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Privacy Policy

What we collect, why, and what you can do about it.

Last updated: October 27, 2026

1. Scope, and who is responsible

This policy explains how Bockins Holdings Inc., doing business as Pencilab (“Pencilab”, “we”, “us”), a company incorporated in British Columbia, Canada, handles personal information in connection with the pencilab service. We are the organisation responsible for that information — the “controller”, in the language of European law.

We handle personal information under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia’s Personal Information Protection Act (PIPA). If you are in the European Economic Area or the United Kingdom, the GDPR applies to you and section 9 sets out your rights under it. If you are in California, the CCPA as amended by the CPRA applies and section 9 covers that too.

It covers the pencilab website and application. It does not cover any third-party site we link to.

2. What we collect

We try to collect as little as the Service can work with. In practice that is:

  • Your Google account profile, if you sign in. Your name, email address and profile image, received from Google when you choose to sign in. Signing in with Google is the only way to create an account, so we never hold a password for you.
  • What you put in a pencil. The assumptions and figures you enter — land costs, unit mixes, rents, financing terms and so on. This is mostly information about a project rather than about a person, with one exception: a pencil can include a site address, and an address can identify whoever owns or occupies it. Please do not enter personal details about other people that the analysis does not need.
  • A guest token, if you have not signed in. A random value stored in a cookie in your browser, which is the only thing connecting you to a pencil you built without an account. We store a hashed form of it, not the value itself.
  • Technical and log information. Your IP address, browser type and the requests your browser makes, recorded by our servers. We use your IP address to apply rate limits that keep the Service available and to investigate abuse.
  • Error reports. When something goes wrong, diagnostic information about the failure is sent to our error-reporting provider. That can include the page you were on and, incidentally, technical context about your session.
  • Analytics. Information about how the Service is used, collected through Google Tag Manager — see section 5.

Your location, only when you ask. The map on our home page has a button, “Pencil the lot you’re on”. Your browser shares where you are only when you press it, and only if you allow it. We use that position to find your lot: it goes to our server’s parcel lookup, which asks the Province of British Columbia’s ParcelMap BC for the lot there or the nearest one, and the lot it finds goes to Google’s geocoder, which names its address. Once the lot is found, our server asks municipal and regional map servers about it, sending a point on the lot, its outline and its PID — never your position. The map tiles around the lot come from MapTiler, which sees which part of the map your browser loads. We keep your position nowhere — not in our database, not in browser storage, not in a web address and not in a log. If you then start a pencil on that lot, the pencil stores its address and lot as any pencil does.

We do not collect payment information. The Service is free and we have no payment processor, so there are no card details for us to hold or lose.

3. Why we use it

We use personal information to run the Service, and for nothing incompatible with that:

  • To provide the Service — to save your pencils, show them back to you, and calculate figures from them.
  • To identify you — to sign you in, keep you signed in, and connect a guest pencil to your account.
  • To communicate with you — to send service messages, and to answer you when you contact us.
  • To keep the Service secure and available — rate limiting, abuse investigation, and diagnosing faults.
  • To understand and improve the Service — aggregate analytics about which parts are used.
  • To meet legal obligations and to establish, exercise or defend legal claims.

If the GDPR applies to you, our legal bases are: contract, for providing the Service and identifying you; legitimate interests, for security, fault diagnosis, service improvement and defending claims, having weighed those interests against your rights; consent, for analytics, which you may withdraw at any time; and legal obligation, where the law requires us to act.

4. Who we share it with

We do not sell personal information, and we have never sold or shared it for cross-context behavioural advertising as the CCPA uses those terms. We share it only with the service providers the Service runs on, each limited to what its job requires:

  • Google — sign-in (Google OAuth) and analytics (Google Tag Manager).
  • Google Maps Platform — address search and geocoding: the address you type into a search, and the position of a lot whose address we look up.
  • MapTiler — map tiles. Your browser fetches them directly, so MapTiler sees your IP address and the part of the map you are looking at.
  • The Province of British Columbia — parcel outlines, from its ParcelMap BC service. Our server asks for the lot at a point, so the request comes from our server and not from your browser.
  • Municipal and regional map servers — zoning and land data for a lot. Our server asks about the lot, so the request comes from our server and not from your browser. It carries a point on the lot, its outline and its PID, never your position. The servers are:
    • District of Oak Bay, at maps.oakbay.ca
    • City of Victoria, at maps.victoria.ca
    • District of Saanich, at map.saanich.ca
    • City of Vancouver (open data portal), at opendata.vancouver.ca
    • Esri’s ArcGIS Online, hosting the City of Vancouver’s services, at services3.arcgis.com
    • Metro Vancouver, at gis.metrovancouver.org
  • Resend — sending email.
  • Sentry — error reporting and diagnostics.
  • Our hosting and database providers — running the application and storing its data.

We may also disclose information where we are legally required to, where it is necessary to protect our rights or someone’s safety, or to a buyer in connection with a merger, acquisition or sale of assets — in which case this policy continues to apply until you are told otherwise.

5. Cookies

We use cookies in three groups. The first two are essential: without them the Service cannot work.

  • Sign-in cookies (essential). Set by our authentication layer to keep you signed in, to protect forms against cross-site request forgery, and to carry you through the Google sign-in round trip. Some are deleted as soon as sign-in completes.
  • The guest pencil cookie (essential). Holds the random token described in section 2. It is the only thing tying you to a pencil you built without an account.
  • Analytics cookies (not essential). Google Tag Manager is loaded by the Service and may set cookies to measure how the Service is used. This is the one group you can refuse without breaking anything.

Your browser can block or delete cookies, and browser extensions can block analytics specifically. Be aware of the trade: blocking the essential cookies means you cannot sign in, and deleting the guest pencil cookie permanently loses a pencil you built without an account — we have no way to recover it, as section 4 of the Terms of Service explains.

6. How long we keep it

  • Account information and your pencils — for as long as your account exists. Ask us to delete the account and we delete them, other than anything we must keep by law.
  • Guest pencils — until you sign in and attach one to an account, or until it has been inactive long enough for our automatic clean-up to delete it, whichever comes first.
  • Logs and error reports — for a limited period appropriate to diagnosing faults and investigating abuse, then discarded.

7. Security

Traffic to and from the Service is encrypted in transit. Access to production systems is restricted to those who need it. We hold no passwords, because sign-in goes through Google, and no payment details, because there is nothing to pay.

No service can promise perfect security. If a breach affects your personal information and creates a real risk of significant harm, we will notify you and the appropriate regulator as the law requires.

8. Where your information goes

We and our service providers operate in Canada, the United States and the European Union, so your personal information may be stored or processed outside the province or country where you live, and may be accessible to the courts and authorities of those places under their laws.

Where we transfer personal information out of the European Economic Area or the United Kingdom, we rely on an adequacy decision where one covers the destination — Canada holds a partial adequacy decision from the European Commission — and otherwise on standard contractual clauses with the recipient.

9. Your rights

Wherever you live, you may ask us to give you a copy of the personal information we hold about you, to correct it if it is wrong, or to delete your account and its contents. Write to legal@pencilab.com. We will respond within the time the applicable law allows — thirty days under PIPEDA and PIPA — and we may need to verify who you are first.

If the GDPR applies to you, you also have the right to restrict or object to processing, the right to data portability, the right to withdraw consent where we rely on it (which does not affect processing already carried out), and the right to complain to your supervisory authority.

If you are in California, you have the right to know what we collect and why, to obtain a copy, to request deletion, to request correction, and not to be discriminated against for exercising any of them. We do not sell personal information or share it for cross-context behavioural advertising, so there is nothing for you to opt out of on that front.

10. Children

The Service is a professional tool for commercial real-estate analysis and is not directed at children. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us information, write to us and we will delete it.

11. Changes to this policy

We may update this policy as the Service changes. The date at the top of this page shows when it was last revised, and we will give notice of a material change before it takes effect — by email to account holders, or prominently in the Service.

12. Contact and complaints

For any question about this policy, or to exercise a right under it:

Bockins Holdings Inc., doing business as Pencilab
British Columbia, Canada
legal@pencilab.com

If you are not satisfied with our answer, you may complain to the Office of the Information and Privacy Commissioner for British Columbia, or to the Office of the Privacy Commissioner of Canada. If you are in the EEA or the UK, you may complain to your own supervisory authority instead.