Privacy Policy

Portage is an independent AI-powered study tool for the Canadian citizenship test. This policy explains what personal information we collect, why we collect it, and how we protect it.

Our designated privacy contact is reachable at hello@portageprep.ca. All privacy requests — access, correction, deletion, complaints — are handled within 30 days, as required by PIPEDA. Where a request is complex or requires us to search older records, we may extend by up to a further 30 days as permitted by PIPEDA section 8(3), and we will tell you why.

• Account information. Your email address, and any display name you choose to add.
• Quiz activity. Questions you've seen, the answers you gave, your scores, and your mastery progress. This is the data the adaptive engine reads from to decide what to show you next.
• Chat conversations. If you use the AI study assistant (a paid-plan feature), the messages you send and the assistant's replies are stored under your account so the assistant can refer back to earlier turns within the same conversation. You can start a fresh conversation from the chat panel at any time, which permanently deletes the prior conversation from our servers; any remaining chat history is deleted when you delete your account.
• Payment information. We never see or store your card number. Card payments are handled by a third-party payment processor; we keep only a subscription reference and plan status.
• Usage data. Only if you accept analytics: page views, feature interactions, and session events such as practice scores — linked to a random account ID, never your email — used to understand what works and what to improve (see §7).
• Voluntary feedback. Any comments, bug reports, or reports about a quiz question or flash card that you submit in the app.
• Access logs. Standard server logs — IP address, request path, response code, timestamp — kept for security, abuse detection, and operational monitoring (see §9 for retention).
• Sign-in history. The IP addresses and browser/device descriptions your account has been used from, with when each was first and last seen — used to spot account abuse, and to show you your recent devices (not their IP addresses) under Recent sign-ins in Settings (see §9 for retention).
• Error reports. When something crashes, a report with technical details only — the error type, page URL, and browser environment — is captured, linked to a random account ID rather than your email. Email addresses and sign-in tokens are removed before a report is sent, and reports do not contain your answers, chat messages, or personal study data.

We do not collect your legal name (unless you provide it), phone number, mailing address, date of birth, immigration status, government ID, or any biometric data.

• To run the service. Your quiz history is what powers the adaptive recommendations.
• To handle billing. To manage your subscription and process payments.
• To improve Portage. Aggregate patterns help us write better questions and fix rough edges.
• To communicate with you. Transactional messages only — account confirmations, billing receipts, and important service notices. We do not send marketing emails without your explicit consent, as required by Canada's Anti-Spam Legislation (CASL).

Portage uses third-party AI providers — a large-language-model provider, and a search provider that finds the passages of our study material related to a question — for two purposes:

• Evaluating open-ended quiz answers and generating explanations of why a wrong answer is wrong. When you submit an open-ended response, the text is sent to our language-model provider for evaluation.
• Powering the AI study assistant (available on paid plans). When you message the assistant, your message together with a short window of prior conversation history is sent to our language-model provider so it can answer in context, and your message is also sent to our search provider to find the passages of our study material that answer it. The assistant is also unavailable while you have a timed practice test in progress — so it can't be used as an answer-lookup tool mid-test.

We use these providers under API terms and account settings under which submitted content is not used to train their models. Each provider may keep submitted content for a limited time under its own retention policy (for example, to detect abuse) before deleting it. We will tell users if a change to those terms materially affects this commitment. Our system also takes reasonable steps to mask personal data the model might echo back, as an extra safety layer.

Please do not include sensitive personal details (immigration file numbers, social insurance numbers, etc.) in your free-text quiz answers or chat messages — they aren't needed and they don't help the model do its job.

We use a small number of established third-party services to run the platform. Each is contractually bound to process your data only as we direct, consistent with applicable privacy laws. The categories of processor are:

• Payment processor — for card payments and subscription billing.
• AI providers — for question evaluation, explanations, and the chat assistant (see §4).
• Email delivery — for sending transactional messages (account confirmations, billing receipts), for delivering the feedback you send us — its text and, if you are signed in, your email address — to our team's inbox, and for our replies to it, which quote what you sent us.
• Hosting & storage — for running the web app and storing study material.
• Identity & database — for authentication and storage of account, quiz, and progress data.
• Product analytics — for measuring aggregate feature usage, loaded only with your consent (see §7).
• Error monitoring — for capturing crash and exception reports.

We do not sell your data to any third party, ever. We do not share it with advertisers or data brokers.

Portage uses an adaptive engine to decide which concept and question to show you next. The decision is based on your past answers, your mastery scores per topic, your selected test date, and how recently you've seen each question. No human reviews the choice; it is fully automated.

The consequence of an adaptive-engine decision is limited to which question appears next in your study session. The engine does not make decisions about your subscription, eligibility, or any other significant outcome for you. You can override it at any time by choosing a specific topic to study.

Separately, simpler rule-based gates in the app — such as paywall checks that grant or deny access to paid features based on your current subscription state, or the counter that enforces the free-tier monthly question limit — also run automatically. These read your subscription and usage data and apply the rules described in the Terms of Service.

If you'd like to understand why the engine picked a particular concept for you, email hello@portageprep.ca and we'll walk you through it.

Local storage. Portage uses your browser's local storage to remember practical things — your interface language, light/dark theme preference, recent session state. These values live only on your device and never leave it. Clearing your browser's site data resets them.

Cookies. We use cookies that are essential to keep you signed in and to protect against abuse, together with the analytics-layer cookies described below. We do not use third-party advertising cookies, retargeting pixels, or social-media trackers.

Analytics. We use a third-party product-analytics provider, processed in the United States (see §8), to measure aggregate usage — which features are used, where users get stuck — to improve the product. Analytics events are linked to a random account ID, never your email address; we do not record your screen or sessions, and we do not capture the text of what you click. It is used only to improve Portage; we do not use it for advertising and we do not share it with advertising networks. Analytics runs only with your consent. The first time you visit, a banner lets you accept or decline, and the analytics provider loads nothing — no script, network request, or cookie — until you accept. If you decline, ignore the banner, or your browser sends a Global Privacy Control or Do Not Track signal, no analytics load at all — a Global Privacy Control or Do Not Track signal overrides even an earlier acceptance. You can change your choice at any time with the Manage cookie preferences button at the bottom of this page, the Cookie preferences link in the site footer, or the analytics switch under Privacy & data in Settings. You may also block analytics with a browser extension (e.g., uBlock Origin) or email us at hello@portageprep.ca.

If you are a Quebec resident, Quebec's Law 25 may grant you additional consent rights regarding cookies and tracking technologies — see §10 (Your rights).

Some of our service providers operate from outside Canada — primarily the United States. By using Portage, your personal information may be transferred to and processed in countries whose privacy laws differ from those of your province or territory.

We work only with providers that maintain industry-standard data protection through contractual safeguards. Once data is outside Canada, it may, however, be subject to lawful access by the authorities of the host country.

• Account data is retained for as long as your account is active.
• Chat conversations are retained until you start a fresh conversation (which permanently deletes the prior one from our servers) or delete your account.
• Account deletion. When you delete your account (from Settings, or by emailing us), it enters a 14-day grace period during which signing back in restores access. After the grace period expires, our purge process permanently removes your personal data — email, quiz history, chat history, progress — promptly on its next run, so the total time from your deletion request to full removal stays within 30 days.
• Email tombstone. After deletion, we keep a short one-way hash of your email address for a brief cooldown period to prevent immediate re-registration with the same address. The tombstone cannot reasonably be reversed into your original email.
• Access logs (IP, request path, timestamp) are retained only for a limited operational window for security and operational monitoring, then pruned in line with our hosting provider's standard log-retention policy.
• Sign-in history (IP address and browser/device description) is kept to show you recent sign-ins and to spot account abuse; each entry is deleted 180 days after it was last seen. The most recent IP address is kept with your account and erased after 180 days without activity, or when the account is deleted.
• Billing records may be retained for up to 7 years as required by tax and financial regulations, even after account deletion. These records do not include your card number.
• Anonymised, aggregated data (e.g., overall question difficulty statistics) may be retained for as long as it remains de-identified and cannot be linked back to you.

Under PIPEDA, you have the right to:

• Access the personal information we hold about you. You can request a structured export by emailing us.
• Correct any inaccurate information.
• Delete your account and all associated personal data — from Settings, or by emailing us.
• Withdraw consent at any time by closing your account. Note that withdrawing consent means you can no longer use Portage, since the data above is what makes the service work.
• Lodge a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca if you believe your rights have been violated. (Yes, we'd rather you talk to us first — but this right exists under PIPEDA whether we mention it or not, and we'd rather you know.)

Additional rights for Quebec residents. If you live in Quebec, the Act respecting the protection of personal information in the private sector (Law 25, CQLR ch. P-39.1) gives you additional rights — including the right to data portability (a copy of your data in a structured, commonly used format), the right to be forgotten in certain circumstances, and the right to be informed about automated decisions affecting you (see §6). Residents of Alberta and British Columbia have similar rights under their provincial private-sector privacy statutes (PIPA Alberta and PIPA BC).

To exercise any of these rights, email hello@portageprep.ca. We respond within 30 days, with a possible extension of up to a further 30 days where permitted by PIPEDA section 8(3) (we will tell you why if we use it).

All traffic between your device and Portage is encrypted in transit (HTTPS). Passwords are never stored in plain text — they are hashed using industry-standard methods. Per-user access controls are designed to prevent any user from reading another user's data. Sensitive operations are throttled to prevent abuse, and we monitor for anomalous activity.

No system is perfect, however. If we ever experience a data breach that poses a real risk of significant harm, we will notify affected users and report the incident to the Office of the Privacy Commissioner of Canada as required by PIPEDA's Breach of Security Safeguards Regulations.

Portage is built for adults. Our Terms of Service require you to be at least 18 to create an account. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, please contact hello@portageprep.ca and we will delete it.

• We will never sell your personal information.
• We will never share your personal information with advertisers, ad networks, or data brokers.
• We will never share your data with Immigration, Refugees and Citizenship Canada (IRCC) or any other government agency, except where required by valid Canadian legal process.
• We will never knowingly allow our AI providers to use your chat messages or quiz answers to train their models, and our agreements with the providers must reflect that commitment.
• We will never share your quiz answers, progress, or chat history with any other Portage user.

If we ever change one of these commitments, we will tell you in advance under §15 (Changes to this policy) — not bury it in a Terms update.

If Portage is acquired, merged, or otherwise reorganised, your information may be transferred to the successor entity as part of the transaction. The successor will be required to handle your data subject to this Policy, and we will notify you in advance of any material changes to how your data is handled. You will have the option to delete your account before any such change takes effect.

If we make material changes, we will notify you by email or in-app notice at least 14 days before they take effect. The "Last updated" date at the top of this page always reflects the most recent version.

Portage provides this policy in English and in French. In case of conflict between the two versions, the English version governs — except for Quebec-resident users, for whom the French version is provided and governs, as required by Quebec's Charter of the French Language and applicable consumer-protection law.