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Legal / Legal notice
Draft · not in forceVersion 0.2Last changed 2026-09-20

Legal Notice and Company Details

Who Troy is, in the sense a register would recognise: the company behind troy-agency.com, the group it sits in, how to reach a person, and where a legal notice would be served. The name, the address and the jurisdiction are settled. The incorporation is not finished, so there is no corporation number yet.

Who this applies to
  • Anyone visiting troy-agency.com who wants to know who is behind it
  • Anyone checking Troy’s details before signing, paying or granting access
  • Anyone who needs to serve a legal notice, a complaint or a claim on Troy
  • Anyone who is a customer of Troy’s sister company and wants to know what that means

Read this first

This is a working draft written alongside the site. It has not been reviewed by a lawyer, it is not in force, and it does not create obligations for anyone. Company details shown as [like this] are decisions Troy has not made yet. The contract you sign governs.

Contents

  1. 1What this page is, and why a company publishes one
  2. 1.1What a page like this has to carry
  3. 1.2What this page does not do
  4. 2The company
  5. 2.1Two names, and which one binds
  6. 2.2Register, number and registered office
  7. 2.3Where Troy is established, and where it is not
  8. 2.4What the company does
  9. 3The group
  10. 3.1What the relationship is
  11. 3.2What the relationship is not
  12. 3.3Notices about the group
  13. 4How to reach a person
  14. 4.1A person answers
  15. 4.2There is no telephone number
  16. 4.3What not to send to these addresses
  17. 5Data protection contacts and representatives
  18. 6Tax registration
  19. 7Regulated activities and supervisory bodies
  20. 7.1The rules that apply whether or not anyone is licensed
  21. 7.2Certifications Troy does not hold
  22. 8Responsibility for what is on this site
  23. 8.1Claims about other companies
  24. 8.2If something on this page is wrong
  25. 9The site itself
  26. 9.1What this site does with your visit
  27. 9.2Where the site runs
  28. 10Complaints and dispute resolution
  29. 10.1Alternative and online dispute resolution
  30. 10.2If you are a consumer
  31. 11How to serve a legal notice on Troy
  32. 11.1What a notice should contain
  33. 11.2Notices from Troy to you
  34. 11.3No agent for service outside Canada
  35. 12When this page changes

1What this page is, and why a company publishes one

In plain EnglishMost countries make a business that sells online say who it is. This is that page. Almost all of it is filled in now. The one thing missing is the corporation number, because the incorporation has not finished.

This is Troy’s legal notice: the page that says which company stands behind troy-agency.com, where that company is registered, and how to reach a person who can answer for it. Canada has no single rule with a name for this page. The requirements are spread across corporate law, which expects a corporation to identify itself; consumer and electronic commerce rules in the province; and the identification rules in Canada’s anti-spam legislation, which apply to any commercial message Troy sends. Elsewhere the same page has a name — an Impressum in Germany, a company details block in the United Kingdom. Different rules, one purpose: you should never have to guess who you are dealing with.

Troy Agency Inc. is being incorporated federally, under the Canada Business Corporations Act, with its registered office in Ontario. That much is decided and this page names it. What has not happened is the incorporation itself: there is no corporation number, and a corporation number is the thing that lets anyone check that the company they are dealing with is the one they think it is. Rather than print a plausible number, this page leaves a blank carrying the question.

Why the blank is the point

A legal notice is the one page where a company cannot round up. A name that is nearly right, an address that used to be right, a registration number belonging to a different entity — each is worse than nothing, because somebody will try to rely on it. The name, the address, the jurisdiction and the addresses on this page are real. The corporation number is absent, because there is not one yet, and until there is there is no corporation.

1.1What a page like this has to carry

In plain EnglishThe rules differ by country. Troy sells in Canada and the United States, and this page answers the strictest version of the checklist rather than the easiest.

Troy’s markets are Canada and the United States. Troy does not offer its services to people in the European Union or the United Kingdom yet. The table below is the checklist identification rules in those markets tend to share, and where each item sits on this page. Where an item is missing, the row still exists: an absent answer is information too.

What identification rules typically require, and where it is on this page
What is requiredWhere it is
The legal name of the operatorclause 2
The register it is held on, and the registration numberclause 2.2
A geographic address, not a post boxclause 2.2
Contact details allowing rapid, direct and effective communication, including an email addressclause 4
A tax registration number, where the operator has oneclause 6
The supervisory body, where the activity is a regulated professionclause 7
Who is responsible for the content published on the siteclause 8
What dispute resolution is available, and where a dispute would be heardclause 10

1.2What this page does not do

In plain EnglishThis page says who Troy is. Four other pages say what Troy does with your data, what it protects, and what you are agreeing to.

  • It is not a contract. The website terms govern your use of this site, and a signed agreement governs an engagement.
  • It does not say what Troy does with personal data. The privacy notice does that, and the cookie page covers what this site stores in your browser.
  • It does not say how Troy protects anything. The security statement does, and it is honest about how little is built.
  • It is not proof that Troy exists as a registered company. Until clause 2.2 carries a corporation number, it is evidence of the opposite.

2The company

In plain EnglishThe name that will sign a contract, the address it will be served at, and the number that does not exist yet.

troy-agency.com is published by the business being incorporated as Troy Agency Inc., trading as Troy.

Legal name
Troy Agency Inc.
Trading name
Troy — the name used on this site, in proposals and in conversation.
Incorporating
federally, under the Canada Business Corporations Act, with its registered office in Ontario.
Corporation number
To be completed: There is no corporation number yet, which means the federal incorporation has not completed. Until it has, Troy Agency Inc. is an intended name rather than a company: it cannot sign a contract, and calling itself “Inc.” in one would be wrong. This is the first thing to finish.[companyNumber]
Registered office
Unit 6, 10651 Keele Street, Maple, Ontario L6A 3Y9, Canada
Jurisdiction
Ontario, Canada
Markets
Canada and the United States. Troy does not offer its services to people in the European Union or the United Kingdom yet.
Part of
Lunari Group, alongside Louin. See clause 3.
Website
troy-agency.com
Contact
troy@louin.io. The full list is at clause 4.

The incorporation has not completed

A corporation exists from the moment the register says it does, and the register has not said so yet. Until it has, Troy Agency Inc. is an intended name rather than a company, nothing on this site is a statement issued by a registered company, and Troy does not sign anything in that name. This is the first thing being finished, and this page changes the day it is.

2.1Two names, and which one binds

In plain EnglishTroy is the name you see. The registered name is the one that will sign and be sued, once it exists.

Troy is the name on this site. Troy Agency Inc. is the name that will sign a contract, receive a notice and appear on an invoice. Where the two differ, the legal name is the one that matters, and it is the one a court would want.

The site lives at troy-agency.com. A domain is not an entity, and registering one is not registering a company. Neither the domain nor the product names used on this site — Troy Score, Agents, Yourself — is a separate business. An earlier domain is not in use and nothing on this site should be read as pointing at one.

2.2Register, number and registered office

In plain EnglishThe jurisdiction and the office are real and checkable. The number is not, because the incorporation has not completed.

Troy is being incorporated federally, under the Canada Business Corporations Act, with its registered office in Ontario, which puts its jurisdiction at Ontario, Canada. Corporation number: To be completed: There is no corporation number yet, which means the federal incorporation has not completed. Until it has, Troy Agency Inc. is an intended name rather than a company: it cannot sign a contract, and calling itself “Inc.” in one would be wrong. This is the first thing to finish.[companyNumber]. Registered office: Unit 6, 10651 Keele Street, Maple, Ontario L6A 3Y9, Canada.

Not decided yet

A corporation number identifies one entity on one register, and it is issued when the incorporation completes. Troy has none, so there is nothing to check and no entry to check it against. This page does not put a placeholder in its place, and nothing on this site should be read as a claim that the corporation already exists.

There is no corporation number yet, which means the federal incorporation has not completed. Until it has, Troy Agency Inc. is an intended name rather than a company: it cannot sign a contract, and calling itself “Inc.” in one would be wrong. This is the first thing to finish.

The registered office is a real address in Ontario where a document can be delivered to a place and a person, rather than a post box. Federal corporate law expects a corporation to keep one and to keep it current; that is what the address above is for, and it is the address in clause 11.

When the number is issued, this page is updated before any other, because several of the other documents read the same company details from the same place.

2.3Where Troy is established, and where it is not

In plain EnglishCanada, with a registered office in Ontario. Not the EU, not the UK, and nothing on this site should be read as a presence anywhere else.

Troy is Canadian. It is being incorporated federally, under the Canada Business Corporations Act, with its registered office in Ontario — the address is at clause 2.2. Its markets are Canada and the United States. Troy does not offer its services to people in the European Union or the United Kingdom yet. Expecting a customer in a country is not being established in it, and Troy claims no establishment, branch or office outside Canada.

One thing cuts across that. Troy is Canadian, but this site and the data behind it run in the United States — see clause 9.2. A Canadian client has a right to know their data leaves Canada, so it is said on this page as well as in the privacy notice rather than left for somebody to discover.

Nothing incidental should be read as an answer either. Prices are quoted in United States dollars; that is a pricing decision, taken because the first customers are in two countries, and it says nothing about where tax is due.

Six answers that followed from one decision

Where Troy is incorporated decided six things at once: the governing law of a Troy contract is the laws of the Province of Ontario and the federal laws of Canada applicable in it; disputes go to the courts of the Province of Ontario; a privacy complaint goes to the federal privacy commissioner, named at clause 5; whether Troy needs a representative in the EU or the UK is answered in the same place; the tax position is at clause 6; and the minimum period Troy has to keep its records follows from Canadian tax and limitation law. That is why the same decision shows up on six documents.

2.4What the company does

In plain EnglishMarketing work, done by people, inside accounts the client owns. A platform is being built out of it. There is no insurance behind it.

Troy sells marketing. Today that means one thing in practice: strategists running a client’s marketing on the client’s own accounts. A free Troy Score, prepared by a strategist from read-only access, is the way in. A Fix Sprint is a fixed piece of work at a fixed price. The agent tier and the self-serve tier are on the public price table with availability labels on them, and they are not on sale.

Four facts about the shape of that business belong on an identification page, because they change who you are dealing with and what you are exposed to.

  • Troy does not hold client media money. Clients pay the advertising platforms directly, on their own accounts and under their own contracts with those platforms. Troy is not a payment intermediary and does not take a percentage of media spend.
  • A client owns their accounts, their data and their access tokens. Access is granted by the client inside the platform that owns it, and can be revoked at any moment without asking Troy. What that access does not keep separate is set out at clause 3.
  • Nothing reaches an audience or spends money without a named person approving it. That rule does not depend on a product existing: today a strategist’s work lands as a paused ad or an unsent draft, and the record of what changed is kept by hand against the client’s file. The approval queue, the hard spend cap and the permanent change log described elsewhere on this site are how Troy intends to hold the same rule in software. None of that is built yet.
  • Troy holds no professional indemnity and no cyber insurance. There is no insurer standing behind an error, so what you could recover is what Troy can pay and what the signed agreement says. Buying cover is on the list of things to do before Troy takes spend authority on a large account; it is not bought, and this page will not imply that it is.

The Troy Score is free and is not a prediction. It grades what is in the connected accounts and shows the evidence for each point. It does not forecast results, and Troy does not claim that it does.

Where the work uses AI, the models come from OpenAI and Anthropic. Troy makes no commitment to any content-provenance or watermarking standard today. It labels AI-made work in the approval queue and tells the client what was AI-made. Which plan each provider is used under, and whether that plan lets the provider train on what Troy sends, is To be completed: Which plan is each of OpenAI and Anthropic used under, and does that plan allow the provider to train on what Troy sends? Both say their business and API terms exclude training by default, but the answer depends on the plan and has to be confirmed rather than assumed — a client will ask, and the sub-processor list has to state it.[aiVendorTerms] — the AI disclosure page and the sub-processor list are where the answer belongs once it exists.

3The group

In plain EnglishTroy sits inside a group, alongside a sister company. The companies share systems and share data. What makes that lawful is not settled.

Troy is part of Lunari Group. Its sister company is Louin, at https://www.louin.io.

That is not only a question of who owns what. Troy, Louin and Lunari Group share systems and data. Client data is held on systems Lunari Group runs, and the companies in the group can see each other's data. Anyone dealing with Troy is entitled to know that before they send Troy anything, which is why it is on the identification page and not only in the privacy notice.

Louin is a separate company with its own customers, its own contracts and its own obligations to them. Separate companies, shared systems: both statements are true at once, and the second is the one people do not expect. Some of Troy’s earliest conversations also come from that network rather than from cold outreach.

Under Canada’s federal private-sector privacy law, the Personal Information Protection and Electronic Documents Act, using someone’s personal information for a purpose they were not told about generally needs their meaningful consent. What makes the sharing inside the group lawful, and how the people whose data moves are told and given a way to refuse, is not settled: To be completed: What makes the sharing lawful, and how is it disclosed? Under PIPEDA, using someone's personal information for a purpose they were not told about needs meaningful consent, and a Louin customer has not agreed to their data being used for Troy's marketing. This needs, at minimum: a written agreement inside Lunari Group, notice to the customers whose data moves, a way for them to say no, and a record of consent. This is the most serious open item on this page — the site now discloses the sharing, but disclosure alone is not a lawful basis.[intraGroupBasis]. This page describes what happens. It does not say the arrangement is consented to, covered by an agreement, or lawful.

Because Lunari Group runs the systems client personal data sits on, it is a processor of that data. It belongs on Troy’s sub-processor list, with the same entry as any outside supplier, rather than in a footnote about corporate structure.

3.1What the relationship is

In plain EnglishSame group, same systems, shared data, shared introductions. The connection is one you can check yourself.

  • A common group. Troy and Louin both sit inside Lunari Group.
  • Shared systems. Client data is held on systems Lunari Group runs and administers, not on systems Troy alone controls.
  • Shared data. The companies in the group can see each other’s data, and that includes what you send Troy.
  • Shared engineering, at least in the early months, from the same place and on the same systems.
  • Introductions. Some of the first people Troy speaks to already know Lunari Group or Louin, and an introduction is how the conversation starts.
  • A connection you can check for yourself, at https://www.louin.io, rather than an unexplained resemblance between two companies.

3.2What the relationship is not

In plain EnglishThere is no wall between the companies on data, and this page no longer says there is. Three other things the group still is not.

An earlier version of this page told you the companies were held apart on data. They are not, so that has been taken out rather than softened. What is true is above: Troy, Louin and Lunari Group share systems and data. Client data is held on systems Lunari Group runs, and the companies in the group can see each other's data.

  • It is not a guarantee. Louin does not stand behind Troy’s obligations and Troy does not stand behind Louin’s. If your contract is with Troy, only Troy owes you anything under it. That is about money and obligations — on data the companies are not held apart at all.
  • It is not a limit on who Troy serves. Louin’s customers are where Troy starts, not who Troy is for.
  • It is not written down. The terms between Troy and the rest of Lunari Group — the shared systems, the shared data, borrowed engineering, who owns the resulting work, referral terms — still have to be agreed at arm’s length and recorded. Nothing on this page should be read as a statement that an agreement exists: To be completed: What makes the sharing lawful, and how is it disclosed? Under PIPEDA, using someone's personal information for a purpose they were not told about needs meaningful consent, and a Louin customer has not agreed to their data being used for Troy's marketing. This needs, at minimum: a written agreement inside Lunari Group, notice to the customers whose data moves, a way for them to say no, and a record of consent. This is the most serious open item on this page — the site now discloses the sharing, but disclosure alone is not a lawful basis.[intraGroupBasis].
  • It is not a reason to send Troy more than it needs. If information would be a problem on a system the group runs, the safest thing is not to send it. Write to privacy@louin.io first and ask.

If you are a customer of Troy’s sister company

The honest answer is that being a customer of one company in this group is not the same as being a customer of only that company. Your records sit on systems Lunari Group runs, and the companies in the group can see each other’s data. Using your information for Troy’s marketing would be a purpose you were not told about when you gave it, and under PIPEDA a new purpose generally needs your meaningful consent. Nobody has asked you for it, and this page does not claim you gave it. If you want to know what is held about you, or want it kept out of Troy’s work, write to privacy@louin.io.

Not decided yet

The sharing is disclosed here because disclosure is owed either way. Disclosure is not a lawful basis, and this page does not claim one. What is missing is the written agreement inside Lunari Group, notice to the people whose data moves, a way for them to say no, and a record of what they agreed to. It is the most serious open item on this site, and it is open rather than quietly assumed.

What makes the sharing lawful, and how is it disclosed? Under PIPEDA, using someone's personal information for a purpose they were not told about needs meaningful consent, and a Louin customer has not agreed to their data being used for Troy's marketing. This needs, at minimum: a written agreement inside Lunari Group, notice to the customers whose data moves, a way for them to say no, and a record of consent. This is the most serious open item on this page — the site now discloses the sharing, but disclosure alone is not a lawful basis.

3.3Notices about the group

In plain EnglishSend a notice to the company it is about. Shared systems do not make the companies one company.

A notice about Troy goes to Troy, in the way clause 11 sets out. A notice about Louin goes to Louin, whose own site at https://www.louin.io carries its details. Serving one on the other does not count as serving the other, and Troy will say so rather than pass it along quietly.

Sharing systems does not merge the companies. Each is responsible for its own obligations, and a claim against one is not a claim against another. That is a point about corporate liability, and it does not change anything about data: on data the arrangement is as described above.

4How to reach a person

In plain EnglishFour addresses on Troy’s own domain. All four are live and each one is read by a person.

Identification rules in Canada and the United States, and the sender-identification rules in Canada’s anti-spam legislation, come down to the same practical thing: an address that reaches a human being, published in plain sight, rather than a form behind three clicks. Troy publishes four, all on troy-agency.com.

Where to send what
What you wantWhere it goes
Anything at all, including when you are not suretroy@louin.io
A legal notice, a complaint or a claimtroy@louin.io
A privacy request, or a question about your dataprivacy@louin.io
A security weakness in this sitetroy@louin.io
A part of this site that does not work for youtroy@louin.io
A correction to this pagetroy@louin.io

Privacy has its own address on purpose. PIPEDA gives a person the right to ask what personal information an organisation holds about them and to have it corrected, and it expects an answer inside a set time — generally thirty days from the request. An address shared with sales is an address where that clock gets missed. Write to privacy@louin.io and say what you want; there is no form to fill in.

4.1A person answers

In plain EnglishNo bot, no ticket number. Also no promised reply time, because Troy has never measured one.

Troy is small and pre-launch. A message to troy@louin.io is read by a person rather than sorted by a system. There is no chatbot on this site, no automated agent answering on Troy’s behalf, and no auto-reply written to sound like one.

What this page does not carry is a response time. Troy has never measured one, and a published time nobody has met is worse than no time at all. What you can expect is a reply from a named person rather than a ticket number.

4.2There is no telephone number

In plain EnglishSome rules expect one. Troy has none to publish, and does not invent one.

Identification rules in several markets ask for a telephone number, or for an equivalent means of rapid contact. Troy publishes no number. Email is the channel it can actually answer, so email is the channel it publishes, and it does not list a line that would ring in an empty room.

Where a rule asks for a mailing address as well — the identification requirements in Canada’s anti-spam legislation are the usual example — the address is Unit 6, 10651 Keele Street, Maple, Ontario L6A 3Y9, Canada, and it is on this page for that reason as much as for service.

If you need to speak to somebody, write to troy@louin.io and say so.

4.3What not to send to these addresses

In plain EnglishNever a password or a key. Nobody at Troy will ask you for one.

  • Passwords, API keys or access tokens. Troy asks for access to be granted inside the platform that owns it, and never by sending a credential. Nobody at Troy will ask you for a password.
  • The contents of an advertising or commerce account as an attachment. Read-only access, granted and revoked by you, is both safer and more useful.
  • Personal data belonging to somebody else, unless you have a reason to be sending it. Email is the easiest place in the world to over-share, and what arrives sits on systems Lunari Group runs — see clause 3.
  • Anything you would not want another company in the group to see. That is a real constraint rather than a caution, for the reason given at clause 3.

5Data protection contacts and representatives

In plain EnglishNo data protection officer is named. No representative in the EU or the UK, because Troy does not sell there. Privacy complaints go to the federal privacy commissioner.

The privacy notice explains what Troy does with personal data and what you can ask for. This page carries only the identification part: who a regulator, or a person exercising a right, would formally be dealing with.

Data protection roles
RoleStatus
Data protection officerNo individual is named on this site. Privacy questions reach the person accountable for privacy at Troy through the address below
Representative in the European Unionnone appointed. Troy does not offer its services to people in the European Union, and will appoint a representative there before it does
Representative in the United Kingdomnone appointed. Troy does not offer its services to people in the United Kingdom, and will appoint a representative there before it does
Supervisory authoritythe Office of the Privacy Commissioner of Canada. People in the EU or the UK may also complain to their own national authority

No individual is named on this site. Privacy questions reach the person accountable for privacy at Troy through the address below. That address is privacy@louin.io. PIPEDA makes an organisation accountable for the personal information under its control and expects it to make someone responsible for that; Troy has not published a name, and a role without a name is worth stating plainly rather than dressing up as an office.

Troy’s markets are Canada and the United States. Troy does not offer its services to people in the European Union or the United Kingdom yet. The two representative rows follow from that. In the European Union: none appointed. Troy does not offer its services to people in the European Union, and will appoint a representative there before it does. In the United Kingdom: none appointed. Troy does not offer its services to people in the United Kingdom, and will appoint a representative there before it does. If Troy does start offering services to people in the EU, Article 27 of the GDPR would require a representative there, appointed in writing and reachable by anyone who wants to use a right, and the UK asks the same question separately under its own version of that law. That is context for a market Troy has not entered, not a claim that Troy has met either requirement.

Naming a representative who has not been appointed would be worse than saying none exists, because somebody could rely on it and get nowhere. So the rows say none.

A complaint about how Troy handles personal information can go to the Office of the Privacy Commissioner of Canada. People in the EU or the UK may also complain to their own national authority. A resident of a US state with its own privacy law keeps whatever that law gives them. Those rights do not depend on Troy publishing a name here, and Troy would rather answer the complaint first — see clause 10.

6Tax registration

In plain EnglishTroy is not registered for GST/HST, so there is no number to publish and no Canadian sales tax on the published prices.

Identification rules ask for a tax registration number where the operator has one. Troy is not registered for GST/HST, so no Canadian sales tax is added to the published prices. That changes once Troy passes the small-supplier threshold, and this page will say so when it does. There is therefore no number on this page, and Troy does not display one belonging to anybody else.

Prices on this site are quoted in United States dollars. Whether a client outside Canada owes tax of its own on a service bought from a Canadian supplier is a question for that client’s own advisers; Troy does not collect it and does not advise on it.

Whether a published price is quoted before or after tax is a term of business, and it belongs in the terms that govern an engagement rather than on an identification page. What belongs here is the registration status, and it is above.

7Regulated activities and supervisory bodies

In plain EnglishMarketing is not usually a licensed profession. That is not the same as being unregulated.

Some identification rules apply only to regulated professions — the ones where a person needs a licence to practise and a named body supervises them. Lawyers, accountants, doctors, financial advisers and insurance brokers are the usual examples, and each has to publish its regulator, its licence and the law it practises under.

Marketing and advertising services are not, as a general matter, a licensed profession in the markets Troy serves. Troy holds no professional licence, is supervised by no professional body, and does not claim otherwise.

Hedged, on purpose

That is a general statement rather than legal advice, and no lawyer has checked it against Ontario, against federal Canadian law or against any US state. Whether a registration, a licence or a supervisory body applies depends on what Troy ends up doing as much as on where it sits. Advising on credit, handling client money, or marketing inside a regulated sector such as health, finance or gambling can each pull ordinary marketing work into regulated territory. It is one of the first questions for counsel, and the answer belongs on this page when there is one.

7.1The rules that apply whether or not anyone is licensed

In plain EnglishNeeding no licence is not the same as having no rules. These bind any advertiser, including Troy.

Not being a regulated profession is not the same as being unregulated. The rules Troy answers to are about what it says and what it does, and they bind any advertiser. What follows is a description of the landscape, not advice, and not a claim that Troy complies with any of it.

  • Advertising and consumer protection law in each market Troy sells in, covering claims, endorsements, reviews, testimonials and comparisons. In Canada the Competition Act’s provisions on false or misleading representations are the usual reference point, and the US regulator is prosecuting inflated AI claims and fake reviews. Troy keeps evidence on file for every claim it makes about itself, and publishes no client names, logos, testimonials, case studies or results it cannot substantiate. Today it publishes none at all.
  • Privacy law. Federally in Canada that is PIPEDA, overseen by the Office of the Privacy Commissioner of Canada. People in the EU or the UK may also complain to their own national authority. In the United States it is the state privacy laws, California’s in particular. The privacy notice and the data processing addendum set out the detail, including that Troy acts as a processor for the marketing data it handles for a client, and including the part this page describes at clause 3.
  • Canada’s anti-spam legislation, CASL, wherever a commercial electronic message is in scope. It asks for consent before a message is sent, identification of who sent it and on whose behalf, and an unsubscribe that actually works. On a Troy engagement the client is the sender: Troy drafts, the client approves, and Troy does not send without that approval. The client attests that its list consented, and Troy does not import lists. Whether a particular message needs express or implied consent is a question about that client’s list, not one this page can answer for it.
  • Transparency rules on AI-generated content. Article 50 of the EU AI Act has applied since 2 August 2026 and reaches companies outside the EU that put content in front of people there; Troy does not offer services in the EU, so it is context rather than the thing driving Troy’s own practice. Troy makes no commitment to any content-provenance or watermarking standard today. It labels AI-made work in the approval queue and tells the client what was AI-made. The AI disclosure page sets out what gets labelled, and when the label is shown to a client for approval.
  • The advertising platforms’ own policies, which sit on top of all of the above and are enforced faster than any of them.

7.2Certifications Troy does not hold

In plain EnglishNone. Listed here so that nobody has to go looking.

Troy holds no security certification, no privacy certification, no quality standard and no industry accreditation. It is not SOC 2 audited. It is not certified to ISO 27001 or to any other standard. It has no badge, seal or scheme membership to display, and it displays none. There is no insurance behind the work either: Troy holds no professional indemnity and no cyber insurance, and clause 2.4 says what that means in practice.

It also does not describe itself as compliant with any law. Compliance is a conclusion an authority reaches, not an adjective a company awards itself. What Troy publishes instead is what it actually does — in the security statement and the privacy notice, including how little of it is built.

8Responsibility for what is on this site

In plain EnglishTroy wrote it, Troy answers for it, and Troy corrects it when it is wrong.

The business being incorporated as Troy Agency Inc. is responsible for the content published at troy-agency.com. Where a rule requires a named individual to be responsible for editorial content, that person will be named here once the incorporation completes and there is a company to name them in.

Everything on this site is published by Troy and answers to Troy. Nothing on it is sponsored, paid for or supplied by a third party. There are no advertisements on this site, no affiliate links, and no arrangement under which Troy is paid to mention anybody.

Some of what this site publishes is about the future — what Troy intends to build, and in what order. Those are intentions rather than commitments, and the site labels them as such. Anything marked as a preview, a draft or illustrative is exactly that, including the sample screens and the sample report.

8.1Claims about other companies

In plain EnglishIf a Troy page says something about another company, it links to that company’s own source. No source, no claim.

Where a Troy page says something about another company — an advertising platform’s access policy, a competitor’s published price — it carries a link to that company’s own source. If Troy cannot source a claim, it does not make it. If a source has since changed and a Troy page is now wrong, write to troy@louin.io and it will be corrected or taken down.

Names, logos and marks belonging to other companies are used on this site only to identify their products. Their owners do not endorse Troy, are not associated with it, and nothing on this site implies that they are.

8.2If something on this page is wrong

In plain EnglishTell Troy and it gets fixed first, ahead of anything else on the site.

A legal notice is the page where an error matters most and gets noticed least. If a detail here is wrong, out of date or missing, write to troy@louin.io with the detail and what it should say instead. Corrections to this page are made before anything else on the site, and the version history at the bottom records them.

9The site itself

In plain EnglishBuilt and run by Troy. Its design system is published in the open at /design.

troy-agency.com is designed, built and operated by Troy. It is not a template, it was not bought in, and no agency made it. That is worth stating on a marketing company’s own site, because the site is the first piece of Troy’s work anybody can judge.

The design system behind it is published at /design: the colours, the type scale, the motion rules, the components and the endorsement lockups, on one page, in the open. Publishing it at all is unusual, and listing it on a legal notice more unusual still. It is here for the same reason the Score formula is published and these drafts are published while they are still drafts — a company asking to be trusted with somebody else’s marketing should be legible from the outside.

9.1What this site does with your visit

In plain EnglishAlmost nothing. No analytics running, no cookies from Troy, and one saved setting that stays on your device.

Very little, and the cookie page says so in detail. The analytics Troy has chosen is Vercel Analytics, which is cookieless and does not track anyone across sites (a proposed default, not yet approved)? — chosen, but not installed, so nothing is measuring you today. The site sets no advertising or measurement cookies, and there is no consent banner because there is nothing to consent to. The one thing kept in your browser is the appearance you choose — the theme, the spacing density and the accent colour, saved under a single key — and it never leaves your device.

Whether the host sets a strictly necessary cookie of its own once the site is deployed — for routing, load balancing or a bot check — is To be completed: Whether Vercel sets a strictly necessary cookie of its own on this project once deployed — routing, load balancing or a bot check. Confirm at deploy and list it in the cookie policy.[hostCookies]. The cookie page carries the answer when there is one rather than guessing at it now.

If you send a brief through the form, the privacy notice explains what happens to it. Where it is sent is still open — Google (Gmail). Forms on this site are sent as email to a Lunari Group mailbox, and are not stored in a database — and what arrives sits on systems Lunari Group runs, for the reason at clause 3.

9.2Where the site runs

In plain EnglishOn Vercel, in Washington, D.C. Troy is Canadian and its site is not: the data is in the United States.

Hosting provider: Vercel Inc.. Region: Vercel's Washington, D.C. region (iad1), in the United States.

That is worth reading twice on a page about a Canadian company. Troy is being incorporated in Canada, but this site and the data behind it run in the United States, which means information you send through it crosses the border and is subject to the law of the place it lands, including lawful access by authorities there. A Canadian client has a right to know that before they send anything, so it is on this page rather than only in an annex.

PIPEDA does not forbid sending personal information outside Canada. What it expects, as a general matter, is that the organisation stays accountable for it, uses contractual means to give it comparable protection, and is open about the fact that it happens. What Troy relies on to carry the transfer is the Standard Contractual Clauses, with the UK Addendum where the United Kingdom is involved, entered into through each supplier's own data processing agreement (a proposed default, not yet approved)?. That is a proposed default rather than a checked answer, and the privacy notice and the sub-processor list are where each supplier’s own position is recorded.

When a provider changes, it changes in three places at once — here, on the sub-processor list, and in the privacy notice — because those are the three places a reader would look, and a provider that appears in only one of them is how a sub-processor list goes stale.

10Complaints and dispute resolution

In plain EnglishWrite to Troy first. If that does not work, Ontario law and the Ontario courts. There is no complaints scheme.

Troy would rather answer a complaint than defend one. Write to troy@louin.io, say what happened, and say what you want done. What you should get back is a position rather than a holding line. No time is promised for it, for the reason given in clause 4.1.

If that does not resolve it: any dispute arising out of this site or out of dealings with Troy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable in it, and the courts of the Province of Ontario have jurisdiction over it. That is subject to clause 10.2, and to any mandatory rule of your own country or state that gives you a different court or a different law.

Time matters as much as forum. Ontario’s basic limitation period is two years from the day a claim was discovered, with exceptions and with different periods for some kinds of claim. That is a general statement rather than advice on your situation, and it is here because it is the reason Troy keeps records for as long as it does. Where a Troy contract has been signed, that contract’s own clauses on law, courts and time limits govern and override anything written on this page.

10.1Alternative and online dispute resolution

In plain EnglishTroy belongs to no complaints scheme and does not pretend to. Whether it has to join one is a question for counsel.

Troy is not registered with any alternative dispute resolution body, is not a member of an ombudsman scheme, and does not undertake to use either. This page links to no online dispute resolution platform either, and it does not assert from memory which platform or scheme a trader in any particular market has to name. That is the open question in the box below.

Still to be checked

Whether Troy has to join an alternative dispute resolution scheme, or to tell customers that one exists, depends on the province and on whether it sells to consumers there. Troy sells to businesses, which usually puts those rules out of scope — but “usually” is not an answer, and counsel has not been asked.

10.2If you are a consumer

In plain EnglishTroy sells to businesses. If you are a consumer anyway, consumer law where you live still protects you, and nothing here changes that.

Troy sells to businesses, and its prices, terms and services are written for businesses. If you are nevertheless a consumer, the mandatory consumer law of the place you live applies to you whatever any contract says — in Ontario that is the province’s consumer protection legislation, which generally cannot be contracted out of, and elsewhere it is your own. You can usually bring proceedings where you live and rely on your own protections. Nothing on this page takes either away, and nothing on it is meant to.

Whether a sole trader buying for their own business counts as a consumer differs from place to place, and it is not Troy’s call to make. If you think you might, say so before you sign anything. Troy will treat the question as open rather than assume the answer that suits it.

11How to serve a legal notice on Troy

In plain EnglishThere is an address and an email. There is not yet a corporation to serve, and that distinction matters.

A legal notice — a formal complaint, a claim, a demand, an intellectual property notice, correspondence from a regulator — should go to troy@louin.io, and to Unit 6, 10651 Keele Street, Maple, Ontario L6A 3Y9, Canada where a written address is required. Both are real, both are monitored, and Troy will not argue that a notice sent to either did not arrive.

What is still missing, and why it matters here

Service is done on a legal person. The incorporation has not completed, so Troy Agency Inc. is not yet a corporation and there is no corporation number to name in a document: To be completed: There is no corporation number yet, which means the federal incorporation has not completed. Until it has, Troy Agency Inc. is an intended name rather than a company: it cannot sign a contract, and calling itself “Inc.” in one would be wrong. This is the first thing to finish.[companyNumber]. Whether a notice served today binds anything, and whom it should be addressed to in the meantime, is a question for your own adviser rather than one this page can answer in its own favour. Saying so is more useful to you than a confident address block would be.

Whether service by email counts as service at all depends on the rules of procedure that apply to your claim, and on any contract between you and Troy. Troy’s commitment is about what it does with a message it receives, not about the legal effect of how you sent it. If your notice has to be served in a particular way in order to count, take advice on that before relying on this page.

11.1What a notice should contain

In plain EnglishFive things. A notice with all five gets a useful answer sooner.

  1. Who you are, and who you act for.
  2. What you say happened, with dates.
  3. The page, message, document or account it concerns.
  4. What you want Troy to do, and by when.
  5. How to reply to you.

A notice that arrives with all five is answered faster than one that arrives with two. That is not a rule, it is just what is true.

11.2Notices from Troy to you

In plain EnglishTroy writes to the last address you gave it. If you have signed an agreement, that agreement decides instead.

Troy sends a notice to the last address you gave it in writing. Under an engagement, the signed agreement says which address counts and when delivery takes effect; where it does, it governs and this page does not.

11.3No agent for service outside Canada

In plain EnglishOne registered office, in Ontario. Nobody is appointed to accept legal papers for Troy anywhere else.

Troy’s registered office is at Unit 6, 10651 Keele Street, Maple, Ontario L6A 3Y9, Canada. It has appointed no agent for service of process in any other country and has no registered agent in any US state. It has no office, branch or establishment outside Canada. If you are a client in the United States and you are relying on Troy having a presence where you are, do not — the hosting at clause 9.2 is not an establishment and does not make one.

12When this page changes

In plain EnglishMost of this page was blank a day ago. What is left is listed below, and the version history records each one as it lands.

This page changes when a decision is made, not on a schedule. The version number rises, the date changes, and the version history says what was filled in or taken out. Nothing is edited silently, including a promise that turns out not to be true: version 0.2 removed one, and says so.

Several other Troy documents read the same company details from the same place, so filling a blank here fills it everywhere at once. There is deliberately no way to write a company detail into one document and not another, and no way to write one as free text at all.

This is version 0.2 and it is still a draft. It is not in force, it creates obligations for nobody, and no lawyer has read it. When one has, the status at the top of this page changes from draft to in force — at the top, where it is read, rather than in a footnote. Some values on this page are marked as proposed defaults: they are suggestions written so the document can be read end to end, and a lawyer has to confirm or replace each one.

What is still open on this page, and what settles each one
Still openSettled by
To be completed: There is no corporation number yet, which means the federal incorporation has not completed. Until it has, Troy Agency Inc. is an intended name rather than a company: it cannot sign a contract, and calling itself “Inc.” in one would be wrong. This is the first thing to finish.[companyNumber]Completing the federal incorporation. Until it is done there is no corporation, and this page says so in four places.
To be completed: What makes the sharing lawful, and how is it disclosed? Under PIPEDA, using someone's personal information for a purpose they were not told about needs meaningful consent, and a Louin customer has not agreed to their data being used for Troy's marketing. This needs, at minimum: a written agreement inside Lunari Group, notice to the customers whose data moves, a way for them to say no, and a record of consent. This is the most serious open item on this page — the site now discloses the sharing, but disclosure alone is not a lawful basis.[intraGroupBasis]A written agreement inside Lunari Group, notice to the people whose data moves, a way for them to say no, and a record of consent. The most serious item on this list.
To be completed: Which plan is each of OpenAI and Anthropic used under, and does that plan allow the provider to train on what Troy sends? Both say their business and API terms exclude training by default, but the answer depends on the plan and has to be confirmed rather than assumed — a client will ask, and the sub-processor list has to state it.[aiVendorTerms]Confirming, for each of OpenAI and Anthropic, which plan is in use and whether it allows training on what Troy sends.
To be completed: Whether Vercel sets a strictly necessary cookie of its own on this project once deployed — routing, load balancing or a bot check. Confirm at deploy and list it in the cookie policy.[hostCookies], Google (Gmail). Forms on this site are sent as email to a Lunari Group mailbox, and are not stored in a databaseDeploying the site, and choosing where the brief form posts. Both then go on the cookie page and the sub-processor list.
A telephone number, and a named person responsible for contentBoth wait on there being a company and a second person in it.
the Standard Contractual Clauses, with the UK Addendum where the United Kingdom is involved, entered into through each supplier's own data processing agreement (a proposed default, not yet approved)?Checking what each supplier actually offers, rather than accepting the default written here.
Whether any registration or licence appliesCounsel’s view on Ontario, on federal Canadian law, and on the US states where clients are.

13Version history

Changes to this document
VersionDateWhat changed
0.220 Sep 2026The company, the address, the jurisdiction, the markets, the hosting, the tax position and the contact addresses were settled and are now filled in. The corporation number is still blank because the incorporation has not completed. The group section was rewritten: an earlier draft said Troy held no sister-company data and had no standing access to any, and that is not what happens — the companies share systems and data, and the lawful basis for it is still open.
0.119 Sep 2026First draft, written alongside the site. Not reviewed by a lawyer.

You probably also need

  • PrivacyHow Troy handles personal data. Troy is the controller for its own site visitors, enquirers and client contacts, and a processor for the personal data inside a client’s connected advertising and commerce accounts.
  • Sub-processorsThe companies Troy brings in to help process a client’s personal data, and the rules for adding one. There are four on the list today — the company that hosts this site, the group company whose systems client data sits on, and the two AI vendors Troy drafts with — and this page says what is still unchosen rather than inventing the rest.
  • Website termsThe terms for using troy-agency.com itself: what you may do with what is on it, what it does and does not promise, and where Troy’s responsibility starts and stops. Buying Troy’s work is covered by the service terms, not by these.
  • SecurityWhat Troy is designing its security around, and what it has not built. Troy is pre-launch, so this is a statement of intent rather than a description of controls that exist.
  • AccessibilityWhat troy-agency.com has been built to do for people using a keyboard, a screen reader or a reduced-motion setting; how it has and has not been tested; and the problems Troy already knows about. WCAG 2.2 AA is the target. No conformance is claimed.
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Troy is a Lunari Group company. Its sister, Louin, runs a company’s operations. Troy runs its marketing.

© 2026 Troy Agency · A Lunari Group company
Pre-launch · figures in product previews are illustrative
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