Privacy Policy

Effective date: January 26, 2026

1. Introduction And Scope

16445039 Canada Inc., doing business as “Onix” (“Onix”, “us”, “our”, or “we”), is committed to maintaining the confidentiality and security of your personal information, as defined in the Definition of “Personal Information” section. This Privacy Policy (the “Policy”) describes our practices regarding the collection, use, disclosure, and protection of your personal information, and outlines the choices available to you with respect to that information.

This Policy applies to:

Individuals who register for and maintain an account on our platform (the “Onix Platform”) for the purpose of creating an expert AI (“creators”).
Individuals who register for or maintain an account on the Onix Platform to interact with expert AIs (“participants”).
Individuals who otherwise contact us or interact with us, including through our websites at onixai.ai and any other websites and mobile application operated by us where this Privacy Policy is posted (the “Website”), whether for informational purposes or to apply for a professional opportunity with Onix.

2. Definition Of “Personal Information”

In this Policy, “personal information” means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name or email address, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual, such as your IP address and details about how you use the Onix Platform or Website (pages viewed, language preferences, time spent, etc.).

3. Personal Information We Collect

The personal information we collect about you depends on the nature of your interactions with Onix (e.g., if you are a creator, participant, Website visitor, etc.). Below is a description of the personal information we may collect about you.

Information we collect about creators

When you use our services to create a creator account on our Onix Platform and develop an expert AI for your subscribers, we may collect the following information about you:

Account information. When you create an account on the Onix Platform, we collect information associated with your account directly from you, including your email address, which serves as your user ID and as a means to receive a one-time password to access the Onix Platform.
Creator content. To create your expert AI, we collect information directly from you about your skills, expertise, qualifications, experience, and any other relevant details. This also includes any content you upload or otherwise share with us, such as files, images, videos, and audio.
Technical information. We automatically collect information about how you interact with the Onix Platform (for example, actions taken within the Onix Platform, settings, and preferences), as well as general technical information about the means you use to access the Onix Platform such as your IP address, the type and version of your browser, and your device identifier. See the Cookies section below for more information on how we use cookies to collect your personal information.

We do not currently collect or process financial information through the Platform. If we introduce payment features in the future, transactions will be processed by a third-party payment processor, and we will update this Privacy Policy accordingly.

Information we collect about participants

When you use our services to register and maintain an account on the Onix Platform and to interact with and subscribe to an expert AI, we may collect the following information directly from you:

Account information. When you create an account on the Onix Platform, we collect information associated with your account, including your email address, which serves as your user ID and as a means to receive a one-time password to access the Onix Platform.
Participant content and information. You may provide input to the expert AIs available on the Onix Platform, including through your prompts, other content you upload (such as files, images, videos, and audio, depending on the features that you use) or other information you provide (including health-related information). If you choose to connect the Onix app with the Apple HealthKit, the app may request access to certain health data made available through HealthKit. We process this information solely to transform it using privacy-protective techniques designed to prevent it from being reasonably associated with you.
Technical information. We automatically collect information about how you interact with the Onix Platform (for example, actions taken within the Onix Platform, settings, and preferences), as well as general technical information about the means you use to access the Onix Platform such as your IP address, the type and version of your browser, and device identifier. See the Cookies section below for more information on how we use cookies to collect your personal information.

Information we collect about visitors of our Website or if you contact us

We may collect the following information from you when you visit our Website, including when you apply for a professional opportunity at Onix through our Website:

Communication information. When you communicate with a member of our team via email or telephone, we may collect your contact information, the contents of the messages you share with us, and any other information that you choose to provide.
Professional information we collect if you apply for a professional opportunity with Onix. This includes information you provide directly in your CV (such as information on your professional experiences, education history, and the contact information of your referrals if you apply for an opportunity with Onix through our website). We may also receive this information from third parties if you apply for an opportunity with Onix through a third-party platform (e.g., LinkedIn or Indeed).
Technical information. We automatically collect information about when you visit our Website, including the IP address and domain used to access our Website, the pages you visit and the time spent on each page, the website you came from to access our Website, and the type and version of your browser. See the Cookies section below for more information on how we use cookies to collect your personal information.

4. Use Of Personal Information

We may use your personal information to operate our business, including delivering our services, managing our Website and Onix Platform, and mitigating commercial risks. More specifically, Onix may use your personal information for the following purposes:

Providing our services. We may use your personal information to deliver our services, including developing and training expert AIs at the request of creators, making those expert AIs available to participants on the Onix Platform, and managing participant subscriptions.
Improving our services. We may use your personal information to improve and develop our services and conduct research, for example, to develop new features for the Onix Platform.

However, the information a creator provides about their expertise or background is used solely to train and develop that creator’s expert AI and will not be used to train any other creator’s expert AI. In addition, we only use information participants include in their prompts to train our AI models (including the expert AIs available on the Onix Platform) with the participants’ consent, for example if we request explicit participant feedback on model performance or if an individual decides to participate in beta testing of the Onix Platform.

Managing our Website and Onix Platform. We may use your personal information to administer and facilitate the use of our Website and Onix Platform, which may include the use of cookies and other similar technologies to analyze and monitor the performance of our Website and Onix Platform, and for other related purposes. See the Cookies section below for more information on how we use cookies.
Communicating with you. If you contact us with a question or inquiry, we may use your personal information to respond to you. We may also use your personal information to send you updates, newsletters, offers, and promotions using your email address. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt out of receiving marketing communications by contacting us using the contact information provided in the Contact Us section below. Please note that you may continue to receive transactional or account-related communications from us.
Evaluating your application. We may use the information you provide us with as part of your application for a professional opportunity with Onix when considering and responding to your application and assessing your suitability for current and future professional opportunities.
For other purposes permitted or required by law. We may use personal information without your consent where we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights or property of Onix or to enforce or apply agreements, or to detect, prevent, and investigate suspicious, unauthorized, fraudulent, illegal, or unlawful activity.

We may also modify or aggregate your personal information to generate anonymized data that cannot reasonably be associated with you. We do this to protect your privacy and the security of your information, and to use the anonymized data to conduct research and analytics, identify usage trends, make improvements to the Website, the Onix Platform, our AI models, and our products and services, and develop new offerings.

5. Disclosure Of Personal Information

We do not share your personal information with third parties without your consent, except as set forth below or as required or permitted by applicable law.

Service providers. We may share your personal information with third parties that provide services on our behalf, such as delivering compliance management, mobile app distribution, product analytics, website hosting, access to and use of AI large language models (LLMs), and data storage. Onix will protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures.
Legal and compliance. We may provide your personal information in response to a search warrant or other legally valid inquiry or order such as subpoenas or court orders, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, protecting the rights, employees or property of Onix, collecting a debt owed to Onix, or as otherwise may be required or permitted by applicable law. Your personal information may also be shared where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Business transactions. We may share your personal information with relevant third parties in connection with a business transaction to facilitate or enable any corporate or commercial transaction involving Onix to the extent permitted by applicable law.

6. Cookies

We use cookies, web beacons (including pixels and tags), and similar technologies on our Website that collect certain information about you by automated means.

We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes IP address, device ID, and other identifiers associated with your device, device type, device characteristics (such as operating system), the pages you visited on the Site, the date and time of your visit, the referring URLs you came from, and other information about your online activities.

We use certain tools that use cookies and similar technologies for the purpose of conducting analytics and monitoring errors on our Website. For example, we use Cloudflare Web Analytics to collect information about visits to our Website, such as pages viewed, referring URLs, and general information about the device and browser used to access the site. This information is used solely to understand how our Website is used and to improve its performance and content. Cloudflare Web Analytics is designed to operate without the use of cookies or similar tracking technologies and does not require the identification of individual visitors. Data collected through this service is processed by Cloudflare in accordance with its own privacy practices.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Note, however, that without cookies, you may not be able to use all of the features of our Website. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

7. Third-Party Links

Our Website and Onix Platform may contain links to other websites that Onix does not own or operate. We provide links to third-party websites as a convenience to the participants, creators, and website visitors. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

8. Cross-Border Transfers

We may transfer your personal information to our service providers who may process it outside of Quebec or Canada, including in Canada and the European Union. As a result, when your personal information is used or stored in a jurisdiction other than where you reside, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

9. How We Protect Personal Information

Onix endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, or disclosure. For example, if the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures are in place. In addition, we have a designated Privacy Officer to monitor Onix’s compliance with applicable privacy laws.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access, use or sharing of your personal information using the contact information provided in our Contact Us section.

10. Retention Of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which the information was collected. However, we may retain your personal information for a longer period when required to comply with our legal and regulatory obligations regarding information or record retention.

11. Children’s Privacy

The Website and Onix Platform are not directed to individuals under the age of 16. We do not knowingly collect or solicit personal information from individuals under the age of 16 through the Website or Onix Platform. If we become aware that we have collected personal information from an individual under the age of 16 through the Website or Onix Platform, we will promptly delete the information from our records. If you believe that an individual under the age of 16 may have provided us with personal information, contact us as specified in the Contact Us section of this Policy.

12. Your Rights

Under privacy laws applicable in the jurisdiction in which you reside, you may have the following rights with respect to your personal information, subject to limited exceptions set out in such laws:

Right to information. You have the right to ask us about our processing of your personal information, including about the categories of persons who have access to your personal information within Onix and the applicable retention period.
Right to access. You can ask us if we hold any personal information about you, and if so, you can request access to that personal information. Depending on the laws applicable in the jurisdiction in which you reside, you may have the right to ask us to communicate to you the personal information you have provided us in a structured, commonly used technological format, as well as to a third party upon your request.
Right to correction. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. You have the right to ask us to rectify any personal information that you demonstrate to be incorrect or outdated and to complete any information that you demonstrate to be incomplete.
Right to withdraw consent. You may withdraw your consent to our processing of your personal information to the extent permitted by law and our contractual obligations. However, you understand that in such a case, you may no longer be able to benefit from our services.

To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section below. Note that we may request certain personal information for the purpose of verifying the identity of the individual seeking to exercise their privacy rights.

13. Updates To This Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above and may be amended from time to time at Onix’s sole discretion. We recommend that you periodically review this Policy as it may be updated or revised from time to time. If we make material changes, we will take reasonable steps to notify you of those changes, including by posting the revised Policy on our Website with adequate notice.

14. Contact Us

If you have any questions regarding this Policy or our processing of your personal information, please contact our Privacy Officer in writing at the following email address: privacy@onixai.ai.