Privacy
Policy

Desmios Inc. is an Ontario corporation (Corp. No. 1001555130; HST 726792831 RT 0001) headquartered at 228 Kingknoll Drive, Brampton, Ontario. Desmios builds and operates Jarvis, an AI-powered voice ordering system deployed at client restaurant locations.

AI Disclosure. Every call answered by Jarvis begins with an automated disclosure that the call is handled by an AI assistant, delivered before any personal information is collected. If at any point you ask whether you are speaking with a human or an AI, Jarvis will disclose that it is an AI system. This disclosure is hardcoded at the platform level and cannot be suppressed or disabled by any restaurant client.

2.1 Collected During Every Call

• •Caller telephone number (collected automatically by Twilio Inc. upon call connection)
• •Order details: items, quantities, customizations, total price
• •Order type (pickup or delivery) and, for delivery orders, delivery address
• •Call timestamp, call duration, and language of the call

2.2 Voice Data and AI Processing — Sensitive Category

• •Your voice audio is streamed in real time, over a secure connection, directly to OpenAI’s Realtime API (model: gpt-realtime-2.1-mini), operated by OpenAI OpCo, LLC (“OpenAI”). This single system performs speech recognition, order-parsing reasoning, and generation of Jarvis’s spoken responses within one continuous processing pipeline — there is no separate hand-off between a speech-to-text vendor, a language model vendor, and a text-to-speech vendor.
• •OpenAI retains API inputs and outputs (including audio and derived transcripts) for a maximum of thirty (30) days solely for abuse and misuse monitoring, after which they are deleted, unless a longer period is required by law. OpenAI does not use this data to train its models. This data handling is governed by an executed Data Processing Addendum between Desmios Inc. and OpenAI.
• •One call transcript per day per restaurant location is separately retained by Desmios for quality assurance for a maximum of thirty (30) days, after which it is permanently deleted.
• •On return calls where Jarvis greets a returning customer by name or reads back a saved delivery address, that name and address are included in the live session provided to OpenAI’s Realtime API for the purpose of generating that spoken response. This is a cross-border transfer of personal information (see Section 6).

2.3 Returning Customers

• •Customer name (provided voluntarily, for order personalization)
• •Delivery address (provided voluntarily; retained for convenience on return calls)
• •Order history (retained to improve service on return calls)

2.4 Website (desmios.ca)

• •Contact form submissions (name, email address)
• •Standard server log data (IP address, browser type, pages visited)
• •Cookie data as described in Section 9

Desmios does not collect payment card information, government-issued identification, or financial information through Jarvis. No information is collected for advertising purposes and no personal information is sold to any third party.

Consistent with PIPEDA Principle 2 (Identifying Purposes) and Principle 4 (Limiting Collection), Desmios collects personal information only to:

• •Receive, process, and confirm telephone food orders through Jarvis
• •Transmit completed orders to restaurant staff for review and fulfillment
• •Send SMS order confirmations to the caller’s telephone number (see CASL Notice below)
• •Greet returning customers by name and recall saved delivery addresses
• •Maintain quality assurance through limited retention of call transcripts
• •Generate anonymized, aggregated analytics for restaurant clients (call volume, order patterns, service performance) — derived from anonymized data only; no individual profiling is conducted
• •Respond to inquiries submitted through desmios.ca
• •Operate and improve the Jarvis system and desmios.ca

Data Minimization. Desmios collects only the minimum personal information necessary for the purposes above, and does not collect personal information speculatively or for undefined future purposes.

Consistent with PIPEDA Principle 5, personal information is retained only as long as necessary for the identified purposes, per the following schedule:

4.1 Retention Schedule

• •Caller name, telephone number, delivery address, and order history (customer profile): retained for a maximum of 24 months after the caller’s last interaction with any Jarvis-enabled restaurant, then permanently purged.
• •Order details (items, price, order type, timestamp): retained for 90 days from the order date, then permanently deleted.
• •Call metadata (duration, language, timestamp): retained for 90 days, then permanently deleted.
• •Quality assurance call transcripts (Desmios-retained copy): retained for a maximum of 30 days, then permanently deleted.
• •Voice audio and derived transcripts processed by OpenAI’s Realtime API: retained for a maximum of 30 days, for abuse-monitoring purposes only, under OpenAI’s Data Processing Addendum with Desmios; not used for model training.
• •Anonymized analytics summaries: retained indefinitely (contain no personal identifiers).
• •Website contact form submissions: retained for 12 months from submission.

Before deletion, order and call records are aggregated into anonymized monthly analytics summaries (e.g., total call volume, order counts, revenue totals) that contain no personal identifiers and cannot be traced to any individual.

4.2 Data at Termination

Upon termination of a restaurant client’s Service Agreement, all customer personal information associated with that restaurant is deleted from Desmios’s systems within 30 days of termination.

• •Restaurant staff access order details, delivery addresses, and caller telephone numbers through the Jarvis dashboard to review, approve, or deny orders. Restaurant clients act as data controllers; data sharing is governed by a written Data Processing Agreement requiring PIPEDA-equivalent protections.
• •Desmios technical staff may access personal information on a need-to-know basis to maintain, troubleshoot, and improve Jarvis, subject to internal data handling obligations.
• •Desmios does not sell, rent, or disclose personal information to any third party for commercial purposes.
• •Desmios may disclose personal information if required by law, court order, or regulatory authority, and will, where legally permitted, notify the affected restaurant client prior to such disclosure.

The following sub-processors receive personal information in connection with the Jarvis service:

• •Twilio Inc. (San Francisco, CA, USA) — Telephony and SMS. Personal information received: caller telephone number, live audio stream, SMS content.
• •OpenAI OpCo, LLC (San Francisco, CA, USA) — Real-time speech recognition, order-parsing reasoning, and voice response generation (Realtime API, gpt-realtime-2.1-mini). Personal information received: live voice audio, derived transcripts, and, on return calls, caller name and delivery address transmitted for personalized voice responses. Retained a maximum of 30 days for abuse monitoring; not used for model training. Governed by an executed Data Processing Addendum.

6.1 Primary Data Storage

Completed order data and customer profiles are stored in Desmios’s primary database on a DigitalOcean server in Toronto, Ontario, Canada — primary storage is on Canadian soil.

6.2 Discontinued Sub-Processors

As of the effective date of this Policy, Desmios no longer engages Deepgram Inc., Soniox Inc., Anthropic PBC, Cartesia AI, or Microsoft Azure Cognitive Services in connection with the Jarvis voice pipeline. These providers previously performed speech-to-text, language-model, and text-to-speech functions later consolidated into the single OpenAI Realtime API integration described above. Any personal information previously held by those providers was processed under their respective Data Processing Agreements with Desmios and was not retained beyond the applicable call session.

6.3 Forward-Looking Compliance — AIDA

Desmios is monitoring the proposed AIDA (Bill C-27, Schedule 1), which will impose algorithmic transparency, impact assessment, and accountability obligations on organizations deploying high-impact AI systems. Desmios will update its practices and disclosures as required upon AIDA receiving Royal Assent.

• •Access: request access to the personal information Desmios holds about you and an account of its use and disclosure.
• •Correction: request correction of inaccurate or incomplete personal information.
• •Withdrawal of consent: withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice; withdrawal may affect Desmios’s ability to provide the Jarvis service to you.
• •Complaint: file a complaint with the Office of the Privacy Commissioner of Canada (PIPEDA s. 11).

To exercise these rights, contact the Privacy Officer (Section 11). Desmios responds to written requests within 30 days.

Office of the Privacy Commissioner of Canada: www.priv.gc.ca | 1-800-282-1376 | 30 Victoria Street, Gatineau, Quebec K1A 1H3

8.1 Safeguards

Desmios maintains reasonable organizational and technical safeguards consistent with PIPEDA Principle 7, including encrypted data transmission, access controls, and server-level security on its DigitalOcean infrastructure.

8.2 Breach Notification

For any breach of security safeguards creating a real risk of significant harm, Desmios will comply with PIPEDA s. 26.1 and the Breach of Security Safeguards Regulations, SOR/2018-64, in accordance with its internal Privacy Breach Response Plan, including notification to the OPC and affected individuals as soon as feasible, and notification to affected restaurant clients without unreasonable delay so they may fulfill their own controller notification obligations.

desmios.ca does not currently set any cookies. Desmios does not use third-party analytics tools, tracking pixels, advertising cookies, or behavioural advertising technologies on desmios.ca. If Desmios introduces cookies of any kind — including functional, session, or analytics cookies — in the future, this Policy will be updated in advance to identify them and describe their purpose, and any consent mechanism required by law will be implemented.

• •Material changes (anything affecting how personal information is collected, used, or disclosed): at least 30 days’ advance written notice before the change takes effect, by prominent notice on desmios.ca and, where practicable, direct notice to affected restaurant clients so they may inform their customers. If you do not accept a revised Policy, you may request deletion of your personal information before the effective date.
• •Non-material changes (minor or clarifying) may be made without advance notice; the effective date above is updated on each revision.
• •Continued use of Jarvis after a material change constitutes acceptance only where the 30-day advance notice above was provided.

Privacy Officer: Anmol Singh

Title: Privacy Officer, Desmios Inc.

Email: privacy@desmios.ca

Mailing Address: 228 Kingknoll Drive, Brampton, Ontario

To make a privacy request, file a complaint, exercise your Section 7 rights, or request deletion of your personal information, contact the Privacy Officer. Written requests are answered within 30 days.

Desmios is monitoring Bill C-27 (CPPA and AIDA). Anticipated changes include expanded individual rights (algorithmic transparency, data portability), mandatory Privacy Management Programs, stricter consent and de-identification standards, AI accountability and impact-assessment obligations, and administrative monetary penalties up to the greater of CAD $25,000,000 or 5% of gross global revenues. Desmios will conduct a gap analysis upon enactment and update this Policy, its internal practices, and its sub-processor agreements accordingly.

The Jarvis service and desmios.ca are not directed at children. Desmios does not knowingly collect personal information from individuals under 18 through the website. Callers of any age may place orders by telephone at a restaurant’s published number; Desmios collects only the minimal order information described in Section 2 and applies the same protections to all callers.

Version 2.1 (September 13, 2026)

Version 2.1 (September 13, 2026) supersedes Version 2.0 (September 8, 2026) to reflect a cookie audit of desmios.ca. Non-material change: Section 9 corrected — an audit of desmios.ca confirmed the site currently sets no cookies of any kind. Prior language stating the site uses ‘essential session cookies’ was inaccurate and has been removed.

Version 2.0 (September 8, 2026)

Version 2.0 superseded Version 1.3 (August 24, 2026) to reflect Desmios’s migration of the Jarvis voice pipeline to OpenAI’s Realtime API, completed August 30, 2026. Material changes:

• •Sections 2.2 and 6 rewritten: Deepgram, Soniox, Anthropic (Claude), Cartesia, and Microsoft Azure removed as sub-processors; OpenAI OpCo, LLC added as the sole processor of live voice data, reflecting the single-hop Realtime API architecture.
• •Section 6 retention language updated to reflect OpenAI’s published 30-day abuse-monitoring retention window and no-training-by-default policy, under an executed Data Processing Addendum with OpenAI.
• •Registered office address confirmed as 228 Kingknoll Drive, Brampton, Ontario, consistent with the Ontario Business Registry amendment filed August 25, 2026.
• •Effective Date finalized as September 8, 2026.