Privacy Policy

Policy Effective Date: October 16, 2025
Operated by Ian Fitzgerald, Newfoundland and Labrador
Contact: ian@votenl.com

 1. Introduction

VoteNL.com, operated by Ian Fitzgerald in Newfoundland and Labrador, is a blockchain-powered online voting platform designed to enhance voter turnout and security for NL elections. We are committed to protecting your privacy and safeguarding your personal information in compliance with the Personal Health Information Act (PHIA), the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable Canadian privacy laws. This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit voteNL.com, participate in our voting platform, engage with candidate advertising, or inquire about investment opportunities.

2. Information We Collect We collect only the minimum information necessary to provide our services, ensuring secure, accessible e-voting and related functionalities.

2.1 Voting and KYV Verification

• Personal Information: When registering for e-voting via our Know Your Voter (KYV) system, we collect:
  • Government-issued ID details (e.g., NL driver’s license number, limited to eligibility verification).
  • Biometric data (e.g., facial recognition scan, processed locally and not stored).
  • Contact details (e.g., email, optional for voting confirmation).
• Non-Personal Data: Anonymized voting data (e.g., encrypted ballots, zero-knowledge proofs) stored on a secure blockchain ledger (details proprietary, available under NDA).

2.2 Candidate Advertising

• Candidate Information: For candidates using our free or premium advertising features:
  • Name, party affiliation, contact details (e.g., campaign website, email).
  • Profile content (e.g., bio, platform statements, photos, videos).
• Usage Data: Anonymized analytics (e.g., ad clicks, impressions) for premium pay-per-click (PPC) ads.

2.3 Website Visitors and Investors

• General Browsing: Non-identifiable data via cookies (e.g., IP address, browser type, pages visited) to improve site functionality.
• Investor Inquiries: Name, email, and phone number (optional) submitted via contact forms (e.g., NDA requests for STO details).
• Community Polls: Optional participation data (e.g., poll responses, anonymized unless consent provided).

3. How We Use Your Information We use your information solely for the purposes outlined below:

• Voting Services:
  • Verify eligibility via KYV (one-vote-per-person) using zero-knowledge proofs to protect identity.
  • Process encrypted ballots on our proprietary blockchain for secure, auditable voting.
  • Provide vote confirmation receipts (non-revealing, to prevent coercion).
• Candidate Advertising:
  • Display candidate profiles (free or premium) to voters.
  • Track PPC ad performance (anonymized) for billing and analytics.
• Website Operations:
  • Improve user experience (e.g., analytics for site navigation).
  • Respond to inquiries (e.g., investor NDA requests).
• Community Engagement: Analyze anonymized poll responses to inform civic initiatives.
• Legal Compliance: Fulfill obligations under NL Elections Act, PHIA, PIPEDA, and CSA regulations for STO.

4. How We Protect Your Information VoteNL prioritizes data security and privacy through industry-leading practices:

• Zero-Knowledge Proofs (ZKPs): KYV verification uses ZKPs to confirm eligibility without storing personal data. Biometric data is processed locally and discarded post-verification.
• Decentralized Storage: Voter and ad data are hashed and stored off-chain (secure, proprietary method, details under NDA), with only anonymized hashes on the blockchain.
• Encryption: End-to-end encryption for ballots and communications (e.g., AES-256 for data in transit).
• Access Controls: Limited to authorized NL-based staff under strict confidentiality agreements.
• Third-Party Audits: Annual security audits by certified firms to ensure compliance with PHIA/PIPEDA.
• DDoS Protection: Infrastructure safeguarded by advanced cybersecurity measures.
• No PII Retention: Personal identifiable information (PII) is not stored post-verification unless required by law (e.g., Elections NL audits).

5. Information Sharing and Disclosure We do not sell, trade, or share your personal information except as follows:

• Service Providers: Limited sharing with trusted partners (e.g., cloud hosting, audit firms) bound by confidentiality agreements and PHIA/PIPEDA compliance.
• Elections NL: Anonymized voting data shared for audit purposes, per NL Elections Act (s.12).
• Legal Obligations: Disclosure if required by law (e.g., court orders) or to protect VoteNL’s rights.
• Candidate Ads: Public-facing candidate profiles (name, bio, platform) are visible to voters; premium ad analytics are anonymized.
• Investors: NDA-protected data (e.g., blockchain specs) shared post-agreement with verified investors.

6. Data Retention

• Voter Data: KYV verification data (e.g., ID hashes) is retained only for the election cycle, deleted post-audit unless legally required (max 1 year per Elections NL).
• Candidate Data: Profiles and ad content retained for the election cycle, removable upon request.
• Website Data: Cookies/analytics data retained for 6 months; investor inquiry data kept until STO completion (Q2 2026) or request for deletion.
• Deletion Process: Users can request data deletion via privacy@votenl.com, subject to legal retention periods.

7. Your Rights Under PHIA and PIPEDA, you have the right to:

• Access: Request a copy of your personal information held by VoteNL.
• Correct: Update inaccurate data (e.g., candidate profile errors).
• Delete: Request removal of non-essential data (e.g., inquiry details post-STO).
• Opt-Out: Disable cookies or opt out of non-essential analytics via browser settings.
• Contact: Email privacy@votenl.com for requests or complaints. We respond within 30 days.

8. Cookies and Tracking

• Cookies: We use essential cookies for site functionality (e.g., session management) and optional analytics cookies (e.g., for traffic insights). You can disable non-essential cookies via your browser.
• Ad Tracking: Premium candidate ads track anonymized clicks/impressions (no PII linked). Users can opt out of targeted ads via settings on voteNL.com.

9. Third-Party LinksVoteNL.com may link to external sites (e.g., candidate campaign pages). We are not responsible for their privacy practices. Review third-party policies before engaging.

10. Security Token Offering (STO)Investor inquiries via voteNL.com/invest require name and email for NDA processing. Post-NDA, proprietary blockchain and financial data are shared securely. Investor data is retained only until STO completion (Q2 2026) or deletion request.

11. Children’s PrivacyVoteNL.com is not intended for users under 19 (NL’s voting age). We do not knowingly collect data from minors. Contact Ian@votenl.com if you believe we have such data.

12. Changes to This Policy We may update this Privacy Policy to reflect legal or operational changes. Updates will be posted on voteNL.com with the effective date. Significant changes (e.g., new data uses) will notify users via email or site pop-up.

13. Contact Us For questions, data requests, or complaints:
Ian Fitzgerald
Newfoundland and Labrador, Canada
Email: ian@votenl.com
If unresolved, contact NL’s Office of the Information and Privacy Commissioner at oipc.nl.ca.