This Privacy Policy explains how The Molly Project ("we," "us") collects, uses, and protects personal information in connection with the SBILT prototype (mollyproject.io). It is intended to comply with Quebec's Act respecting the protection of personal information in the private sector (Law 25) and the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

01 / Identity

Who We Are & Privacy Officer

The Molly Project is a Quebec-based research initiative developing AI-powered interview training tools.

The person responsible for the protection of personal information (responsable de la protection des renseignements personnels) as required by Law 25 is:

Louis Vaillancourt

Email: info@mollyproject.io

Location: Quebec, Canada

02 / Collection

What We Collect & Why

2.1 Access Request Form

When you submit a tester access request on our website, we collect your email address. It is used solely to respond to your request and, if approved, to send you access credentials. Your email is stored on our server (OVH Canada, Beauharnois QC) and sent to our team via our own mail relay. We do not use it for marketing without your explicit consent.

2.2 Session Interaction Logs

When you use the SBILT prototype, your practice conversations are recorded in anonymous session logs stored on our server. These contain: conversation text, timestamps, random session identifiers (not linked to your identity), and interaction metrics (rapport scores, ORBIT quadrant data). These logs are used to evaluate and improve the tool for research purposes.

2.3 Server Logs

Our web server automatically records standard technical data including IP addresses, browser type, and access times. This is retained for 30 days for security and diagnostic purposes and is not used to identify you personally.

2.4 Authentication Credentials

Access to the SBILT prototype requires a username and password issued by us. Credentials are stored in encrypted form on our server. Authentication attempts are not logged beyond standard security monitoring.

03 / Retention

How Long We Keep Your Information

Type Retention Period
Email addresses (access requests)Until the research phase concludes, or upon your deletion request
Session interaction logsUp to 12 months, then anonymized or deleted
Server access logs (IP addresses)30 days
Authentication credentialsUntil access is revoked or the prototype is discontinued

04 / Third Parties

Who We Share Your Information With

We do not sell or rent your personal information. We share it only with the following service providers as necessary to operate this prototype:

  • OVH Canada Inc. (Beauharnois, Québec) — Provides server hosting. Your data is stored in Quebec, Canada.
  • OpenRouter, Inc. & Google LLC (United States) — AI inference providers used to generate persona responses and coaching feedback. During practice sessions your conversation content is transmitted to OpenRouter, which routes it to Google's Gemini model; this AI processing takes place on servers outside Canada (United States).
  • Zoho Corporation (Canada) — Hosts our team email mailbox (info@mollyproject.io) in its Canadian data centre (Toronto, Ontario). Access-request notifications are sent from our Québec server and delivered to this Canadian mailbox; this email does not leave Canada.
  • Anthropic PBC (United States) — Provides the AI assistant (Claude) our team uses for development and tuning. Anonymized practice transcripts (random session identifiers, not linked to your identity) may be reviewed via Claude to evaluate and improve the tool. Identifiable personal information is not shared for this purpose.

05 / Cross-Border Transfers

Transfers Outside Quebec

Your account data and session logs are hosted in Canada (OVH, Beauharnois QC). Our use of AI involves two distinct cross-border activities, both currently taking place in the United States: (1) real-time inference — during practice sessions your conversation content is transferred to OpenRouter, Inc. and Google LLC (US) to generate persona responses and coaching feedback; and (2) development and tuning — anonymized practice transcripts may be reviewed via Anthropic PBC (US) to evaluate and improve the tool. Email notifications are sent from our Québec server and delivered to our team mailbox hosted by Zoho in Canada (Toronto, Ontario), remaining within Canada. We are actively working to bring both AI activities onto Canadian infrastructure. Personal information is transferred only to the extent necessary to operate the prototype.

This is an early-stage prototype offered only to a small group of invited testers, who are informed of these data flows in advance. We rely on our providers' standard data-processing terms for these cross-border transfers and are working to formalise our assessment under Quebec Law 25 as the project matures. If you have any questions or concerns about how your information is handled, please contact us at info@mollyproject.io before using the prototype.

06 / Your Rights

Your Rights Under Law 25 & PIPEDA

You have the right to:

  • Access the personal information we hold about you
  • Correct inaccurate or incomplete information
  • Request deletion of your personal information (subject to legal retention obligations)
  • Withdraw consent at any time, which may affect your ability to use the service
  • Data portability — request a copy of information you provided, in a structured, commonly used format
  • File a complaint with the Commission d'accès à l'information du Québec (CAI) at cai.gouv.qc.ca, or the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca

To exercise any of these rights, contact info@mollyproject.io. We will respond within 30 days.

07 / AI & Automated Processing

Automated Decision-Making

The SBILT prototype uses artificial intelligence — Google's Gemini model, accessed via OpenRouter, Inc. (United States) — to generate persona responses and coaching feedback during practice sessions. This AI processing:

  • Is used solely for educational and training purposes
  • Does not make decisions with legal or significant consequences affecting you
  • Does not create profiles used to determine access to services

No automated profiling is used to make decisions that affect your rights.

08 / Security

Security Measures

We take reasonable technical and organizational measures to protect your personal information, including:

  • HTTPS encryption for all web traffic (TLS via Let's Encrypt)
  • Password-protected access to the prototype (credentials stored in encrypted form)
  • Server hosted in a Canadian data centre (OVH, Beauharnois, Québec)
  • Brute-force protection and firewall hardening on the server

In the event of a confidentiality incident presenting a risk of serious injury, we will notify the Commission d'accès à l'information and affected individuals as required by Quebec Law 25.

09 / Cookies

Cookies & Tracking

The SBILT prototype does not use tracking cookies or advertising technologies. The practice sessions use browser memory (sessionStorage) to maintain your current session — this is not a tracking cookie and is cleared when you close the tab.

10 / Updates

Changes to This Policy

We may update this policy as the prototype evolves. The revised policy will be posted on this page with an updated date. We encourage you to review it periodically.

11 / Contact

Questions & Rights Requests

For any privacy questions, rights requests, or concerns:

Louis Vaillancourt

Privacy contact: info@mollyproject.io

Website: mollyproject.io

Regulatory authority: Commission d'accès à l'information du Québec (CAI) — cai.gouv.qc.ca