DESVY Holdings ("DESVY," "we," "us," or "our") operates the Rose public assistant platform at rose.3enet.ca. Rose is a public-facing AI assistant for general chat, language learning, and coding education.
DESVY Holdings is the data controller responsible for your personal data collected through the Rose service. For questions about this policy or your data, see Section 13 (Contact Us).
We collect the following categories of information:
| Category | Data Points | Source | Required? |
|---|---|---|---|
| Account data | First name, last name, email address, username, hashed password | You provide at registration | Yes |
| Conversation data | Messages you send, AI responses, conversation titles, timestamps | Generated during use | To provide the service |
| Preference data | Target language, difficulty level, coding language preference | You provide optionally | No |
| Usage data | Login timestamps, login count, last active date | Automatically collected | Automatic |
| Technical data | IP address, browser user agent (for security and rate limiting only) | Automatically collected | Automatic |
| Audit data | Login events, signup events, password reset events, chat activity logs | Automatically generated | Security requirement |
What we do not collect:
We use the information we collect for the following purposes:
We do not use your personal data for advertising, targeted marketing, or sale to third parties.
We retain your data for the following periods:
| Data Type | Retention Period |
|---|---|
| Account data | Duration of account, plus 90 days after deletion request |
| Conversation history | Duration of account; you may delete individual conversations at any time |
| Password reset tokens | 1 hour from creation (automatically invalidated) |
| Session tokens | 24 hours from creation |
| Security audit logs | 90 days |
| IP addresses | 30 days for rate limiting; 90 days in security logs |
| Preference data | Duration of account |
When you delete your account, we will delete or anonymize your personal data within 90 days, except where retention is required by law or for legitimate security purposes.
We do not sell your personal data. We may share your information only in the following limited circumstances:
We do not share your conversation content, account data, or preferences with any advertising networks, data brokers, or analytics companies.
We implement technical and organizational measures designed to protect your personal data, including:
No method of electronic storage or transmission is 100% secure. While we implement industry-standard protections, we cannot guarantee absolute security. In the event of a security breach affecting your data, we will notify you as required by applicable law.
Rose operates on a strictly isolated data architecture:
rose_db) separate from all internal DESVY systemsThis architectural separation is enforced at the database, application, and network levels.
Rose uses minimal client-side storage:
localStorage to maintain your login session. This token expires after 24 hours.You can clear your browser's localStorage at any time to remove your session token, which will sign you out of Rose.
Depending on your jurisdiction, you may have the following rights regarding your personal data:
To exercise any of these rights, contact us at admin@3enet.ca. We will respond to your request within 30 days. We may need to verify your identity before processing your request.
If you are located in the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with your local data protection authority.
If you are a resident of Canada, your rights are protected under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
The Service is not directed to children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe we have inadvertently collected data from a child under 13, please contact us immediately at admin@3enet.ca and we will take steps to delete such data promptly.
Users between 13 and 18 years of age must have parental or guardian consent to use the Service, as described in our Terms of Service.
DESVY Holdings operates from Canada. Your data is stored and processed on servers located in Canada. If you access Rose from outside Canada, your data will be transferred to and processed in Canada.
By using the Service, you consent to the transfer of your information to Canada, which may have data protection laws that differ from those in your country. We implement appropriate safeguards for any cross-border transfers of personal data as required by applicable law.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.
For privacy-related inquiries, data subject requests, or to report a security concern:
We aim to respond to all privacy inquiries within 30 days. For urgent security matters, please mark your email as urgent.