Building software in Canada: why location matters for privacy and compliance

Where a software company is incorporated, where it stores your data, and which country's laws govern that data are not abstract details. They are some of the most important factors determining how your personal information is actually protected. Most users do not think about jurisdiction when they download an app. But jurisdiction is often the difference between strong privacy protection and almost none at all.

siasola is a Canadian company, operating under Canadian federal and provincial privacy law. This was not an accident. It was a deliberate decision, and it has concrete consequences for how we handle data, how we build products, and what legal protections apply to the people who use them.

This article explains why Canada's privacy framework matters, how it compares to other jurisdictions, and what it means in practice for siasola's products.

What is PIPEDA, and why should you care?

PIPEDA (the Personal Information Protection and Electronic Documents Act) is Canada's federal private-sector privacy law. It has been in effect since 2000, and it establishes ten fair information principles that govern how companies collect, use, and disclose personal information.

The principles are straightforward: companies must identify why they are collecting your data before they collect it, obtain meaningful consent, limit collection to what is actually necessary, and protect that data with appropriate safeguards. Individuals have the right to access their personal information, challenge its accuracy, and file complaints with the Office of the Privacy Commissioner.

PIPEDA applies to all commercial activities across Canada, with provinces that have enacted "substantially similar" legislation (Alberta, British Columbia, and Quebec) applying their own laws locally. For a company like siasola, operating out of Quebec, this means we are subject to both federal and provincial privacy requirements.

This dual layer of oversight is not a burden. It is a feature.

Quebec's Law 25: among the strictest privacy rules in North America

In September 2023, Quebec's Law 25 (formerly Bill 64) came into full effect, introducing privacy obligations that in many cases exceed PIPEDA and rival the European Union's GDPR. For any company operating in Quebec, Law 25 is not optional.

Here is what Law 25 requires:

Privacy impact assessments. Before any new project that involves personal information, the company must conduct a formal assessment of privacy risks. This is not a checkbox exercise. It is a documented analysis of how data flows through the system and where risks exist.

Mandatory breach notification. If a privacy breach creates a risk of serious harm, the company must notify affected individuals and the Commission d'acces a l'information (Quebec's privacy authority). The notification must include what happened, what data was affected, and what steps are being taken.

Data minimization by default. Organizations must collect only the personal information necessary for the identified purpose. Collecting extra data "just in case" is not permitted.

Consent and transparency. Consent must be clear, specific, and obtained separately for each purpose. Bundling consent into a single "agree to everything" button does not meet the standard. Privacy policies must be written in clear, simple language.

Right to data portability and deletion. Individuals have the right to receive their data in a commonly used format and to request its deletion when it is no longer necessary.

For siasola, Law 25 alignment was not an afterthought. It shaped how we designed our data handling from the beginning. Our products collect minimal data, our privacy practices exceed what the law requires, and our infrastructure is built around the principle that the best way to protect data is to avoid collecting it in the first place.

The US CLOUD Act: why jurisdiction is not just paperwork

One of the most significant differences between Canadian and American data protection is the US CLOUD Act (Clarifying Lawful Overseas Use of Data Act), enacted in 2018.

The CLOUD Act allows US law enforcement to compel American technology companies to provide data stored on their servers, regardless of where in the world those servers are physically located. If your data is held by a US-based company, it is subject to US government access, even if the servers are in Canada, Europe, or anywhere else.

This has practical implications. When you use a cloud service from an American company, the physical location of the data centre is less relevant than the legal jurisdiction of the company itself. A US company hosting data in a Canadian data centre is still subject to the CLOUD Act.

Canadian companies operating exclusively under Canadian law are not subject to the CLOUD Act. For data held by a Canadian company on Canadian servers, access by law enforcement requires compliance with Canadian legal processes, which include judicial oversight and are governed by the Canadian Charter of Rights and Freedoms.

siasola is incorporated in Canada. Our servers are in Canada. The data we hold is governed by Canadian law. This is a structural privacy advantage that no privacy policy or marketing promise can replicate, because it is backed by the legal framework of the country, not just the intentions of the company.

How Canada compares to other jurisdictions

Canada vs. the United States. The US has no comprehensive federal privacy law. Privacy protection is a patchwork of state laws (California's CCPA being the most notable) and sector-specific regulations like HIPAA for healthcare. For most consumer apps, there is no federal baseline. Canada's PIPEDA and provincial laws like Law 25 provide consistent, enforceable protections across the country.

Canada vs. the European Union. The EU's GDPR is widely considered the global gold standard for privacy regulation. Canada's framework, particularly when you combine PIPEDA with Law 25, is comparable in many respects: both require consent, data minimization, breach notification, and individual rights to access and deletion. Canada and the EU have a mutual adequacy finding, meaning the EU recognizes Canada's privacy protections as sufficient for cross-border data transfers. This is a status that the United States does not have on the same terms.

Canada vs. Australia and the UK. Both Australia and the UK have comprehensive privacy laws, but neither combines federal and provincial layers of enforcement the way Canada does. Quebec's Law 25, in particular, creates a standard that exceeds the federal baseline and is enforced independently.

What this means for siasola's products

Our location in Canada is not a marketing talking point. It is a structural decision that affects every product we build.

Data stays in Canada. When you use Siasola Tinnitus Masking Sounds, Siasola Cycling Beats, or any of our products, the data we collect (which is minimal to begin with) is stored on Canadian servers, governed by Canadian law.

No CLOUD Act exposure. Because siasola is a Canadian company, your data is not subject to US government access under the CLOUD Act. This matters particularly for our AI automation services, where clients entrust us with business-sensitive information.

Provincial and federal oversight. Our data handling is subject to both PIPEDA and Quebec's Law 25, one of the most rigorous privacy frameworks in North America. We do not get to choose the more lenient option. We comply with both.

Bilingual operations. Operating under Quebec law means siasola functions in both English and French. Quebec's language laws (including Bill 96) require that commercial communications be available in French. This is not just a legal obligation; it reflects our commitment to serving a diverse, global user base in the languages they are most comfortable with.

Why privacy-conscious users should ask where their apps are built

The next time you download an app, consider three questions:

1. Where is the company incorporated?
2. Where is your data stored?
3. Which country's laws govern what happens to that data?

The answers to these questions tell you more about your actual privacy protections than any marketing language, privacy badge, or trust seal. Laws are enforceable. Marketing promises are not.

siasola chose Canada because Canada's privacy framework aligns with how we believe software companies should treat personal information: with restraint, transparency, and accountability. It is not the only country with strong privacy laws, but it is the one we operate under, and we think that matters.

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Learn more about our privacy practices in Why We Don't Sell Your Data (And Never Will), or explore what we are building: Tinnitus Masking Sounds, Cycling Beats, and AI automation services.