Last Updated: May 6, 2025

1. INTRODUCTION

1.1 Welcome to Flow Focus Action

Flow Focus Action ("FFA"), a subsidiary business of Bits of Digital Inc. ("we," "our," or "us"), respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website flowfocusaction.com or use our services.

1.2 Policy Scope

This Privacy Policy applies to information we collect:

• On our website

• Through email, text, and other electronic communications

• When you register for our services

• When you purchase our products or services

1.3 Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

2. INFORMATION WE COLLECT

2.1 Personal Information

We may collect the following types of personal information:

• Identity Data: First name, last name

• Contact Data: Email address, telephone number

• Transaction Data: Details about payments to and from you, and details of products and services you have purchased from us

• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website

2.2 Collection Methods

We collect information from you when you:

• Register on our website

• Place an order

• Subscribe to our newsletter

• Respond to a survey

• Fill out a form

• Book a coaching session

• Use or view our website via your browser's cookies

2.3 Information We Do Not Collect

We do not collect:

• Special categories of personal data (such as details about your race, ethnicity, religious beliefs, health information, or sexual orientation)

• Financial information directly (all payment processing is handled through our secure third-party payment processors)

3. HOW WE USE YOUR INFORMATION

3.1 Lawful Basis

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

• Where we need to comply with a legal obligation

3.2 Purposes for Processing

We may use the information we collect from you for the following purposes:

• To register you as a new customer

• To process and deliver your order

• To manage our relationship with you

• To provide you with the services you have requested

• To send you transactional information

• To send appointment and call reminders

• To send you marketing and promotional communications (only if you have expressly opted in)

• To improve our website, products/services, and customer service

• To administer and protect our business and website

• To deliver relevant website content to you

• To use data analytics to improve our website, products/services, marketing, and user experience

4. DISCLOSURE OF YOUR INFORMATION

4.1 Service Providers

We may share your personal information with service providers we use to support our business, including:

• Payment processors (such as Stripe)

• Email service providers

• Web hosting providers

• Analytics providers (such as Google Analytics and Facebook Pixel)

These third parties are only permitted to use your personal data for specified purposes and in accordance with our instructions.

4.2 Legal Requirements

We may disclose your personal information where required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction.

4.4 With Your Consent

We may disclose your personal information for any other purpose with your consent.

5. DATA SECURITY

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorized way. These measures include:

• Using secure protocols for communication and transferring data (such as HTTPS)

• Using secure payment processors that adhere to PCI DSS standards

• Password protection and encryption of sensitive data

• Limiting access to personal information to personnel who need to know

Despite our best efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

6. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data

• The potential risk of harm from unauthorized use or disclosure of your personal data

• The purposes for which we process your personal data

• Whether we can achieve those purposes through other means

• The applicable legal, regulatory, tax, accounting, or other requirements

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 What Are Cookies

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites function and to provide analytics information.

7.2 How We Use Cookies

We use cookies to:

• Understand and save user preferences for future visits

• Compile aggregate data about site traffic and site interactions

• Enhance the user experience on our website

• Track users' engagement with our marketing campaigns

7.3 Types of Cookies We Use

• Essential Cookies: Required for the operation of our website

• Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our website

• Functionality Cookies: Enable us to personalize content for you

• Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed

7.4 Third-Party Cookies

We use Google Analytics and Facebook Pixel, which may set cookies on your browser. These third parties may use cookies, web beacons, and other storage technologies to collect information about your use of our website and other websites.

7.5 Managing Cookies

Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impact your overall user experience.

8. YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information:

8.1 For Users in Canada

Under the Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial privacy laws, you have the right to:

• Access your personal information

• Correct inaccurate or incomplete information

• Withdraw consent for the collection, use, or disclosure of your personal information

• File a complaint with the relevant privacy commissioner

8.2 For Users in the European Economic Area (EEA)

Under the General Data Protection Regulation (GDPR), you have the right to:

• Access your personal data

• Rectify inaccurate personal data

• Erase your personal data

• Restrict processing of your personal data

• Object to processing of your personal data

• Data portability

• Withdraw consent

• Lodge a complaint with a supervisory authority

8.3 For Users in the United States

Depending on your state of residence, you may have specific rights under state privacy laws such as the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and others.

These rights may include:

• Right to know what personal information is collected

• Right to access your personal information

• Right to delete personal information collected from you

• Right to opt-out of the sale of your personal information

• Right to non-discrimination for exercising your privacy rights

8.4 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data.

9. CHILDREN'S PRIVACY

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

10. INTERNATIONAL TRANSFERS

We are based in Canada, but we may process, store, and transfer personal data in countries outside your country of residence. If we transfer your personal data outside your country of residence, we will take appropriate measures to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

11. LINKS TO OTHER WEBSITES

Our website may contain links to other websites that are not operated by us. If you click on 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.

12. COMMUNICATION POLICIES

12.1 Phone Number Usage

When you provide us with your phone number, we will:

• Only use it for appointment reminders and scheduled coaching calls

• Never use it for cold calling, telemarketing, or sales solicitations

• Never send promotional SMS messages unless you have specifically opted in

• Never share your phone number with third parties for marketing purposes

12.2 Email Communication Policy

When you provide us with your email address, we will:

• Use it primarily for transactional emails and service-related communications

• Only send appointment confirmations, reminders, and follow-ups related to services you've purchased

• Never send spam or unsolicited promotional content

12.3 Marketing Communications Opt-In

We will only send you marketing communications when you have expressly opted in to receive such communications by checking the relevant opt-in box or providing express consent through another clear affirmative action.

12.4 Opt-Out Options

You can opt out of receiving any communications from us at any time by:

• Clicking the "unsubscribe" link in any email we send you

• Replying "STOP" to any text message (if applicable)

• Contacting us directly using the information in the "Contact Us" section

13. CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Flow Focus Action

A Subsidiary of Bits of Digital Inc.
Toronto, Canada—

1 Concorde Gate, Suite 702

ON M3C 3N6

Email: [email protected]

Phone: (647) 492-8446

14. COMPLAINT PROCEDURE

If you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us first. We will investigate your complaint and work with you to resolve the issue.

If you are not satisfied with our response, you may have the right to lodge a complaint with a data protection authority or other regulatory agency.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.