// Cloud Commons Labs · Structure & Governance

THE STRUCTURE.

Two organizations. One mission. Cloud Commons Labs is the commercial builder, the for-profit that does the technical development. Cloud Commons Canada is the public-interest foundation it works alongside. Neither is a subsidiary of the other. Their relationship is governed by the inter-entity agreement.

TWO ENTITIES.
ONE
ECOSYSTEM.

Labs builds the tools. The non-profit holds the data those tools help generate, in trust, governed to benefit the people who created it.

// What the pipeline actually is

When someone uses LEON and opts in, their phone's observations about the personal data economy, including which apps contact which trackers, how many times, and from which jurisdictions, are contributed as an anonymized structural profile. That profile goes into Cloud Commons Canada's governed data infrastructure. CCC holds it in trust on behalf of the contributor. It is not sold. It is not licensed for advertising. It is published openly for researchers, journalists, and policymakers who need a clear picture of how Canada's app ecosystem actually behaves.

Labs' role is to build the tools that make that contribution possible and worthwhile. The for-profit side handles software development, commercial sustainability, and the user-facing product. The non-profit side handles the standards those products must meet, the governance of the data once it arrives, and the public-interest mission that justifies collecting it in the first place.

The structure described on this page is the intended operating framework for Cloud Commons Labs and its relationship with Cloud Commons Canada. The inter-entity agreement is a working draft pending legal review and execution. We operate according to these principles now, and are formalizing them with counsel.

Cloud Commons Canada is a Canadian non-profit. That status provides credibility, access to grants, and legal standing as a public-interest organization. It also creates a constraint: non-profits cannot own commercial software products, issue equity, or raise venture capital. Cloud Commons Labs is the commercial entity those products need. The inter-entity agreement defines how the two work together: the non-profit sets the standards those tools must meet, owns the governed data infrastructure they connect to, and under the agreement's intended structure, will hold an equity stake in Labs, giving it a genuine financial interest in the commercial success of the ecosystem it governs.

Cloud Commons Labs

Where the
Commons Gets Built.

BC Corporation · Incorporated April 2026

  • Builds and owns LEON, Parler, commercial APIs
  • Raises investment capital and grants
  • Issues equity to founders and collaborators
  • Technical development, hiring, product roadmap
  • Dark aesthetic · Technical voice · cloudcommonslabs.ca
Mission guardrails · pipeline access · intended equity stake
Cloud Commons Canada

The Civic
Observatory.

Canadian NFP · 1680382-2 · Vancouver, BC

  • Holds contributed user data in trust, governed to benefit contributors
  • Publishes aggregated findings openly to researchers and policymakers
  • Sets and enforces the standards any tool must meet to write to the commons
  • Owns all consent logic, provenance standards, and governance frameworks
  • Intended equity stake in Labs under the inter-entity agreement
  • Structural veto on any sale that dissolves the relationship

WHAT EACH
ENTITY
OWNS.

The inter-entity agreement defines this boundary precisely. The rules are owned by the non-profit. The implementation of those rules in specific products is owned by Labs. Neither can compromise the other's core asset.

Labs Owns

LEON: software, product, associated technical IP

Parler: software and product implementation (Arcade + Civic)

All commercial APIs, developer tooling, and analytics instruments built by Labs

All technical systems, codebases, and infrastructure operated by Labs

Equity stakes and licensing rights acquired by Labs in third parties

Proprietary algorithms, trade secrets, and software architectures developed by Labs staff

CCC Owns

The Ethical Data Pipeline, in its entirety. Not modifiable by Labs.

All governance frameworks, data standards, and pipeline certification criteria

All consent, provenance, attribution, and value-distribution logic for contributors

The licensing framework that governs how pipeline data can be used

All constitutional policy and standards documents that define the commons

The Cloud Commons brand assets (licensed to Labs under the inter-entity agreement)

Where a Labs product incorporates pipeline governance logic, including consent flows, provenance tagging, and attribution mechanisms, the governance logic remains with CCC and the product implementation remains with Labs. The boundary is between the rules and the product that implements them.

THE FLOOR
THAT CAN'T
BE LOWERED.

Mission Guardrails are principles adopted by the Cloud Commons Canada board as binding conditions of pipeline access. Labs must meet these standards to connect to the pipeline. Violating them is a material breach of the inter-entity agreement, and CCC can suspend pipeline access accordingly.

// Guardrail 01

No Covert Data Collection

Labs products may never collect data about users without explicit, informed consent. Consent flows are governed by the pipeline's consent logic, owned by CCC, not Labs.

// Guardrail 02

Open Outputs

Aggregate public-interest data produced through pipeline contribution must remain openly accessible to researchers, journalists, and policymakers. It cannot be paywalled, sold exclusively, or restricted from public-interest use.

// Guardrail 03

Canadian Data Sovereignty

Labs products that contribute to the pipeline must store and process that contribution within Canadian jurisdiction. This is structural, not policy: the hosting choices are made in advance of any commercial pressure to change them.

// Guardrail 04

No Hostile Transfer

Labs cannot be sold to a buyer who will not assume the inter-entity agreement. The inter-entity agreement provides CCC with a structural veto on any such transaction. This cannot be amended without CCC's written consent.

ACCESS IS
EARNED.
NOT GIVEN.

Labs holds a non-exclusive, non-transferable right to connect its products to the Cloud Commons pipeline, conditional on meeting current pipeline standards and passing CCC's certification process for any product that requests write access.

Labs' Obligations

Conditions of Access

All connected products must meet current pipeline standards. Labs must notify CCC 30 days before any material change that could affect pipeline integrity. Labs must cooperate with CCC audits on reasonable notice.

CCC's Obligations

Standards in Good Faith

CCC publishes pipeline standards openly. Certification requests are processed within 45 business days with written reasons for any denial. CCC gives 60 days' notice of material standard changes that would require Labs to modify a product.

This is a managed relationship, not a dependency. Labs needs the pipeline to deliver on its public-interest mandate. CCC needs Labs to build the tools that make the pipeline useful. The inter-entity agreement formalizes that mutual interest.

THINGS
FUNDERS
ASK.

Does this structure affect CCC's charitable status?

No. A non-profit holding a passive minority equity stake in a related commercial entity is a standard and permitted activity, provided the non-profit does not operationally control the commercial entity. The structure we're building toward is exactly this: CCC influencing Labs through the inter-entity agreement and pipeline standards, not operational control. Labs has its own independent governance.

What happens if Labs does something CCC disagrees with?

The inter-entity agreement addresses this directly. Labs must meet CCC's pipeline standards to connect to the pipeline. If Labs breaches the agreement materially, CCC can suspend pipeline access. If Labs attempts to restructure in a way that severs the relationship, the Articles require CCC's written consent before any such transaction can close.

Can Labs raise venture capital?

Yes. Labs is incorporated as a BC Corporation and can issue equity to investors, founders, and collaborators. The inter-entity agreement and CCC's intended equity stake are designed to remain in place regardless of subsequent investment rounds, unless CCC consents to changes.

Is the ethical data pipeline available to other developers?

Yes. The pipeline standards are published openly. Any developer can build a pipeline-compatible tool and apply for CCC certification. Labs products are not the only applications that can connect to the pipeline. They are the first ones Labs is building.

CCC governance →

WE RESPOND
TO EVERYTHING.

We're a small team in active development. Whether you're an investor, a grant funder, a potential technical collaborator, or a civic institution that wants to understand the structure: write to us. We read everything and respond personally.

If you have questions about the inter-entity agreement, the governance model, pipeline access conditions, or anything on this page, this is the right place to ask.

Or write directly

gregory@cloudcommonslabs.ca

Send a Message

WE'LL BE
IN TOUCH.

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