PRIVACY POLICY

PRIVACY POLICY
SOP COMMAND™

This Privacy Policy describes how Victory Hour Multimedia Inc. ("SOP Command™", "we", "our", "us") collects, uses, and protects information in connection with the SOP Command™ compliance operations platform at sopcommand.com.

Effective Date: May 2026  ·  Last Updated: May 2026  ·  Governing Law: Ontario, Canada (PIPEDA)  ·  Company: Victory Hour Multimedia Inc., Windsor, Ontario, Canada
TABLE OF CONTENTS
SECTION 1
🏢WHO WE ARE
COMPANY INFORMATION
Legal Name: Victory Hour Multimedia Inc.
Operating As: SOP Command™
Location: Windsor, Ontario, Canada
Website: sopcommand.com
Privacy Contact: info@victoryhourmedia.com
Applicable Law: Personal Information Protection and Electronic Documents Act (PIPEDA), Canada; Ontario privacy legislation

SOP Command™ is a B2B compliance documentation platform serving regulated industries in Canada, the United States, and internationally. We are committed to protecting the privacy of our users in accordance with Canadian federal privacy law (PIPEDA) and applicable provincial legislation.

SECTION 2
📊WHAT INFORMATION WE COLLECT

We collect minimal information and only what is necessary to provide the service. Here is a complete and transparent breakdown:

2A — INFORMATION YOU VOLUNTARILY PROVIDE
Lead capture form (optional): If you choose to provide your name, company name, and email address before generating your first SOP, we collect that information. This is always optional — you can skip it. This information is used to send you a copy of your generated document and relevant compliance resources.
Compliance Assessment form (optional): If you complete the Compliance Readiness Assessment, you may provide your name, company, email, and industry selection. This is used to deliver your assessment results and personalized recommendations.
Facility Compliance Review inquiries: If you contact us via email (info@victoryhourmedia.com) to book a consultation, we collect your name, email, company, and the details you provide in your message.
Payment information: If you purchase a paid plan, payment is processed by Gumroad (our payment processor). We do not collect, store, or have access to your credit card, banking, or payment details. Gumroad's privacy policy governs payment data.
2B — AUTOMATICALLY COLLECTED INFORMATION
Standard web server logs: Cloudflare (our hosting provider) may collect standard server logs including IP address, browser type, operating system, referring URL, and pages visited. This is standard infrastructure logging. We do not access or analyze this data for marketing purposes.
No analytics tracking: We do not use Google Analytics, Facebook Pixel, Hotjar, or any other behavioral analytics or tracking tool. We do not track individual user behaviour across sessions.
2C — INFORMATION PROCESSED BUT NOT RETAINED (OPERATIONAL DATA)

When you use SOP Command™ to generate documents, you may enter operational information including company names, facility details, product descriptions, process parameters, and regulatory context. This information is:

Processed: Sent to our API infrastructure to generate your document. Not stored: Not written to any database, file, or storage medium on our infrastructure. Not retained: Does not exist on our systems after your generation request completes. Not accessible: We cannot retrieve, review, or disclose this information because we do not have it.

See our Data Security page for a complete technical explanation of how your operational data flows through our system.

SECTION 3
🚫WHAT WE DO NOT COLLECT
We do not collect health information or patient data. SOP Command is not a healthcare application and must not be used to process patient-identifiable health information.
We do not collect biometric data, financial account data, government ID numbers, or any other special categories of sensitive personal information.
We do not build user profiles or behavioural advertising audiences. We have no relationship with advertising networks.
We do not collect children's personal information. SOP Command is a B2B enterprise platform not directed at individuals under 18.
We do not sell your personal information. Under no circumstances do we sell, rent, or trade personal information to third parties for their commercial use.
SECTION 4
⚙️HOW WE USE YOUR INFORMATION

Information collected from lead capture forms and assessment completions is used for:

Delivering your requested document or assessment results — the primary purpose of collection.
Sending relevant compliance resources relevant to your industry — infrequent, value-focused communications.
Following up on enterprise inquiries you initiate through our contact form or email.
Processing your payment through Gumroad (handled by Gumroad — we receive only payment confirmation, not payment details).
Improving the platform — aggregate, anonymized usage patterns only (e.g., which industries are most used). Never individual-level tracking.
✓ LEGAL BASIS (PIPEDA)
Under PIPEDA, we collect and use personal information with your consent (express or implied by your voluntary submission) and only for purposes that a reasonable person would consider appropriate in the circumstances. You may withdraw consent at any time by contacting info@victoryhourmedia.com.
SECTION 5
🔒WHAT WE NEVER DO WITH YOUR INFORMATION
We never sell your personal information to any third party, data broker, advertiser, or other organization — for any reason, at any price.
We never share your email or contact details with marketing companies, lead generation firms, or advertising networks.
We never use your operational data for AI training. Information you enter to generate SOPs and forms is not used to improve, fine-tune, or train any AI model.
We never engage in behavioral advertising or retargeting based on your activity on SOP Command™.
We never disclose information to government authorities except where legally required by valid legal process under Canadian law, after seeking legal counsel.
SECTION 6
📅DATA RETENTION
RETENTION SCHEDULE
Operational data (SOPs and forms you generate): Zero retention. Not stored on our infrastructure at any point.
Lead capture information (name, email, company): Retained for a reasonable period to fulfill the purpose of collection. You may request deletion at any time.
Assessment completion data: Retained to deliver results and follow-up resources. Deleted upon request.
Email correspondence: Retained as long as reasonably necessary for business purposes. May be retained longer if related to a contractual or legal matter.
Payment transaction records: Retained by Gumroad per their policies and applicable financial regulations. We retain only payment confirmation records (not payment details).
Cloudflare server logs: Managed by Cloudflare per their data retention policies (typically 30 days for standard logs). See Cloudflare's privacy policy for details.
SECTION 7
🍪COOKIES & BROWSER STORAGE

SOP Command™ has a minimal cookie and browser storage footprint:

WHAT WE USE
sessionStorage (browser-only): We use browser sessionStorage to remember within-session preferences such as whether you have seen the documentation modal, whether lead capture has been completed, and other session-state items. This data exists only in your browser during the session and is automatically cleared when you close the tab or browser.
Cloudflare cookies: Cloudflare may set technical cookies (e.g., __cf_bm for bot management) as part of their infrastructure services. These are security and performance cookies, not tracking cookies.
PWA Service Worker cache: If you install SOP Command™ as a Progressive Web App, the service worker caches the application files (HTML, fonts, icons) for offline use. No personal information is cached by the service worker.
⚠️ WHAT WE DO NOT USE
We do not use advertising cookies, tracking pixels, third-party analytics cookies, social media cookies, or any persistent identifier that tracks you across websites. We have no cookie consent banner because we do not set cookies that require consent under PIPEDA or GDPR.
SECTION 8
🤝THIRD-PARTY SERVICES & DATA PROCESSORS

The following third parties process data in connection with SOP Command™. This is a complete list:

CLOUDFLARE INC.
Role: Infrastructure, CDN, Security
Data: Standard server logs, IP addresses, traffic patterns
Location: USA (global edge network)
Privacy: cloudflare.com/privacypolicy
ANTHROPIC PBC
Role: AI document generation (API)
Data: Prompts containing your inputs; processed transiently
Location: USA
Privacy: anthropic.com/legal/privacy
GUMROAD INC.
Role: Payment processing, subscription management
Data: Payment details, billing address, purchase history
Location: USA
Privacy: gumroad.com/privacy
GOOGLE FONTS / CDN PROVIDERS
Role: Font delivery; JS library CDN
Data: Standard CDN request data (IP, browser type)
Note: No personal or operational data transmitted
Privacy: policies.google.com/privacy

We do not share your personal information with any third parties beyond those listed above and only to the extent necessary to provide the service.

SECTION 9
⚖️YOUR PRIVACY RIGHTS (PIPEDA)

Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, you have the following rights regarding your personal information:

👁
RIGHT OF ACCESS
You have the right to request access to the personal information we hold about you, and to receive an explanation of how it is used and to whom it has been disclosed.
✏️
RIGHT TO CORRECTION
If personal information we hold about you is inaccurate, incomplete, or out of date, you have the right to request that we correct it.
🗑
RIGHT TO DELETION
You may request that we delete personal information we hold about you where it is no longer needed for the purpose it was collected, subject to legal retention requirements.
🚫
RIGHT TO WITHDRAW CONSENT
You may withdraw your consent to our collection and use of your personal information at any time, subject to legal or contractual restrictions and reasonable notice.
📋
RIGHT TO COMPLAIN
If you believe your privacy rights have been violated, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.
📧
HOW TO EXERCISE
To exercise any of these rights, contact us at info@victoryhourmedia.com with the subject line "PRIVACY REQUEST." We respond within 30 days as required by PIPEDA.
✓ NOTE FOR EU / UK USERS
If you are located in the European Union or United Kingdom, you may have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the right to data portability and the right to object to processing. We will honour these rights to the extent applicable. Our legal basis for processing is consent and/or legitimate interests. Contact info@victoryhourmedia.com for a GDPR-specific response.
SECTION 10
👶CHILDREN'S PRIVACY

SOP Command™ is a B2B compliance platform designed exclusively for business use by adults operating in regulated industries. We do not knowingly collect personal information from individuals under the age of 18.

If we become aware that we have inadvertently collected personal information from a person under 18, we will delete it promptly. If you believe a minor has provided personal information to us, please contact info@victoryhourmedia.com immediately.

SECTION 11
🌍INTERNATIONAL USERS & DATA TRANSFERS

SOP Command™ is operated from Windsor, Ontario, Canada. If you are accessing the platform from outside Canada — including the United States, European Union, United Kingdom, UAE, or elsewhere — please be aware of the following:

DATA TRANSFER NOTICE
Our infrastructure involves Cloudflare's global edge network (servers in multiple countries) and Anthropic's API (USA-based). When you use SOP Command™, data may be processed in the United States or other countries where Cloudflare operates edge nodes.
We rely on Cloudflare's and Anthropic's standard data protection commitments for cross-border data transfers. Both maintain robust privacy programs.
By using SOP Command™, you acknowledge that your information may be transferred to and processed in countries with privacy laws that may differ from your home country.
For EU/EEA users: We rely on standard contractual clauses and the legitimate interests of providing the service for any cross-border data transfers of personal information. Contact us if you require a Data Processing Agreement (DPA).
SECTION 12
🔔CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Post a notice on sopcommand.com
• Where we hold your email address and the change is significant, notify you by email

Your continued use of SOP Command™ after a policy update constitutes your acceptance of the updated policy. If you do not agree with the updated policy, you should discontinue use of the platform and contact us to delete your personal information.

We encourage you to review this Privacy Policy periodically. This page is available at sopcommand.com/privacy.html.

PRIVACY OFFICER CONTACT
For privacy inquiries, access requests, corrections, deletions, consent withdrawal, or complaints under PIPEDA, contact our Privacy Officer. We respond within 30 days as required by law.
info@victoryhourmedia.com
Subject line: "PRIVACY REQUEST — [Your Name]"
Victory Hour Multimedia Inc. · Windsor, Ontario, Canada

Office of the Privacy Commissioner of Canada
If your concern is not resolved to your satisfaction:
priv.gc.ca · 1-800-282-1376