PRIVACY POLICY
Effective date: 2025-10-20
1. Introduction
Welcome to 1001380238 Ontario Inc.
1001380238 Ontario Inc. (“us”, “we”, or “our”) operates https://instituteoffinancialfreedom.com/ (hereinafter referred to as “Service”).
Our Privacy Policy governs your visit to https://instituteoffinancialfreedom.com/ and explains how we collect, safeguard, and disclose information that results from your use of our Service.
We use your data to improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and, together with the Privacy Policy, constitute your agreement with us (“agreement”). We reserve the right to terminate or suspend your access to the Site at our sole discretion, without notice, for conduct that we believe violates these Terms.
2. Definitions
● SERVICE means the https://instituteoffinancialfreedom.com/ website operated by 1001380238 Ontario Inc. and all of its subpages.
● PERSONAL DATA means any information that can be used to identify a living person, either on its own or when combined with other information we have or may get access to. This includes things like your name, email address, phone number, payment details, or any other information that can identify you directly or indirectly.
● USAGE DATA is data collected automatically, either generated by the use of the Service or from Service infrastructure itself (for example, the duration of a page visit).
● COOKIES are small files stored on your device (computer or mobile device).
● DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
● DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
● DATA SUBJECT is any living individual who is the subject of Personal Data.
● THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
3. Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
4. Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
0.1. Email address
0.2. First name and last name
0.3. Phone number
0.4. Address, Country, State, Province, ZIP/Postal code, City
0.5. Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any or all, of these communications from us by following the unsubscribe link. Where applicable, we process your Personal Data based on your consent, the necessity to perform a contract with you, compliance with legal obligations, or our legitimate interests, provided your rights are not overridden. In the event of a data breach that could compromise your Personal Data, we will notify you and any relevant authorities in accordance with applicable laws.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or access it through any device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
When you access the Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers, and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service, and we hold certain information.
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags, and scripts, to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
0.1. Session Cookies: We use Session Cookies to operate our Service.
0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
0.3. Security Cookies: We use Security Cookies for security purposes.
0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Other Data
While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location, and other data you provide.
5. Use of Data
1001380238 Ontario Inc. uses the collected data for various purposes:
0.1. to provide and maintain our Service;
0.2. to notify you about changes to our Service;
0.3. to allow you to participate in interactive features of our Service when you choose to do so;
0.4. to provide customer support;
0.5. to gather analysis or valuable information so that we can improve our Service;
0.6. to monitor the usage of our Service;
0.7. to detect, prevent, and address technical issues;
0.8. to fulfil any other purpose for which you provide it;
0.9. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
0.10. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
0.11. to provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
0.12. in any other way we may describe when you provide the information;
0.13. for any other purpose with your consent.
7. Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
If you are located in Canada and choose to provide information to us, please note that we may transfer, store, and process your data, including Personal Data, outside of Canada in jurisdictions that may have different data protection laws than Canada. By providing your information, you consent to such international transfers and processing.
Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer.
Your personal data is stored on servers located in the United States of America. Where personal data is transferred internationally, we implement appropriate safeguards, such as Standard Contractual Clauses, to protect your information in accordance with United Kingdom General Data Protection Regulation (UK GDPR), European Union General Data Protection Regulation (EU GDPR), and Personal Information Protection and Electronic Documents Act (PIPEDA).
1001380238 Ontario Inc. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
8. Disclosure of Data
We may disclose personal information that we collect or you provide:
0.1. Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
0.2. Business Transaction
If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
0.3. Other cases
We may disclose your information also:
0.3.1. to our subsidiaries and affiliates;
0.3.2. to contractors, service providers, and other third parties we use to support our business;
0.3.3. to fulfill the purpose for which you provide it;
0.3.5. for any other purpose disclosed by us when you provide the information;
0.3.6. with your consent in any other cases;
0.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
9. Security of Data
The security of your data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We implement reasonable administrative, technical, and physical safeguards to protect personal information in accordance with PIPEDA and applicable OSC guidelines.
10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
You have certain rights regarding the personal information we hold about you under applicable data protection laws, including UK GDPR, EU GDPR, and Canada’s PIPEDA. We take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Specifically, you have the right to:
● Access – Request a copy of the Personal Data we hold about you.
● Rectification – Request correction of any inaccurate or incomplete information.
● Deletion – Request that we delete your Personal Data, subject to legal or regulatory obligations.
● Restriction – Request that we restrict the processing of your Personal Data.
● Objection – Object to our processing of your Personal Data where applicable.
● Data Portability – Receive a copy of your Personal Data in a structured, machine-readable, and commonly used format.
● Withdraw Consent – Withdraw your consent at any time where processing is based on consent.
● Challenge Compliance (PIPEDA) – Challenge our compliance with applicable privacy laws and request that we review our practices.
To exercise any of these rights, please contact us at info@instituteoffinancialfreedom.com. We may ask to verify your identity before responding to requests. Please note that some services may not be available if certain necessary data is removed.
You also have the right to complain with your local Data Protection Authority regarding our collection or use of your Personal Data.
13. Service Providers
We may engage third-party companies and individuals (“Service Providers”) to facilitate the operation of our Service, provide the Service on our behalf, perform Service-related functions, or assist us in analyzing how the Service is utilized. These Service Providers are granted access to Personal Data solely to perform their assigned tasks on our behalf. They are contractually obligated not to disclose or use it for any other purpose.
14. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
15. CI/CD tools
We may use third-party Service Providers to automate the development process of our Service.
16. Behavioral Remarketing
We may use remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize, and serve ads based on your past visits to our Service.
17. Payments
We may offer paid products and/or services through the Service. Payments are processed by third-party providers, such as Stripe. We do not store or collect your payment card details. All payment information is provided directly to the third-party payment processor and is governed by their Privacy Policy. These processors comply with the Payment Card Industry Data Security Standard (PCI-DSS), managed by the PCI Security Standards Council (including Visa, Mastercard, American Express, and Discover), which sets security standards for handling payment information.
18. Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We are not responsible for the content, accuracy, or opinions expressed on third-party sites linked to from our Site. Your interactions with third-party sites are at your own risk.
19. Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
For Canadian users, we do not knowingly collect personal information from children under 13 without parental consent, in accordance with applicable privacy laws.
20. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective, and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
21. Applicability of Canadian Law
If you are located in Canada, your personal information is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA). We are committed to protecting your personal information in accordance with Canadian privacy laws and applicable provincial regulations.
22. Consent
We collect, use, and disclose your personal information only with your consent, except where otherwise permitted or required by law. You may withdraw your consent at any time, but this may limit your ability to use certain features of our Service.
23. Purpose Limitation
We collect personal information solely for purposes that are clearly identified at or before the time of collection. We do not use your information for purposes unrelated to those for which it was collected without your consent.
24. Access and Correction
You have the right to access the personal information we hold about you and to request corrections if it is inaccurate or incomplete. To make such a request, please contact us at info@instituteoffinancialfreedom.com.
25. Retention
We retain personal information until your account is deleted, except where longer retention is required by law or regulatory obligations, including but not limited to compliance with Ontario Securities Commission (OSC) record-keeping requirements.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
26. Disclosure to Third Parties
We do not disclose personal information to third parties for purposes other than those for which it was collected, except with your consent or as required by law or regulatory authorities.
27. Cross-Border Transfers
If your personal information is transferred outside Canada, we ensure that it remains protected by contractual or other safeguards consistent with Canadian privacy laws and applicable regulatory requirements. Transfers are conducted only to jurisdictions with adequate data protection measures or under contractual safeguards.
28. Regulatory Compliance (OSC)
Where required by law or the Ontario Securities Commission (OSC), we may collect, use, and retain personal information to comply with securities regulations, including record-keeping and reporting obligations. By using our Service, you acknowledge that we may share certain information with regulatory authorities as required by law. We may retain transaction records, communications, and compliance-related documents as required under OSC regulations.
29. Complaints and Dispute Resolution
Dispute Resolution
We value our clients and aim to resolve any concerns quickly and fairly. If you have a complaint about our Services, please contact us first at info@instituteoffinancialfreedom.com so we can attempt to resolve the issue informally.
Before pursuing any formal legal action, you agree to follow these steps in order:
1. Notification:
You must notify us in writing of any complaint, concern, or dispute within 15 days of becoming aware of the issue. If you fail to notify us within this period, you agree that your claim is waived and permanently forfeited.
2. Negotiation (within 15 days of notice):
Upon receiving your notice, both parties will attempt in good faith to resolve the matter through direct discussion. We will make every reasonable effort to work with you to find a fair and timely solution. Negotiation efforts must occur and conclude within 15 days from the date we receive your written notice, unless both parties mutually agree to extend this period in writing.
3. Mediation (within 30 days after negotiation):
If negotiation does not resolve the issue, both parties agree to engage in mediation with a neutral mediator to seek a voluntary resolution before proceeding to arbitration or court. Mediation must be initiated within 30 days after the conclusion of the negotiation period. 1001380238 Ontario Inc. is not responsible for any mediation costs.
4. Arbitration (within 45 days after mediation):
If the matter cannot be resolved through negotiation or mediation, it will be submitted to binding arbitration under the rules of the Arbitration Act (Ontario) or the applicable arbitration law in your jurisdiction. Arbitration must be initiated within 45 days after the mediation period concludes. The arbitration will take place virtually or in Ontario, Canada, and the decision of the arbitrator will be final and binding.
5. Litigation:
Only after completing all of the above steps may either party pursue legal action, and only in the courts located in Ontario, Canada.
By agreeing to these Terms, you acknowledge that you must comply with all timelines and exhaust these informal and alternative dispute resolution processes, including the 15-day notification requirement, before bringing any claim to court.
30. Compliance with UK FCA and ASA Regulations
For users located in the United Kingdom:
● Educational Purpose Only: Institute of Financial Freedom and 1001380238 Ontario Inc. are not authorised or regulated by the Financial Conduct Authority (FCA). The information, materials, and services provided through this website are for general educational purposes only and do not constitute financial, investment, tax, or legal advice. You should seek independent professional advice before making any financial decisions.
● No Investment Promotion: Nothing on this website should be interpreted as an invitation, inducement, or recommendation to buy or sell any financial product or service.
● Advertising Standards: All promotional content, marketing, and testimonials appearing on this website comply with the UK Advertising Standards Authority (ASA) and CAP Code requirements.
● Data Protection: We comply with the UK Data Protection Act 2018 and UK GDPR when handling personal data of UK users.
31. ICO Registration
We are registered with the UK Information Commissioner’s Office (ICO) under registration number 00011984147. We collect, use, and store personal data in accordance with the Data Protection Act 2018 and UK GDPR. You have the right to access, correct, or request deletion of your personal data. For more information or to contact the ICO, visit https://ico.org.uk/.
32. Contact Us
If you have any questions about this Privacy Policy, please contact us by email: info@instituteoffinancialfreedom.com
