Privacy Policy

Your privacy is very important to us. Accordingly, we have developed this privacy policy (“Policy”) in order for you to understand how we collect, use, communicate and disclose and make use of Personal Information. We are taking a global approach to data protection to help ensure that you benefit from control and clarity. We are committed to putting you first and working every day to maintain the trust you put in us. 

• GENERAL TERMS

“Agreement” or “contract” means all of the documents which you and the Company have signed, including the Credit Card Authorization Form.

“Client” or “you” means any purchaser, client and/or user of any of our programs and services.

“Company”, “we” or “us” means FXO Consulting Inc.

“Site” means the platform we offer at our website (https://www.fxoconsulting.com).

“Terms of Use” means our Terms of Use, which can be found here: Term of Use.

This Policy is incorporated into, and considered a part of, the Terms of Use.

• OUR COMMITMENT TO PRIVACY

We are committed to protecting your Personal Information (as defined below) by ensuring that your Personal Information is treated with care and is not used or disclosed in ways to which you have not consented or as described in this Policy.

We will only use your Personal Information in accordance with this Policy, unless otherwise permitted or required by applicable law. Please read this Policy carefully to understand our policies and practices for collecting, using, disclosing, processing, storing and deleting your Personal Information. By providing us with your Personal Information and using our Site, you accept this Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.

• PERSONAL INFORMATION

When we use the term “Personal Information” in this Policy, we mean information that identifies, or can be used to identify, an individual. This may take the form of an identification number, name, title, e-mail address, payment information, telephone number(s), photo, or home address. Personal information does not include information that has been appropriately anonymized or deidentified, information that is publicly available from government records, or business contact information. 

• INFORMATION WE COLLECT

Personal Information

Certain users of the Site choose to interact with us in ways that require us to gather Personal Information. The amount and type of information gathered depends on the nature of the interaction. In each case, we collect such information only insofar as is necessary or appropriate to fulfil the purpose of your interaction with us. Examples of the information we collect include:

• Contact Information. This may include your first and last name, postal address, telephone number, and email address when you sign up for an account.
• Client Information. We may ask for certain information to help us provide the services to you or your business including information relating to your business, employees and clients.
• Billing and Financial Information. To help users of our services set up a payment account and pay fees, we may collect financial information, including debit card or credit card numbers, and other payment information, as applicable. We use financial information in order to operate the Site and the services that we provide and to ensure that you are billed for the services you choose to receive from us. We do this as necessary for our legitimate interests in providing our Sites and services and to fulfil our contracts with users.
• Promotional Information. Certain offerings of the Site are optional and so you are not required to enter them or to give us your data in connection with them. Where you do consent to take advantage of our offerings, we will use your data to (as applicable) send you newsletters and other communications that are tailored based on information we have about you, or to operate and manage surveys, contests or similar offerings in connection with our legitimate interest in promoting our business and the Site. 
• Content Information. You also may choose to send us Personal Information in an email or chat message containing inquiries about the Site and services. We use this information in order to help us respond to your inquiries. We also collect additional information in order to facilitate your technical support request, such as information about the technical support issue you are seeking to fix, the time, and the date.

Technical Information

When you visit our Site, we automatically collect the following information, which we refer to as “Technical Information” in this Policy. 

• Device Information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, MAC address, operating system, browser type, mobile network information, and the device’s telephone number (where applicable).  
• Location Information. If you permit us to identify your location when using the Site, we will have access to your location and time zone. We do not collect real-time information about the location of your device. Any location information collected will be anonymized.  

Technical Information is generally used on an aggregate and anonymized basis and in a non-personally identifiable form, but if we can or do use your Technical Information to identify you, we treat such Technical Information as Personal Information in accordance with this Policy. Our purpose in collecting Technical Information is generally to better understand how you use our Site. From time to time, we may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

The technologies we use for automatic data collection may include:

• Log files. Log files track actions occurring on the Site, and collect data including your IP address, MAC address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• Web beacons. Small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) permit us, for example, to count users who have visited certain pages and other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

• USE OF YOUR INFORMATION

We collect and use information for business and commercial purposes in accordance with the practice described in this Policy. Our business purposes for collecting and using information include:

• To create and customize our services in order to fulfill our contracts with you;
• To enable payment for services, in order to fulfill our contracts with you;
• For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which you can use our services and in order to comply with our legal obligations;
• To analyze the Site’s usage as necessary for our legitimate interest in improving the Site to grow our business;
• To notify you about changes to our Site or any products or services we offer or provide though it;
• To contact you and deliver (via email, push notifications, or otherwise) transactional information, administrative notices, marketing notifications, offers, and communications relevant to your use of services, with your consent when required under applicable law, as necessary for our legitimate interests in proper communication and engagement with you and in promoting our business;
• To provide you with customer support in order to fulfill our obligations to you;
• For internal market research for our legitimate interest in improving the website and our services to grow our business;
• For troubleshooting problems for our legitimate interests in ensuring a safe and secure environment in which you and other users can receive the services they opt to use;
• To assist you in the resolution of complaints and disputes, as necessary for our legitimate interests in facilitating good customer service to all users;
• To enforce our Terms of Use and our legitimate interests in ensuring our Agreement is complied with;
• To protect the security or integrity of our Site when necessary;
• For any other purpose with your consent.

We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information. 

We may use both manual and automated systems, such as machine learning and artificial intelligence, to: analyze your Personal Information to improve our Site; personalize your experience; automate certain aspects of the Site; aggregate, de-identify or anonymize your information; provide you certain features; and protect the safety and security of our Site.

• EMBEDDED CONTENT

Articles on this Site may include embedded content (e.g. videos, images, articles, links etc.). Embedded content from other platforms behaves in the exact same way as if the visitor has visited the other platform. These third party platforms may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

These third party websites are not governed by this Policy but by other policies that may differ from our Policy. This Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party platforms, whether linked to this Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party platform or any content on such platform. We encourage you to review the privacy policy of each platform visited before using them or disclosing Personal Information to third parties.

• SHARING YOUR DATA

We only share the information we collect about you as described in this Policy. We may disclose Personal Information that we collect as described in this Policy with your consent for any other purpose we disclose when you provide the information or as permitted or required by applicable law. When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will obtain your consent for the new purpose, unless the new purpose is required or permitted by law.  We will not rent or sell your Personal Information to anyone.

We may share or disclose your Personal Information in the following circumstances:

• Third Party Agents. To operate the FXO Consulting Inc. platform, including processing your transactions, we may share your Personal Information with our agents, representatives, vendors and service providers (“Third Party Agents”) so they can provide us with support services. We share information, including Personal Information, with entities that process information on our behalf for our business purposes. Third Party Agents assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, fraud prevention and detection, communication services, and technical support. Third Party Agents are contractually obligated to keep Personal Information confidential, to use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this policy. We may permit Third Party Agents to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• Subsidiaries and Affiliates. We may disclose your Personal Information to our subsidiaries and affiliates for the purposes that you consented to. 
• “”Legal Obligations. FXO Consulting Inc. and our Third Party Agents may disclose your Personal Information to comply with any court order, law, or legal process, including in response to a subpoena or other governmental request according to applicable law.
• Merger or Acquisition. We reserve the right to share Personal Information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
• Enforce our Rights. We may disclose your Personal Information to enforce our rights arising from any contracts between you and us, and, if applicable, for billing and collection.
• Protect our Rights. We may disclose your Personal Information if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

• STORING AND RETAINING YOUR DATA

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. We use secure means of disposing of Personal Information. 

Note that we will retain Personal Information to the extent necessary to send you marketing communications in accordance with your marketing preferences, which you can change at any time.

Your Personal Information may be processed or stored outside of the jurisdiction in which it was originally collected, including outside of Canada. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. You can obtain more information about our policies and practices with respect to the use of non-Canadian service providers or to ask us delete this information by writing to us at the address provided at the end of this policy.

• PROTECTING YOUR DATA

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect Personal Information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. The safety and security of your Personal Information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our Site, you are responsible for keeping it confidential. We ask you not to share your password with anyone. PLEASE DO NOT SUBMIT ANY CONFIDENTIAL INFORMATION WHEN BOOKING APPOINTMENTS ON THE SITE.

While we will use commercially reasonable efforts to ensure the security of all information, including financial information and Personal Information, we expressly disclaim any liability for unauthorized access to or use of our secure servers and/or any all Personal Information and/or financial information stored therein, and you agree to hold us harmless for any damages that may result therefrom. If you have any further questions on this issue, please refer to the Terms of Use.

The third-party services that we use to store data are equipped to monitor unauthorized access and share with us any known system breaches. Additionally, if, at any point, we become aware of a data breach through one of the third parties listed above, or by our own measures, we will immediately contact all affected parties and also take immediate action in accordance with the rules and regulations of the authority having jurisdiction.

• PERSONAL INFORMATION OF MINORS 

We do not knowingly track, collect, use or disclose the Personal Information of minors (i.e., anyone under the age of 18), without the consent of a parent or legal guardian. However, we cannot always determine the age of persons who access and use our Site. If we learn we have collected or received Personal Information from a minor without parental/guardian consent, we will delete that information.

• YOUR PRIVACY RIGHTS 

You have certain rights with respect to your Personal Information that we collect and process, as described below. To exercise any of your privacy rights, please contact us as set out below under the “Contact Us” heading.

• Updating Your Personal Information. We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information. Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
• Access to & Correction of Personal Information. If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
• Withdrawal of Consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
• Unsubscribe from Marketing & Promotional Communications. If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g. email) you receive or by contacting us as set out below under the “Contacting Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transactional emails or emails about your account and use of our Site.

• CHANGES TO THE PRIVACY POLICY

Although most changes are likely to be minor, we may change this Policy from time to time, and in our sole discretion. If we make material changes to how we treat our users’ Personal Information, we will notify you by email and through a click-through notice on the Site home page.

We include the date the Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and to frequently check this page for any changes to the Policy. 

• CONTACTING US

If you have any questions or concerns about your privacy or anything in this Policy, we encourage you to contact us by e-mail at contactus@fxoconsulting.com