DRAFT — NOT YET APPROVED

This page is a draft for internal review only (MapleTask #228). It is legal-adjacent and must be reviewed and approved by our Privacy Officer (Joel Gathercole) and legal counsel before any cross-driver data is shared and before this policy is published to production. Do not treat this as a binding policy.

MapleDrive Privacy & Data-Sharing Policy

Aggregated Recommendations vs Individual Driver Data

Status: DRAFT  ·  Effective Date: [pending legal approval]

Policy decisions (opt-in by default, K=5 minimum cohort, banded tip ranges + differential-privacy noise, and honouring the early legal-review gate) were confirmed by the Privacy Officer on 2026-06-22. This page remains a DRAFT pending formal legal sign-off and is not published to production.

MapleDrive is a Maple-branded product owned and operated by Joel & Nanz Inc. (“Maple,” “we,” “us,” “our”). This policy explains how MapleDrive keeps each driver’s own data private while producing aggregated, anonymized recommendations that draw on patterns across many drivers. It is PIPEDA-aligned and supplements the general Privacy Statement and Terms of Service.

0. Plain-language summary

Your deliveries, messages, and tips are private to you. We only use combined, anonymized patterns from at least 5 drivers to power recommendations — never your individual numbers, and only if you opt in. You can turn this off anytime.

1. Data classes

2. What counts as aggregated / anonymized

An output is “aggregated” only if it (a) combines at least K distinct contributing drivers and (b) carries no field that can re-identify a single driver, delivery, customer, or exact tip. Aggregates are statistics (rates, bands, ranks) — never row-level pass-through. De-identification is irreversible: source driver IDs are stripped before the aggregate is computed, not merely hidden at display time.

3. Minimum-cohort (K-anonymity) threshold

4. Never shared / never crosses a tenant boundary

5. Consent: opt-in by default

Contributing your data into the cross-driver aggregate pool is opt-in. You may use MapleDrive’s private features (compose messages, track your own tips) without ever contributing to aggregates. A clear, separate consent toggle — “Help improve recommendations by contributing my anonymized patterns” — enrols you in the pool; it is off by default.

Why (PIPEDA): PIPEDA requires meaningful consent proportional to sensitivity. Tip and earnings data is financial and reasonably sensitive, and using it to power recommendations for other drivers is a secondary purpose beyond the primary purpose (your own tooling). Sensitive data plus a secondary purpose calls for express, opt-in consent rather than bundled or opt-out consent. Consent is granular, revocable, and not a condition of using the core product.

Withdrawal: turning the toggle off stops all future contribution. Any already-published aggregate that no longer meets the K threshold after a withdrawal is recomputed or suppressed on the next aggregation cycle.

6. Retention

Aggregate inputs and derived statistics are held under our standard 7-year retention. Withdrawal removes a driver from future aggregation cycles. You may request access to, correction of, or deletion of your personal information at any time by contacting our Privacy Officer (below); verified requests are actioned within 30 days, subject to overriding legal retention obligations.

7. Data sovereignty

Aggregation compute and storage stay on Canadian-hosted infrastructure. White-label instances aggregate only within their own country and tenant boundary — there is no cross-border pooling and no pooling across white-label deployments.

8. Accountability & legal review

This draft is the pre-review artifact. Under our general legal posture, formal counsel review is deferred to 1,000 clients or the MapleTriage IRAP grant; however, the parent requirement (#215) explicitly requires legal sign-off before any cross-driver data crosses a boundary (before child #8 ships). That child-ship gate overrides the general deferral (confirmed by the Privacy Officer): the first cross-driver aggregate ship is the trigger for at least a focused legal pass on this policy, regardless of client count or IRAP status.

Privacy Officer (PIPEDA §29)

Joel Gathercole — Joel & Nanz Inc.
Email: [email protected]
Mail: Joel & Nanz Inc., New Brunswick, Canada

For questions about this policy, to request access to your personal information, to request correction, to withdraw consent, or to file a complaint, contact our Privacy Officer at the email above.

DRAFT  ·  MapleTask #228  ·  awaiting Joel + legal approval  ·  [email protected]  ·  Joel & Nanz Inc., New Brunswick, Canada