We are committed to maintaining the accuracy, confidentiality, and security of our users’ personally identifiable information (“Personal Information”). As part of this commitment, our Privacy Policy governs our actions as they relate to the collection, use and disclosure of Personal Information. Our Privacy Policy is based upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.
1. Introduction
We are responsible for maintaining and protecting the Personal Information under our control. Censtra is wholly owned and operated by Hilltop Partner Network Inc. (HPN). This Privacy Policy governs Censtra’s data collection and usage on the Censtra website (censtra.ai) and application (censtra.app), hereafter called the “Sites”. By using the Sites, you consent to the data practices described in this statement.
2. Identifying Purposes
We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address, payment and other contact information is provided as part of the order process.
3. Consent
Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our products or services. We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.
4. Limiting Collection
The Personal Information collected will be limited to those details necessary for the purposes identified by us, or as otherwise required or permitted by this Privacy Policy or applicable laws. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet:
- Information collected indirectly, through our Sites’ technology. When you access our Sites, our Internet access logs automatically record your browser type, the time and date of your visit, the IP address of the connecting computer, and the URLs you accessed. None of this information is personally identifying. It is used solely for system administration purposes and to analyze traffic on our Sites.
- Directly, when you knowingly provide information (for example, signing up for an account on our Sites or when you complete a contact form through the Sites). Information that we obtain directly from you is used only for those purposes in which we have specifically obtained your permission and only so that we can serve your needs and our legitimate business objectives.
- Directly, when you add your consulting information to your account (leads, information about your firm, work history, past projects, etc.), or upload client documents such as RFPs, that information will be visible to other registered users within in your account tenant, to the Censtra AI, and to the Sites’ Administrators. This data remains strictly segregated and isolated within your specific tenant account.
- Directly, when you engage with other users through the Sites (for example, through team and external collaboration features). This information can be accessed by the Censtra AI, by the Sites’ Administrators, and by Censtra users in the account tenants within which you are collaborating (the intended recipients) but is not visible to other Censtra users who are outside of these personal or company tenant accounts.
- Directly, through AI Telemetry and Gateway Logging. To ensure AI safety, Censtra routes all AI requests through a centralized LLM API Gateway. User inputs (prompts) and AI-generated outputs are logged and monitored by platform administrators for security auditing, abuse prevention, and quality assurance purposes.
- Censtra explicitly utilizes Microsoft Azure OpenAI under an enterprise agreement for our AI features. Your data is securely isolated and is never used by Microsoft or OpenAI to train public foundational models. Additionally, uploaded documents are processed and indexed into a secure graph database (GraphRAG) to enable AI functionality.
5. Financial Information
HPN does not collect, store, or process your credit card or banking information within the Sites. All payment processing is securely managed by our third-party integration partner, PayPal Braintree. The only financial data HPN retains is limited to details necessary for subscription management, such as your tier level, payment dates, and payment amounts. This ensures that sensitive payment information remains protected and is not accessible or stored by HPN.
6. Limiting Use, Disclosure and Retention
Your Personal Information may only be used or disclosed by us for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by this Privacy Policy or applicable laws.
HPN retains the right to aggregate and fully anonymize operational data and platform outcomes (such as whether an opportunity resulted in a “Win” or “Loss,” and final pricing parameters). This non-personally identifiable information is used strictly to train, tune, and improve Censtra’s internal predictive analytics and custom machine learning models.
HPN does not sell, rent, or lease user lists to third parties. We may, from time to time, share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to HPN, and they are required to maintain the confidentiality of your information.
HPN does not collect or disclose sensitive personal information, such as race, religion, or political affiliations.
7. Accuracy
Personal Information will be maintained in an as accurate, complete, and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
8. Safeguarding Information
Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect your Personal Information from any loss or unauthorized use, access, or disclosure.
When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
9. Access
Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.
10. Challenging Compliance with Privacy Laws
All questions or concerns regarding our privacy practices should be directed to the contact information below.
We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures. We will inform you of the outcome of the investigation regarding your complaint.
11. Policy Changes and Suggestions
HPN reserves the right to add, remove or modify portions of this Privacy Policy at any time at our discretion. You are encouraged you to periodically review this Privacy Policy to be informed of how we are protecting your information.
Questions or inquiries with respect to our Privacy Policy or our practices by contacting privacy@censtra.ai.
Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/.
Additional Information
Cookies and Local Storage
A cookie is a small computer file or piece of information that may be stored in your computer’s hard drive when you visit our Sites. We may use cookies and local storage mechanisms to improve our Sites’ functionality and, in some cases, to provide visitors with a customized online experience. For example, we use local storage to securely save your non-sensitive user preferences directly on your device.
Cookies are widely used, and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies, to clear your local storage, or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies or local storage, you may not experience optimal performance of our Sites
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Other Websites
Our Sites may contain links to other third-party sites that are not governed by this Privacy Policy. Although we endeavour to only link to sites with high privacy standards, our Privacy Policy will no longer apply once you leave our Site. HPN is not responsible for the privacy of information or other content on websites outside of our own Sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared, and disclosed.
Updated: May 2026