Privacy Policy
How We Handle Your Data
GRW Project ("GRW Project", "we", "us", "our") operates the behavioural analysis platform at grwproject.app. This privacy policy explains what information we collect, how we use it, and what rights you have over it.
We are incorporated in Canada and subject to the Personal Information Protection and Electronic Documents Act (PIPEDA). Where users are located in the European Economic Area or United Kingdom, the General Data Protection Regulation (GDPR) applies. Where users are Illinois residents, the Biometric Information Privacy Act (BIPA) applies.
Special Category — Biometric Data
Biometric Data Processing
Our platform extracts facial landmark geometry (468 landmarks per frame) and body language classifications from video you provide. Under PIPEDA, BIPA, and GDPR Article 9, this constitutes biometric data and requires explicit, informed consent before processing. We obtain this consent through our Biometric Data Consent Notice, shown before any analysis begins.
What we do NOT do
Legal basis for processing (GDPR): Explicit consent (Article 6(1)(a) and Article 9(2)(a)). You may withdraw consent at any time by closing your browser session or clearing your browser's local storage.
BIPA compliance: Illinois residents are notified that their facial geometry data is being collected and provide written electronic consent before processing begins via our consent modal. Raw biometric identifiers (facial landmark coordinates) are not stored, sold, or licensed. Derived behavioural scores are not considered biometric identifiers under BIPA.
CCPA/CPRA compliance (California): California residents have the right to: (a) know what personal information is collected, (b) request deletion of personal data, (c) opt out of the sale or sharing of personal information, and (d) non-discrimination for exercising these rights. We do not sell personal information as defined under the CCPA. To exercise any of these rights, contact info@boostinnovation.ca.
What We Collect
Email address and username when you create an account. Required to associate your subscription and report history.
The context settings, focus area, and depth parameters you select before running an analysis. Stored with your session to generate your report.
The scored analysis results (not the underlying video or raw geometry). Retained so you can access your report after leaving the page.
Payment and billing records are handled by Stripe. We receive a confirmation token and subscriber record only — no raw card data ever touches our servers.
Anonymous aggregate usage data (pages visited, analysis count) to improve the platform. No personally identifiable information is included.
Data Retention
Raw biometric data (facial landmark coordinates, body pose keypoints) is processed in-browser and never stored on our servers. It ceases to exist when your browser session ends. For server-processed sessions, video frames are ephemeral (never written to disk) and raw landmark data is discarded after report generation.
Derived behavioural scores (the numerical outputs of our analysis, such as composure and engagement scores) are stored with your report. Reports are retained for up to 365 days from creation, after which an automated retention job deletes them. You can also delete individual reports at any time from your report history.
Personal baselines (if you opt into longitudinal tracking) store statistical summaries of your signal patterns across sessions. This data is deleted when you delete your account or withdraw consent.
Anonymised aggregate data (if you opt into benchmark contribution) is stripped of all identifying information and contributes to platform-wide percentile benchmarks. Once aggregated, this data cannot be attributed to individual users.
Account data is retained while your account is active. You may delete your account and all associated personal data at any time from your profile settings or by contacting info@boostinnovation.ca. Deletion requests are processed within 30 days.
Your Rights
Terms of Service
Conditions of Use
1.Eligibility
You must be at least 18 years old to use this platform. By using GRW Project, you represent that you are of legal age and have the authority to enter into these terms. You also represent that any individuals whose video you upload for analysis have given explicit consent and are at least 18 years of age. If you are analyzing video of minors (under 18) in a sports or educational context, you represent that you have obtained verifiable parental or guardian consent in compliance with applicable law (including COPPA for US users and GDPR Article 8 for EU users).
2.Permitted Use
GRW Project is a professional assessment tool for coaches, HR professionals, talent evaluators, and organizational leaders. You may use the platform to analyze video of yourself or of individuals who have given explicit consent to be analyzed.
You may not use this platform for: covert surveillance, analyzing individuals without their consent, any purpose prohibited by law in your jurisdiction, or to discriminate against individuals on the basis of protected characteristics.
3.Subscription and Payment
Subscriptions are billed in Canadian dollars (CAD) on a monthly or annual basis. Your subscription provides unlimited analyses at the tier level purchased. Subscriptions auto-renew unless cancelled before the renewal date. Cancellation takes effect at the end of the current billing period — you retain access through the date you paid for.
4.Accuracy and Limitations
GRW Project scores are based on observed behavioural signals in the video provided. They are analytical tools, not clinical diagnoses. Results are influenced by video quality, lighting, camera angle, and the context of the footage. You are responsible for interpreting scores within appropriate professional context.
We make no warranty that scores are accurate for any specific individual, purpose, or jurisdiction. Do not use these scores as the sole basis for employment, medical, legal, or safety decisions.
5.Intellectual Property
All software, algorithms, report formats, and platform design are the intellectual property of GRW Project. You may not copy, reverse-engineer, or redistribute any part of the platform without written permission.
6.Limitation of Liability
To the maximum extent permitted by law, GRW Project shall not be liable for any indirect, incidental, or consequential damages arising from use of this platform. Our total liability for any claim shall not exceed the amount paid by you in the 12 months preceding the claim.
7.Governing Law
These terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein. Any disputes shall be resolved in the courts of Ontario.
8.Changes to These Terms
We may update these terms from time to time. Material changes will be communicated to subscribers by email. Continued use after notice constitutes acceptance.
Sub-Processors
Third-Party Data Processors
We use the following sub-processors to operate the platform. Each is subject to data processing agreements and applicable privacy law.
Account data (email, username, profile fields), subscription records, report metadata
Billing confirmation tokens and subscription records only — no raw card data touches our servers
Application hosting, CDN delivery, serverless function execution
Raw video, audio, and transcript text are processed transiently when the on-device path is unavailable (large clips, unsupported codecs, opt-in cardiovascular extraction). Content is held in memory only for the duration of analysis and is not persisted on Modal infrastructure post-completion. Only derived statistical features return to GRW for storage.
Font file requests (IP address, user-agent). No personal data associated with analysis.
To request removal of your data from any sub-processor, contact info@boostinnovation.ca and we will coordinate the deletion request on your behalf.
Contact & Requests
For privacy requests, data deletion, or legal inquiries: