FlexiPro Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) applies to personal information provided to Flexibility Maestro Ltd. (the “Vendor” “we” “us” or “our”) through the services we make or offer (“Services”), including the FlexiPro software-as-a-service platform as well as any associated website, application, or widget that links to this Privacy Policy.

Flexibility Maestro Ltd. is incorporated in Ontario, Canada, and this Privacy Policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws.

This Privacy Policy covers how our Services process information relating to identified or identifiable individuals and households (“Personal Information”). (We use the term “process” to refer to the collection, use, storage, and sharing of Personal Information.)

We also process certain Personal Information of our customers on our own behalf, and this kind of processing is also described in this Privacy Notice.

This Privacy Policy does not cover collection and use of Personal Information by third parties, and we are not responsible for the actions of third parties with respect to your Personal Information. You are encouraged to review the privacy practices of your connected fitness apps or other additional third parties prior to providing Personal Information.

We shall revise this Privacy Policy when our Personal Information processing practices change. The most current version of which shall always be available on our website.

Please note that we are not a “health information custodian” under Ontario’s Personal Health Information Protection Act (PHIPA) or similar provincial health privacy legislation. Our Services are designed for fitness and wellness purposes, not for the provision of health care.

Email Marketing Consent

By creating an account with FlexiPro or signing up for our mailing list, you consent to receiving emails from Flexibility Maestro Ltd., which may occasionally include marketing material about our services, features, and related offerings. 

The email address you provide when signing up for the training app or through our sign-up forms will be added to our email database and retained until you unsubscribe from the list.

This consent complies with Canada’s Anti-Spam Legislation (CASL). You may withdraw your consent to receive marketing communications at any time. We provide an “opt-out” or “unsubscribe” function within all marketing email communications, and/or will cease communications of this nature if you inform us that you would like to opt-out. However, you may not opt-out of communications related to the Services or your Account, such as important service updates, account notifications, or security alerts.

The same privacy protections outlined in this Privacy Policy apply to all email addresses collected through FlexiPro account registration or our mailing list sign-up forms.

Processing of Personal Information

Our Services collect the following categories of Personal Information:

Information you submit to us

Account and identity information: in the event that you choose to register as a user of the Services, you will be asked to create a unique username and private password (collectively, the “Access ID”) which will be used to create and activate an account through which we can make the Services available to you (the “Account”). We may require certain information such as your name, address, telephone number, and email address to make the Services available to you.

Fitness information: you may choose to provide other information to improve your experience or enable certain features of the Services. This information can include your fitness and nutrition information, workout logs, progress tracking data, and health and wellness goals.

Financial information: we may collect billing and other financial information to process payments required in connection with the Services.

Commercial information: we maintain records about the transactions you engage in with us or other parties through the Services, such as information about purchases, what has been provided to you, when and where, if applicable, how much you paid, and similar information.

User content: you may choose to provide additional information to improve your experience which may be in any form, such as text, images, sound, or video. You may also choose to provide additional information to us, such as when you contact us for technical support through the Services, participate in a poll, survey, or otherwise provide feedback on the Services.

Information we collect from your use of the Services

Log and usage data: we collect log data and usage information relating to your use of the Services. For example, we collect information about how you interact with the Services, such as when you log into your Account, how you navigate the Services, and what functions you use in the Services. We also collect information about the devices used to access the Services, such as the device type, operating system, and IP address.

Location Information: With your consent, we collect Personal Information about your location.

Information we collect from third parties

Social Media and App Information: If you link your Account to third-party services, we may collect information about you from such other services. You can also link your Account to other social media, fitness, or business applications. The types of information we may collect from such third-party services depends on the nature of the third-party services you connect to your Account. For example, you can link your account to Facebook and import your Facebook profile information. You may also choose to grant us access to fitness or activity information from a third-party fitness application.

YouTube API Data: Without limiting the foregoing, the Services use certain YouTube API Services. Google, which operates YouTube, describes its processing of Personal Information in its privacy policy at https://www.google.com/policies/privacy. We process data, content (including audiovisual content) and information provided to the Services through the YouTube API services, including without limitation YouTube Video ID information and YouTube video thumbnail information (collectively, the “YouTube API Data”) to provide the functionality of the Services to you, including enabling you to view and interact with exercise and training video content through the Services.

Consumer profile information: Information used to create a profile about you reflecting your preferences, market segments, likes, favorites and other data or analytics provided about you or your account by a FlexiPro Customer, social media companies or data aggregators, including the products and services you use or intend to use or purchase, and your interests.

How We Use Personal Information

We use Personal Information for the following purposes, which we have identified under PIPEDA:

• to create and activate your Account;
• to respond to any request for customer service or technical support;
• to make the Services available to you and to other users of the Services;
• to improve the quality of the Services;
• to assess service levels, monitor traffic patterns and gauge popularity of different features, functionalities and service options of, or related to, the Services;
• to create and manage your Account, and to verify access rights to the Services;
• to bill, or render invoices relating to, your Account, and to collect any debt owed to us;
• to facilitate payments between you and other parties through the Services;
• to communicate with you, including for the purpose of providing you with notifications, content, and information about your Account and/or the Services;
• to communicate with you for marketing purposes with your express consent as described in the Email Marketing Consent section above, in compliance with CASL;
• to administer, maintain, monitor, and secure the Services;
• to respond to claims of any violation of our rights or those of any third party;
• to protect the rights, property, or personal safety of you, our personnel, other users, and the public;
• as required to comply with any applicable laws, or as authorized by any applicable laws.

We will not use your Personal Information for purposes other than those purposes we have disclosed to you, without your consent.

Data Retention

We retain each category of Personal Information above for as long as may be reasonably necessary to achieve the purposes for which it was collected or as may be required or permitted by law, after which time we will delete the Personal Information or aggregate or anonymize the information so that it no longer relates to an identified or identifiable person or household.

Email addresses collected through account registration or mailing list sign-ups will be retained in our email database until you unsubscribe from the mailing list or request deletion of your data.

We generally consider the following factors when we determine how long to retain Personal Information: (1) retention periods established under applicable Canadian law; (2) industry best practices; (3) whether the purpose of processing is reasonably likely to justify further processing; (4) risks to individual privacy in continued processing; (5) applicable privacy impact assessments; (6) IT systems design considerations/limitations; and (7) the costs associated with continued processing, retention, and deletion.

In accordance with PIPEDA, we retain Personal Information only as long as necessary for the fulfillment of the identified purposes or as required by law. For more information about our retention periods, please contact us using the information in the “Contact Us” section, below.

Legal Basis for Processing Your Personal Information

Under PIPEDA and applicable Canadian privacy laws, we process Personal Information based on the following:

• Consent: We obtain your consent for the collection, use, and disclosure of Personal Information. Your consent may be expressed or implied depending on the sensitivity of the information and reasonable expectations in the circumstances.
• Contractual necessity: Processing is necessary to provide the Services for which you have entered into a contract with us.
• Legal obligations: Processing is required to comply with applicable Canadian laws and regulations.
• Legitimate purposes: Processing serves legitimate business purposes that are reasonable in the circumstances and do not override your interests or rights.

You have the right to withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent, please contact us using the information in the “Contact Us” section below.

Disclosure of Personal Information

We disclose Personal Information as described below, in accordance with PIPEDA requirements:

• Your Personal Information may be shared with your trainer and/or the FlexiPro app providing services.
• We share Personal Information with law enforcement authorities who make a request in accordance with applicable Canadian law.
• We may also share Personal Information with third parties when needed to comply with a legal obligation that we are subject to under Canadian law.
• We may share Personal Information to a successor or potential successor to all or a part of our business.
• We share Personal Information with our partner organizations, such as the Flexibility Maestro Ltd. family of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership.
• We share Personal Information with third-party service providers that we engage with contracts that require them to use your Personal Information only for the purpose of delivering the services for which we have engaged the third-party or as otherwise permitted by law. These kinds of third parties provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, transmission of email or other messages, and quality assurance.
• At your direction, we share Personal Information with third-party partners in connection with your use of the functionality of the Services. This includes companies, such as FitBit, Garmin, and Withings, that collect, analyze, process, and/or store data that you may elect to integrate with our Services.

We do not sell your Personal Information to third parties.

Children’s Privacy

We do not direct the Services to children under the age of majority in their province or territory of residence, or knowingly collect Personal Information from children under that age without parental consent. In Ontario, the age of majority is 18. If you have not reached the legal age of majority in your jurisdiction, our Terms of Service do not allow you to use our Services without parental or guardian consent. If we learn that Personal Information has been collected on the Services from persons under the age of majority without appropriate consent, we will promptly delete this information. If you are a parent or guardian and discover that your child has provided Personal Information, then you may alert us as set forth in the “Contact Us” section, below, and request that we delete your child’s Personal Information from our Services.

Your Rights Under PIPEDA

Under PIPEDA and applicable Canadian privacy laws, you have the following rights:

• Right to Access: You have the right to request access to your Personal Information that we hold and to receive information about how we use and disclose it.
• Right to Correction: You have the right to request correction of any inaccurate or incomplete Personal Information we hold about you.
• Right to Withdraw Consent: You have the right to withdraw your consent to our collection, use, or disclosure of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice.
• Right to Challenge Compliance: You have the right to challenge our compliance with PIPEDA and to file a complaint with the Office of the Privacy Commissioner of Canada.
• Right to Portability: Where technically feasible, you have the right to receive your Personal Information in a structured, commonly used format.

We will respond to your access requests within 30 days of receiving your request, as required by PIPEDA. In some cases, we may extend this timeline and will notify you of any extension.

To exercise your rights, please submit a request by contacting us through any of the means outlined in the “Contact Us” section, below. We may require verification of your identity before processing your request.

There is no cost to submit an access request. However, we may charge a minimal fee if your request requires extensive retrieval or processing of records, and we will inform you of any such fee before processing your request.

Do Not Track and Global Privacy Control Signals

Because no consensus has emerged on how to handle “Do Not Track” signals, the Services do not respond to such signals or use them to alter how Personal Information is processed. We also do not process the Global Privacy Control signal because, in connection with the Services, we do not sell or share Personal Information for cross-contextual behavioral advertising purposes.

Security

• We strive to prevent unauthorized access to your Personal Information. We will regularly assess our security to ensure that we have in place reasonable technical, administrative, and physical safeguards to protect your Personal Information from unauthorized access, use, and disclosure, in accordance with PIPEDA’s security safeguards principle.
• We take steps designed to ensure that only those of our employees who need access to your Personal Information to fulfil their employment duties will have access to it.
• Nevertheless, there is no guarantee that such technology or procedures can or will eliminate the risks of unauthorized access, use, disclosure, theft, loss or misuse.
• Do not disclose your Access ID to anyone. If you forget your password, we will ask you for the username associated with your Access ID and will send you an email containing password reset instructions to the email address associated with your Access ID.
• You are responsible for maintaining the secrecy of your Access ID. If you disclose your Access ID, others who have your Access ID will be able to access your Personal Information.
• We cannot be responsible for and do not control how other users of our Services use your Personal Information. You should use caution in sharing your Personal Information with others through the Services.
• If we learn of a breach of security involving Personal Information, we will comply with the breach notification requirements under PIPEDA and applicable Canadian provincial laws, including notifying affected individuals and the Privacy Commissioner of Canada where required.

Cross-Border Data Transfers

Your Personal Information may be processed and stored in countries outside of Canada, including the United States, United Kingdom and Australasia, where our service providers operate. By using the Services, you consent to the transfer of information to countries outside Canada, which may have different privacy protection rules than in Canada.

When your Personal Information is in another country, it may be subject to the laws of that country, and may be disclosed to or accessed by the courts, law enforcement, and governmental authorities in accordance with those laws.

However, our practices regarding your Personal Information will at all times continue to be governed by this Privacy Policy. We take steps to ensure that our service providers provide a comparable level of protection for your Personal Information while it is being processed outside of Canada, in accordance with PIPEDA requirements.

Quebec Residents

If you are a resident of Quebec, you have additional rights under Quebec’s Act respecting the protection of personal information in the private sector (Quebec Privacy Act). These include:

• The right to access your Personal Information without being required to provide a reason for your request
• The right to request that your Personal Information be corrected
• The right to request that your Personal Information be deleted in certain circumstances
• The right to file a complaint with the Commission d’accès à l’information du Québec

To exercise these rights, please contact us using the information in the “Contact Us” section below.

British Columbia, Alberta, and Other Provincial Residents

If you reside in a Canadian province with substantially similar provincial privacy legislation to PIPEDA (such as British Columbia’s Personal Information Protection Act or Alberta’s Personal Information Protection Act), your rights under this Privacy Policy are governed by the applicable provincial legislation, and you may file complaints with your provincial privacy commissioner.

Contact Us and Privacy Officer

Flexibility Maestro Ltd. has designated a Privacy Officer who is accountable for our compliance with this Privacy Policy and applicable privacy laws.

If you have any questions or comments about this Privacy Policy or our processing of your Personal Information, to make an access or correction request, to exercise any applicable rights, to make a complaint, to unsubscribe from our mailing list, or to obtain information about our policies and practices, you may contact our Privacy Officer at:

Flexibility Maestro Ltd.
Attention: Privacy Officer

Email: [email protected]

Filing a Complaint with the Privacy Commissioner

If you believe that we have not complied with this Privacy Policy or applicable Canadian privacy laws, you have the right to file a complaint with:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca

Residents of Quebec may also file a complaint with the Commission d’accès à l’information du Québec at www.cai.gouv.qc.ca.

Last Updated: 27 Oct 2025

This Privacy Policy is governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.