1. Scope and accountability
This policy applies to personal information under the control of Panda AI Lab (Canada) Inc. in connection with its websites and operating brands, including Prudentia21 and Shepherd Family Connect. We follow British Columbia's Personal Information Protection Act (“PIPA”) and, where applicable, federal Canadian privacy law.
Panda AI Lab has designated a Privacy Officer responsible for privacy compliance, questions and complaints. Contact details appear in section 19.
2. Our privacy principles
- Collect only information reasonably necessary for identified purposes.
- Explain key uses and disclosures in understandable language.
- Use express consent for sensitive or optional sharing where appropriate.
- Give people meaningful choices and honour withdrawal of consent where legally possible.
- Protect information using safeguards appropriate to its sensitivity.
- Retain identifiable information only as long as reasonably needed for legal or business purposes.
3. Information we may collect
Website and inquiry information
Name, contact details, organization, general reason for contacting us, correspondence, scheduling information and technical information reasonably necessary to deliver and protect the website, such as IP address, browser type, request time and anti-abuse signals.
Prudentia21 business services
Business name, role, team size, technology needs, project descriptions, service choices, contracts, invoices, payment status and information voluntarily provided for a requested service. Payment-card data is handled by the payment provider and is not intended to be stored in our website database.
Shepherd Family Connect
Contact information; confirmation of age eligibility and capacity to consent; scheduling and service preferences; service orders; payment and attendance records; consent choices; authorized information-sharing instructions; an optional emergency contact; limited fit, boundary and safety information; and necessary records of material safety incidents, complaints or legal matters.
4. Shepherd-specific data limits
Shepherd is a non-clinical companionship service. As an operating rule:
- companionship sessions are not audio- or video-recorded;
- we do not create detailed transcripts or clinical-style session notes;
- the website does not request medical histories, diagnoses, medications or crisis narratives;
- ordinary email should not be used to send health records or urgent safety information;
- we keep only limited operational, consent, payment, safety and legally required records; and
- we do not infer a diagnosis or create a clinical profile.
If information outside these limits is voluntarily disclosed during a conversation, that does not change Shepherd into a health-care or crisis service. We will avoid recording unnecessary details and may direct the person to an appropriate professional or emergency resource.
5. Information about another person
A family member, church, community organization or other referral source may provide basic contact or referral information only where it has lawful authority to do so. We seek the prospective participant's own consent before beginning companionship or providing substantive updates. A referral or payment by another person does not transfer the participant's privacy rights.
6. Purposes for collection and use
We may use personal information to:
- respond to an inquiry and arrange an initial conversation;
- confirm eligibility, consent, service fit, boundaries and availability;
- prepare and administer service orders, scheduling, payments and communications;
- provide requested technology, business or companionship services;
- document and respect information-sharing choices;
- maintain continuity without creating detailed conversation records;
- protect participants, personnel, the public and our systems;
- respond to complaints, disputes, suspected fraud or legal claims;
- meet tax, accounting, corporate and other legal obligations; and
- improve services using aggregated or de-identified information where reasonably possible.
We do not use personal information for an unrelated purpose without appropriate notice and consent or other lawful authority.
7. Consent and choice
Consent may be express or implied depending on sensitivity, reasonable expectations and applicable law. We use clear, express choices for optional Shepherd disclosures to family members, payers or referral partners. We do not make optional disclosure consent a condition of receiving companionship.
You may withdraw consent on reasonable notice, subject to legal, contractual and evidentiary restrictions. We will explain material consequences, such as being unable to continue a service that requires certain operational information.
8. When we disclose information
We do not sell personal information. We may disclose limited information:
- to personnel and contractors who need it to perform authorized duties and are subject to confidentiality expectations;
- to hosting, communications, scheduling, payment, security, professional-advisory and other service providers acting for us;
- to a family member, payer, church or referral partner only within the participant's express authorization;
- where reasonably necessary to respond to an immediate and serious safety concern, if permitted by law;
- where required or authorized by law, court order, warrant, regulator or lawful investigation;
- to establish, exercise or defend legal claims, collect a debt or investigate misconduct as permitted by law; or
- in connection with a lawful business transaction, subject to applicable safeguards and notice requirements.
We limit disclosure to what is reasonably necessary for the permitted purpose.
9. Emergency contact and safety disclosures
Providing an emergency contact is optional unless a particular service arrangement reasonably requires one. An emergency contact is not a monitoring service, guardian or substitute decision-maker. Shepherd may contact emergency services or disclose limited information without consent where applicable law permits or requires it, including certain urgent circumstances where consent cannot be obtained in time. Shepherd does not promise that it will detect, assess or prevent a crisis.
10. AI and automated processing
We do not use Shepherd participant personal information, companionship content or service records to train artificial-intelligence models. We do not use automated decision-making to determine Shepherd eligibility or safety actions. If these practices materially change, we will update this policy and obtain consent where required before the new use begins.
11. Service providers and processing locations
We may use providers for cloud hosting, security, video or voice communications, email, scheduling, electronic signatures and payments. Providers may process information outside British Columbia or Canada, where it may be subject to the laws of that jurisdiction. We select and configure providers with regard to the sensitivity and minimum amount of information involved, but no cross-border system can eliminate all risk.
12. Cookies, logs and analytics
The website may use strictly necessary cookies, server logs and anti-abuse technologies needed for delivery, security and fraud prevention. We do not currently describe behavioural advertising or cross-site tracking as part of Shepherd. Before adding non-essential analytics or advertising technologies, we will update our notices and implement any consent mechanism required by law.
13. Retention and destruction
We use retention criteria rather than keeping all information indefinitely. We retain information while it is needed to provide the service, administer consent, meet legal or accounting requirements, resolve disputes, manage safety records or protect legitimate legal interests. Where personal information is used to make a decision that directly affects an individual, it may be retained for at least the period required by applicable law so the individual has a reasonable opportunity to access it.
When the purpose is no longer served and retention is not reasonably necessary for legal or business purposes, we destroy the information or remove identifying links using methods appropriate to the medium. Backup copies may persist temporarily until overwritten through ordinary secure cycles.
14. Safeguards
We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, which may include role-based access, confidentiality expectations, account security, encrypted transport, managed infrastructure, limited collection, secure disposal and vendor review. No organization can guarantee absolute security, and email and text messaging carry inherent risks.
15. Privacy incidents
We maintain a process to identify, contain, assess, document and respond to suspected unauthorized access, collection, use, disclosure, loss or disposal. Depending on the circumstances and applicable law, we may notify affected individuals, service providers, law enforcement, insurers or privacy regulators where notification can reduce harm or is legally required.
16. Access, correction and questions
Subject to applicable law and limited exceptions, you may request access to personal information under our control, information about how it has been used and disclosed, and correction of inaccurate information. We may need to verify identity and may withhold information that would reveal another person's information, legal privilege or other protected material.
17. Deletion and withdrawal requests
You may ask us to delete information or withdraw consent. We will comply where required and reasonably possible, but may retain information needed for legal obligations, payment records, safety, fraud prevention, dispute resolution, legal claims or evidence of consent and instructions. Withdrawing required operational consent may mean a service cannot continue.
18. Age and capacity
Shepherd Family Connect V1 is limited to adults age 20 or older who can provide informed consent. The website is not intended to solicit personal information from minors for Shepherd services. If we learn that information was submitted contrary to this rule, we will assess and delete or otherwise handle it as required by law.
19. Privacy contact and complaints
Privacy Officer
Panda AI Lab (Canada) Inc.
contact@pandalab.ai
Shepherd participants may also contact contact@shepherdfamilyconnect.com. Please do not include unnecessary sensitive details in ordinary email. If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia.
20. Changes to this policy
We may update this policy as services, providers or legal requirements change. The effective date identifies the current version. We will provide appropriate notice and obtain new consent before any materially new use or disclosure where required by law.
Legal review status: This operational draft reflects the confirmed minimum-data model and current public regulatory guidance. It is not legal advice or a representation of lawyer approval. Obtain British Columbia privacy counsel review before accepting paid Shepherd participants.