Privacy Policy.

THM Coaching Ltd., operating as Graphite Automation (“we,” “us,” or “our”), is committed to protecting your personal information. This Privacy Policy explains what information we collect through our website at graphiteautomation.com, why we collect it, how we use it, and your rights regarding that information.

We are based in Vancouver, British Columbia, and comply with Canada’s Personal Information Protection and Electronic Documents Act(PIPEDA) and British Columbia’s Personal Information Protection Act (PIPA).

1. What we collect.

Information you provide

• Meeting bookings — When you book a call through our Cal.com scheduling widget, we collect your name, email address, and any information you include in the booking form.
• Newsletter signup — When you subscribe to our newsletter, we collect your email address.

Information collected automatically

• Analytics data — We use Google Analytics 4 (GA4) to understand how visitors use our site. This collects IP addresses, device and browser information, pages visited, and interaction data.
• Advertising data — We use the Meta Pixel (Facebook) to measure the effectiveness of our advertising. This collects browsing activity and interaction data on our site.
• Tag management — We use Google Tag Manager (GTM) to manage the analytics and advertising tags listed above.

2. Why we collect it.

• To schedule meetings — Your name and email allow us to confirm and manage bookings.
• To send our newsletter — Your email address allows us to send you updates about AI automation, consulting insights, and our services. You can unsubscribe at any time.
• To understand site usage — Analytics data helps us improve our website and content.
• To measure advertising — Advertising data helps us understand how people find our site and whether our ads are effective.

3. Consent.

Canadian privacy law is evolving rapidly. Current PIPEDA violations carry fines up to C$100,000, and the upcoming Consumer Privacy Protection Act (CPPA) will increase penalties to C$25 million or 4% of global revenue. We take these obligations seriously and design our data practices to exceed current requirements.

We obtain your consent before collecting personal information:

• Cookies and tracking — When you first visit our site, we ask for your consent before loading analytics or advertising cookies. You can accept or decline non-essential cookies. Essential cookies required for the site to function do not require consent.
• Newsletter— By submitting the newsletter signup form, you provide express consent to receive commercial electronic messages from us in accordance with Canada’s Anti-Spam Legislation (CASL).
• Meeting bookings — By submitting a booking request, you consent to us using your information to schedule and manage the meeting.

You can withdraw consent at any time by contacting us at privacy@graphiteautomation.com, or by using the unsubscribe link included in every newsletter.

4. Cookies and tracking technologies.

Analytics and advertising cookies are only loaded after you provide consent. You can change your cookie preferences at any time using the cookie settings on our site.

5. Third-party services.

We share personal information with the following third-party services:

• Cal.com — Scheduling platform for meeting bookings
• Google — Analytics (GA4) and tag management (GTM)
• Meta — Advertising measurement (Meta Pixel)

Each of these services operates under its own privacy policy. We encourage you to review their policies.

A note on AI tools: When we use AI APIs (such as OpenAI or Anthropic) in our consulting work, we use the enterprise API tier, which by default does not use your data for model training — this is contractually guaranteed by each provider. This is distinct from consumer-facing products like ChatGPT Free, where data may be used for training. Your business data is never used to train AI models.

6. Storage and cross-border transfers.

Some of the third-party services we use store and process data outside of Canada, including in the United States. This means your personal information may be accessible to law enforcement and national security authorities in those jurisdictions under their laws.

By consenting to our collection of your information, you acknowledge this cross-border transfer.

7. How long we keep your information.

• Meeting booking data — Retained for the duration of any business relationship, plus 2 years.
• Newsletter subscriptions — Retained until you unsubscribe, plus a reasonable period to process the request.
• Analytics and advertising data — Retained according to the default retention settings of each platform (typically 14 months for GA4).

8. Your rights.

Under PIPEDA and BC PIPA, you have the right to:

• Access your personal information we hold
• Correct inaccurate personal information
• Withdraw consent for any collection, use, or disclosure
• Request deletion of your personal information

To exercise any of these rights, email us at privacy@graphiteautomation.com. We will respond within 30 business days.

9. Data breaches.

In the event of a breach of personal information that creates a real risk of significant harm, we will notify affected individuals and the Office of the Information and Privacy Commissioner for British Columbia (OIPC) as required by law.

10. Complaints.

If you have concerns about how we handle your personal information, please contact us first at privacy@graphiteautomation.com.

If you are not satisfied with our response, you may file a complaint with:

• Office of the Information and Privacy Commissioner for BC (OIPC) — oipc.bc.ca
• Office of the Privacy Commissioner of Canada (OPC) — priv.gc.ca

11. Changes to this policy.

We may update this policy from time to time. Changes will be posted on this page with a revised “last updated” date. We encourage you to review this page periodically.

12. Contact.

THM Coaching Ltd. o/a Graphite Automation
Vancouver, British Columbia, Canada

privacy@graphiteautomation.com