  • Strictly necessary cookies: Required for authentication, session management, and core platform security. These are essential to the operation of the Service and cannot be disabled without impairing functionality.
  • Performance and analytics cookies: Anonymized usage data collected to understand how the platform is used and to improve it. This data does not identify individual users and is not shared with third-party advertising networks.

We do not use advertising cookies, tracking pixels for behavioural advertising, third-party marketing cookies, or cross-site tracking technologies. We do not participate in real-time bidding or targeted advertising ecosystems.

17. Children's Privacy and Sensitive Information

17.1 Children's Data

DojoOS is a business-to-business platform. Schools may enter personal information about minor students (under 18) as part of their membership management. This data is entered and controlled by the subscribing school, which is responsible for obtaining appropriate parental or guardian consent for the collection of minors' personal information under applicable provincial and federal law.

AashCo does not knowingly collect personal information directly from minors. If you believe a minor's personal information has been entered without appropriate parental consent, please contact the school directly, or contact AashCo at hello@dojoos.ca.

17.2 Sensitive Personal Information

Certain categories of personal information require heightened protection under PIPEDA and applicable law, including health information, financial information, and information about minors. Where DojoOS processes sensitive personal information (for example, health notes on waivers), AashCo applies heightened security controls including:

  • Stricter access controls limiting visibility to authorized personnel only
  • Encryption at rest and in transit
  • Audit logging of access to sensitive data fields

Subscribers are responsible for ensuring they have a valid legal basis and appropriate consents for collecting and processing sensitive personal information about their members.

18. Quebec Residents (Law 25)

Quebec's Act respecting the protection of personal information in the private sector (Law 25, also known as Bill 64) imposes additional obligations on organizations handling personal information of Quebec residents. AashCo complies with Law 25 as applicable, including:

  • Privacy by default: AashCo's platform is designed to collect only the personal information necessary for the intended purpose, with the strictest privacy settings as the default
  • Privacy impact assessments (PIAs): AashCo conducts PIAs before implementing new systems or processes that involve personal information of Quebec residents, and before cross-border transfers of such information
  • Breach notification: AashCo notifies the CAI within 72 hours of a confidentiality incident affecting Quebec residents as described in Section 14
  • Automated decision-making: DojoOS does not make automated decisions that produce legal or significant effects on individuals without human review

Quebec residents have the following additional rights under Law 25:

  • Right to de-indexation: The right to request that personal information published online be de-indexed or that its dissemination be stopped where it causes serious injury to the person
  • Right to portability: The right to receive personal information held by AashCo in a structured, commonly used technological format, and to request that it be communicated to another organization where technically feasible
  • Right to contest automated decisions: The right to be informed of and to contest any decision based exclusively on automated processing that produces legal or significant effects

To exercise Law 25 rights, contact our Privacy Officer at hello@dojoos.ca. We will respond within 30 days.

19. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by email at the address associated with your account at least 14 days before the changes take effect. The updated Policy will be posted at dojoos.ca/privacy with a revised "Last updated" date and version number.

Your continued use of the Service after the effective date of changes constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must cancel your Subscription and cease using the Service before the effective date.

20. Contact and Privacy Officer

AashCo has designated a Privacy Officer accountable for our compliance with PIPEDA and applicable provincial privacy law. You may contact the Privacy Officer for any privacy-related inquiry, access request, or complaint:

  • Privacy Officer: DojoOS
  • Email: hello@dojoos.ca
  • Province: Ontario, Canada

If you are not satisfied with our response, you have the right to escalate your complaint to the relevant supervisory authority:

  • Office of the Privacy Commissioner of Canada (OPC): priv.gc.ca · 1-800-282-1376
  • Commission d'accès à l'information du Québec (CAI — Quebec residents): cai.gouv.qc.ca · 1-888-528-7741
  • Office of the Information and Privacy Commissioner of Alberta (OIPC — Alberta residents): oipc.ab.ca
  • Office of the Information and Privacy Commissioner for BC (OIPC — BC residents): oipc.bc.ca
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