Global Privacy Policy & Data Governance

Effective Date: March 17, 2026  |  Last Updated: April 28, 2026

Privacy Officer: information@ireferclub.com  |  Jurisdiction: Innisfil, Ontario, Canada

1. Introduction & Accountability

The IRefer Club is dedicated to safeguarding the data integrity of our small business clients and our Affiliate Champions. We act as the Data Controller for the information utilized across our Strategic Blueprint. Our approach to privacy is built on the foundation of transparency, ensuring that every Digital Handshake is secure, verified, and compliant with global standards.

2. Information Architecture: What We Collect

We collect only the essential data required to maintain the C.A.I.T.L.Y.N. Core Infrastructure and manage our global referral grid:

• Account InfrastructureLegal name, verified business entity, email, and primary contact number.
• Affiliate Leadership DataSocial media identifiers (for professional verification), tax identification (where mandated for executive payouts), and organizational referral history.
• Financial Transaction DataAll payments are processed via high-security third-party processors including Stripe. The IRefer Club does not store raw credit card data on its internal servers.
• Technical Grid DataIP addresses and device identifiers collected via secure tokens to ensure the accuracy of the 6-level and 9-level commission architecture.

3. Lawful Basis for Processing (GDPR/PIPEDA/CCPA)

• Contractual NecessityTo execute the Digital Handshake services purchased by business subscribers and to fulfill commission obligations to our Champions.
• ConsentFor professional communications and grid updates, which may be withdrawn at any time via your Champion Dashboard.
• Legitimate InterestsTo maintain the security of the global grid, prevent systemic fraud, and optimize GEO performance for our members.

4. Global Data Rights & Sovereignty

• Right to AccessRequest a comprehensive audit of the data held within your profile.
• Right to ErasureRequest the permanent removal of your Digital Anchor and personal identifiers.
• Right to RectificationEnsure your professional information is accurate and current.
• Right to PortabilityRequest your data in a machine-readable format for transition to other systems.
• Non-DiscriminationWe do not sell or rent user data. We prioritize the "Privacy by Design" standard in all grid expansions.

5. Security, Retention & Breach Protocol

• EncryptionWe implement industry-leading SSL/TLS encryption for all data in transit.
• RetentionFinancial records are maintained for 7 years to comply with Canadian and US tax regulations. Standard account data is retained only as long as the Digital Anchor remains active.
• Incident ResponseIn the event of a data compromise, we commit to notifying affected users and relevant authorities within 72 hours.

Privacy inquiries: information@ireferclub.com