Privacy Policy

Effective Date: March 22, 2026

Enabled HR Labs Inc. ("we," "our," or "us") operates the PowerSpeak mobile application (the "App") and the website at www.powerspeak.app (the "Site"). This Privacy Policy explains what personal information we collect, how we use and protect it, and your rights regarding that information.

This policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec Law 25, Ontario's Personal Health Information Protection Act (PHIPA) where applicable, the U.S. Children's Online Privacy Protection Act (COPPA), and Apple App Store requirements.

By downloading or using PowerSpeak, you agree to the practices described in this policy. If you do not agree, please do not use the App.

1. Who This Policy Applies To

This policy applies to:

Users who download and use the App, including caregivers, parents, speech-language pathologists (SLPs), and institutional administrators

Individuals whose communication profiles are created within the App, including children and adults with disabilities

Visitors to our website

Because PowerSpeak serves individuals with autism, ALS, speech delays, acquired communication disabilities, and related conditions, including many who are minors, we apply heightened care to all data handling practices.

2. Information We Collect

Information you provide directly:

Email address, if you sign up for updates or create an account

Name and contact details for caregiver, SLP, or institutional accounts

Communication vocabulary, symbol sets, and board configurations created within the App

Messages sent to us through support or contact channels

Information collected automatically:

Device type, operating system version, and app version

Anonymous usage data such as feature interactions and session duration

Crash logs and diagnostic reports used to identify technical issues

IP address, which may be collected by our hosting or analytics infrastructure

We do not collect: audio recordings, voice data, biometric identifiers, precise geolocation, or government-issued identifiers. We collect only the information necessary to provide and improve the App.

3. Sensitive Personal Information

Communication disability status, health conditions such as ALS or autism, and AAC usage patterns may constitute sensitive personal information or personal health information under Canadian law.

We collect this information only as necessary to provide the App's core communication support functions. We treat all such information with the highest level of protection and do not use it for any secondary purpose without explicit, informed consent.

For users in Quebec, we obtain explicit consent before collecting or using sensitive personal information, as required by Law 25.

4. Children's Privacy (COPPA and Canadian Law)

PowerSpeak is designed in part for use by children, including children with autism, speech delays, and related communication needs. We take children's privacy very seriously and comply with both U.S. and Canadian law in this area.

For users in Canada: Under PIPEDA and Quebec Law 25, we do not collect personal information from minors under the age of 14 (Quebec) or 13 (other provinces) without the verifiable consent of a parent or person with parental authority. The App is designed to be set up and managed by a parent, caregiver, or SLP on behalf of the child.

For users in the United States: PowerSpeak is subject to the U.S. Children's Online Privacy Protection Act (COPPA) and the 2024 COPPA Rule amendments. We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. Consistent with COPPA requirements:

We do not collect biometric identifiers, government-issued identifiers, geolocation data, or audio recordings from children

We do not share children's personal information with third parties for advertising or marketing purposes

Parents may request access to, correction of, or deletion of their child's information by contacting us at jeby@enabledtalent.com

Parents may revoke consent at any time; upon revocation we will delete the child's information promptly

If you believe we have inadvertently collected personal information from a child without appropriate parental consent, please contact us immediately at jeby@enabledtalent.com and we will delete it without delay.

5. How We Use Your Information

We use the information we collect to:

Operate, maintain, and improve the App and its features

Respond to support and account requests

Send product updates or communications you have opted into

Analyze anonymous usage patterns to prioritize development

Detect and address technical issues and security incidents

Comply with applicable legal obligations

We do not sell your personal information. We do not use your information for advertising. We do not use your information for any purpose other than those stated above without your express consent.

Under PIPEDA's accountability principle, we are responsible for personal information in our possession, including information transferred to third-party processors. We require all service providers to maintain standards of protection equivalent to our own.

7. How We Share Your Information

We share personal information only in limited, defined circumstances:

Service providers: We use third-party providers for cloud hosting, analytics, and email services. These providers act under our instructions and are contractually prohibited from using your information for any other purpose.

Apple: Information necessary for App Store distribution is shared with Apple under Apple's own privacy terms.

Legal requirements: We may disclose information when required by law, court order, or regulatory authority, or when necessary to protect our rights or the safety of users.

Business transfers: If we are involved in a merger, acquisition, or sale of assets, user information may be transferred. We will notify you of any such change and the choices available to you.

We do not disclose personal information to third parties for advertising, marketing, or data brokerage purposes.

8. Data Retention

We retain personal information only as long as necessary for the purposes for which it was collected, or as required by law. When information is no longer needed, we securely delete or anonymize it.

You may request deletion of your account and associated data at any time by contacting jeby@enabledtalent.com. We will process deletion requests within 30 days unless we are required by law to retain the information for a longer period.

9. Data Storage and Cross-Border Transfers

Your information may be stored and processed in Canada or in other countries where our service providers operate, including the United States. By using the App, you consent to this transfer and storage.

For users in Quebec, we inform you that your personal information may be communicated outside of Quebec. We ensure that any such transfer is governed by contractual protections that meet the standards required by Law 25 and PIPEDA.

We use industry-standard security measures including encryption in transit, access controls, and secure server infrastructure.

10. Security and Breach Notification

We implement and maintain administrative, technical, and physical safeguards to protect personal information against unauthorized access, loss, alteration, or disclosure.

In the event of a privacy breach that poses a real risk of significant harm, we will:

Notify the Office of the Privacy Commissioner of Canada as required under PIPEDA's mandatory breach reporting rules

Notify affected individuals as required by law

Notify the Commission d'acces a l'information (CAI) in Quebec as required by Law 25

Maintain a record of all privacy breaches as required

No method of data transmission or storage can be guaranteed to be 100% secure. You provide your information at your own risk, but we take all reasonable steps to minimize that risk.

11. Your Rights

Depending on where you are located, you have the following rights regarding your personal information:

Access: You may request a copy of the personal information we hold about you.

Correction: You may request that inaccurate or incomplete information be corrected.

Deletion: You may request that your personal information be deleted, subject to legal retention requirements.

Withdrawal of consent: You may withdraw consent to certain uses of your information at any time.

Data portability (Quebec residents): You may request your personal information in a structured, commonly used format.

Objection to automated decision-making (Quebec residents): You have the right to challenge decisions made solely by automated means.

To exercise any of these rights, contact us at jeby@enabledtalent.com. We will respond to access or correction requests within 30 days. We will not charge a fee for a first request unless it is excessive or unreasonable.

You may also file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca, or with the CAI in Quebec at cai.gouv.qc.ca.

12. Privacy Officer

In accordance with PIPEDA's accountability principle and Quebec Law 25, we have designated a Privacy Officer responsible for our compliance with applicable privacy laws.

Privacy Officer: Enabled HR Labs Inc. / PowerSpeak

Email: jeby@enabledtalent.com

Website: www.powerspeak.app

14. Apple App Store

PowerSpeak is distributed through the Apple App Store. Apple's own privacy practices are governed by Apple's Privacy Policy. We are responsible for our data practices and not for Apple's. This privacy policy is accessible within the App and at our website as required by Apple's App Store Review Guidelines.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated policy on our website at www.powerspeak.app with a revised effective date. For material changes, we will provide notice through the App or by email where we have your contact information. Continued use of the App after changes are posted constitutes acceptance of the updated policy.

16. Contact Us

For questions, concerns, or to exercise your privacy rights:

Enabled HR Labs Inc.

PowerSpeak Privacy

Email: jeby@enabledtalent.com

Website: www.powerspeak.app