Privacy Policy

At Flip & Floss Incorporated, we are committed to protecting the privacy of the personal information of our customers and users of our digital properties. We take all reasonable steps to ensure that this information is safe and secure, including putting in place rigorous policies and procedures to fully comply with all relevant Canadian and US privacy laws and regulations.

Application Date: This policy is effective October 27, 2020
Published: October 28, 2020

1. Scope and Application

Who does this policy apply to?

All customers and users of the products, services, websites, apps, and other digital services offered by Flip & Floss Incorporated. These include our online courses and merchandise. Our products and services are not intended for, and are not marketed to, individuals under the age of 13.

What information does this Privacy Policy apply to?

This policy applies to all personal information that we collect, use, or disclose about our customers and users of our digital platforms. This includes your name, address, email, how you pay for your services, how you use our products including our websites, network use, and information gathered from third parties, such as credit bureaus. It also includes IP addresses, URLs, data transmission information, as well as the time you spend on websites, what advertisements you follow, and your time on and use of our apps.

2. Consent

How does Flip & Floss Incorporated obtain consent?

Your consent to the collection, use, or disclosure of personal information may be implied or expressed, through written, oral, electronic or any other method. For example, when you provide us your address, it is implied that it is used for billing purposes and service provisioning. However, if we are dealing with more sensitive information, such as performing a credit check, we will seek your express consent. We will also obtain your express consent for marketing purposes.

Withdrawing Consent

The choice to provide Flip & Floss Incorporated with your consent is always yours. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, your decision to withhold such consent may limit our ability to provide you with certain products, services, or offers. To withdraw your consent, please contact us at info@flipandfloss.com.

3. Children's Privacy (COPPA Compliance)

Flip & Floss provides family-oriented financial literacy and educational experiences, some of which may be accessible to children under 13. To comply with COPPA, we:

• • Obtain verifiable parental consent before collecting, using, or disclosing personal information from a child under 13.
• • Limit the information collected from children to that which is reasonably necessary to participate in an activity.
• • Allow parents to review, delete, or refuse further collection of their child's personal information at any time by contacting us.
• • Do not use children's information for targeted advertising or disclose it to third parties except as necessary to operate our Services.

4. How and Why We Collect Personal Information

How does Flip & Floss Incorporated collect my personal information?

We primarily collect information about you, from you. We do this when you sign-up for new products or services, when you make changes to your account, when you get in touch with us by phone, email or chat, when you visit our websites or apps, when you fill out a survey or enter a competition or when you participate in our online forums.

Your information may be collected in the following ways:

• • Automatically: When you use a product or service that we supply to you.
• • From our digital channels: Like our websites and mobile apps. When you interact with us via digital channels we will collect your personal information in different ways such as through use of cookies or web beacons.
• • When you download our application: We will ask you for your phone number and or email address. We use this information to send you an OTP (One Time Passcode) code to authenticate your identity.

Why does Flip & Floss Incorporated collect my personal information?

Flip & Floss Incorporated collects personal information for many different reasons in order to provide you with the products and services we offer, including but not limited to the following:

• • To deliver you the products and services you have purchased from us, and to bill you and collect payment for those products and services.
• • To provide tailored service to you. For example, we may use account information about you to improve your interactions with us or provide a positive and personalized customer experience.
• • To provide geo-location services that will send you offers and promotions from carefully chosen third parties based on your current and historical personal location information.
• • To perform analytics, administer surveys, or request feedback to improve and manage our relationship with you.
• • To ensure the Flip & Floss Incorporated networks are functioning and protect the integrity of our networks.
• • To confirm or authenticate your identity and ensure your information is correct and up-to-date.
• • To ensure compliance with our Terms of Service and Acceptable Use Policy. To comply with legal obligations and regulatory requirements.
• • We may collect information to manage credit and business risks, collect an outstanding debt, detect, prevent, manage, and investigate fraud or other unauthorized or illegal activity. This may require us to obtain information from credit agencies or members or affiliates of Flip & Floss Incorporated.
• • Your information may also be collected to evaluate eligibility for other Flip & Floss Incorporated products and services, and to assist members or affiliates of Flip & Floss Incorporated to assess your eligibility for their products or services.
• • From time-to-time, information may also be collected for other purposes, or as permitted or required by law. We will always identify any additional purpose prior to, or at the time, of collection.

5. Disclosure

When is my personal information disclosed?

Unless we have your express consent or pursuant to a legal power, we will only disclose your personal information to organizations outside Flip & Floss Incorporated without your consent in the following limited circumstances:

• • To a person who, in our reasonable judgement, is seeking the information as your agent.
• • To a service provider or other agent retained by us, such as a credit reporting agency, for account management, the collection of past due bills on your account, or to evaluate your creditworthiness.
• • To a service provider or third party that is performing administrative functions for us to manage our customer accounts.
• • To another organization for fraud prevention, detection or investigation if seeking consent from you would compromise the investigation.
• • To a law enforcement agency whenever we have reasonable grounds to believe that you have knowingly supplied us with false or misleading information or are otherwise involved in unlawful activities.
• • To a public authority or agent of a public authority if it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.
• • To a public authority or agent of a public authority, for emergency public alerting purposes, if a public authority has determined that there is an imminent or unfolding danger that threatens the life, health or security of an individual and that the danger could be avoided or minimized by disclosure of the information.
• • To a third party who may be interested in buying Flip & Floss Incorporated assets and personal customer information must be shared to assess the business transaction.
• • We will disclose information about your credit behaviour to credit reporting agencies or parties collecting outstanding debt.

6. Storage, Security & Retention

Where will my personal information be stored?

Flip & Floss Incorporated operates in Canada and the United States. Personal information collected from users in Canada will be stored and processed within Canada, and personal information collected from users in the United States will be stored and processed within the United States. This ensures that your information remains protected under the privacy laws of your respective country.

How will Flip & Floss Incorporated ensure my personal information is kept safe?

Flip & Floss Incorporated has rigorous security and safeguard processes and procedures to ensure the information we have about our customers and users of our digital properties remains safe from theft, loss, or unauthorized access. Flip & Floss Incorporated Chief Innovation & Technology Officer and delegates ensure that Flip & Floss Incorporated is responsible for all personal information of our customers and users of our digital properties in our possession and control. We ensure that there is a comparable level of protection for information that is processed for us by third parties.

How long will Flip & Floss Incorporated retain my personal information?

Flip & Floss Incorporated will only retain your personal information for as long as necessary to fulfill the purpose for which it was collected or for sufficient time to allow you access to the information if it was used to make a decision about you or your account. Information that is no longer required by us will be destroyed or de-identified.

7. Access

How to access your personal information

You may access or review the information we have about you. You can challenge its accuracy and completeness and request amendments, as appropriate, by contacting us at info@flipandfloss.com.

If you remain concerned about your Privacy after contacting Flip & Floss Incorporated

The Office of the Privacy Commissioner of Canada oversees Flip & Floss Incorporated' personal information handling practices. If your privacy concerns are not addressed to your satisfaction by Flip & Floss Incorporated, you may contact the Office of the Privacy Commissioner of Canada for further guidance:

• • Website: priv.gc.ca/en
• • Phone: 1 800 282 1376 or 819 994 5444
• • Fax: 819 994 5424
• • TTY: 819 994 6591

Effective Date: October 28, 2020