PRIVACY POLICY

Section 1. Introduction

Internet Marketing Group FlightAce Inc. ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, store, and disclose your personal information when you access or use our Services, as defined in our Terms of Service. This includes our websites (EnneagramMatrix.com, ValleyofGuardians.com), our programs (including the Pi9 Purpose Intelligence® program), AI coaching tools, and community platforms.

Your privacy and the security of your data are cornerstones of our mission. Because our Services are designed to facilitate deep personal development, we handle highly personal information. We want you to be confident that this information is safe and used only to provide and improve your experience

By using our Services, you agree to the collection and use of information in accordance with this policy. This Privacy Policy is incorporated by reference into our Terms of Service.

Section 2: The Information We Collect

We collect information in a few different ways to provide and improve our Services. The types of personal information we collect depend on how you interact with us

2.1 Information You Provide to Us Directly

• Account and Profile Information: When you register for an account, you provide us with information such as your name, email address, and password. You may also choose to add more information to your profile.
• Payment Information: When you purchase a Subscription, you provide your payment information, such as a credit card number and billing address. This information is provided directly to our third-party payment processors. We do not store your full credit card information on our servers.
• Personal Development and Assessment Data: This is the cornerstone of your experience. When you use our tools, you provide us with highly personal information, including but not limited to:

• Your Enneagram Matrix® assessment results (including Core Type, Wing, Subtype, Instinctual Sequence, TriCenter).
• Your responses and scores from the Wheel of Life Evaluation
• Your responses and scores from the Purpose Awareness Assessment.
• Your responses and scores from the Spiral Dynamics Personal Values test.

• Community and AI Interaction Data: We collect the content you create and post within the Services. This includes your posts in the Valley of Guardians community forums, your comments, and the inputs, queries, and journal entries you submit to the AI Copilots.
• Communications: When you purchase a Subscription, you provide your payment information, such as a credit card number and billing address. This information is provided directly to our third-party payment processors. We do not store your full credit card information on our servers.

2.2 Information We Collect Automatically

• Usage and Log Data: When you use the Services, our servers automatically record information, including your Internet Protocol (IP) address, browser type, operating system, the pages or features of our Services you browsed, the time spent on those pages, and other statistics.
• Cookies and Tracking Technologies: We use cookies and similar technologies to help operate our Services, such as by remembering your login status. We also use them to understand how users interact with our Services so we can improve them. Our use of cookies is described in more detail in our Cookie Policy.

2.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to operate and improve our Services, enhance your user experience, and analyze our website traffic. A cookie is a small text file stored on your device.

• When you first visit our site, you will be presented with a cookie banner that allows you to accept or manage your cookie preferences. Non-essential cookies will not be placed on your device without your explicit consent.
• For detailed information on the types of cookies we use, why we use them, and how you can manage your preferences, please see our full Cookie Policy

Section 3: How We Share and Disclose Your Information

We do not sell your personal information. We only share your information with third parties in the specific circumstances described below, and our policy is to do so only with trusted partners who are contractually obligated to keep your information secure.

3.1 With Service Providers (Sub-processors)

We engage third-party companies and individuals to perform services on our behalf to help operate and provide the Services ("Service Providers"). These Service Providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

The categories of Service Providers we use include:

• Payment Processors: To securely handle credit card payments.
• Assessment Delivery Platforms: To administer tools like the Enneagram Matrix® assessment.
• AI Service and Infrastructure Providers: To power the functionality of our AI Copilots
• Cloud Hosting Services: To host our websites, community platform, and user data.
• Email and Communication Providers: To send you transactional emails and newsletters.

For a detailed and current list of the specific companies we use as sub-processors, please see our List of Sub-processors page at ennagramMatrix.com/legal-sub-processors.

3.2 For Legal Reasons

We may disclose your information if we believe it's reasonably necessary to comply with a law, regulation, legal process, or governmental request; to enforce our Terms of Service; to protect the safety of any person; or to address fraud, security, or technical issues.

3.3 Business Transfers

If the Company is involved in a merger, acquisition, or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

Section 4: How We Use Your Information

We use the information we collect for the following purposes:

• To Provide and Operate the Services: To authenticate you, process your payments, provide you with access to the course content and community, and ensure the Services are functioning correctly
• To Personalize Your Experience: This is a core function of our platform. We use your Personal Development and Assessment Data to power the AI Copilots, tailor coaching insights, guide you through the Pi9 program, and help you connect with relevant content and discussions.
• To Communicate With You: To send you essential service-related announcements (e.g., updates to our Terms, security notices), respond to your support requests, and send you newsletters or marketing communications that you have consented to receive.
• To Improve Our Services: We analyze usage data to understand how our members use the Services, which helps us to troubleshoot issues, develop new features, and improve the overall user experience.
• For Safety and Security: To protect the safety and security of our users and our platform, to prevent fraud, and to enforce our Terms of Service.

Section 5: Data Security and Retention

5.1 Security:

We are committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and measures, including encryption and access controls, to help protect your information from unauthorized access, use, or disclosure. However, 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 information, we cannot guarantee its absolute security.

5.2 Retention:

We will retain your personal information for as long as your account is active or as needed to provide you with the Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may request the deletion of your account and associated personal information as described in Section 6 (Your Rights and Choices).

Section 6: Your Rights and Choices

We believe you should have control over your personal information. Subject to applicable law, you have the following rights regarding your data:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification (Correction): You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete. You can update most of your account information directly through your account settings.
• To Communicate With You: To send you essential service-related announcements (e.g., updates to our Terms, security notices), respond to your support requests, and send you newsletters or marketing communications that you have consented to receive.
• Right to Erasure (Deletion): You have the right to request that we delete your personal information, subject to certain legal and contractual exceptions (for example, we may need to retain data for financial record-keeping or to comply with legal obligations).
• Right to Withdraw Consent: You have the right to withdraw your consent to our processing of your personal information at any time, where consent is the legal basis for the processing. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Opt-Out of Marketing Communications: You can opt-out of receiving promotional emails from us at any time by clicking the "unsubscribe" link at the bottom of our emails. Please note that you will continue to receive essential, non-promotional emails related to your account and our Services.

To exercise any of these rights, please contact us at privacy@enneagramMatrix.com. We will need to verify your identity before processing your request and will respond within the timeframes required by law.

Section 7: International Data Transfers

Our Company is based in Canada. Your personal information will be primarily processed and stored in Canada.

However, to provide our Services, we use third-party Service Providers, such as our website host (Webflow) and AI service providers, who may transfer, store, or access your personal information in other jurisdictions, most notably the United States.

We understand that the data protection laws in other countries may differ from those in your country of residence. Therefore, we take steps to ensure your personal information is protected when it is transferred internationally. When we transfer personal information from the European Economic Area (EEA), the UK, or Switzerland to other countries, we rely on established legal mechanisms to do so. These include:

• Executing Standard Contractual Clauses (SCCs) with our Service Providers, which are legal agreements approved by the European Commission that require companies to protect personal data to a standard equivalent to that of the EU.
• Confirming our Service Providers' certification under the EU-U.S. Data Privacy Framework (DPF).

By using our Services, you consent to the transfer of your information to countries outside your country of residence, including Canada and the United States, under these safeguards.

Section 8: Information for European Users

8.1 EU Representative

As we are a company based outside of the European Union, and pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed Data Protection Representative Limited (trading as DataRep) as our authorized representative in the EU. This allows you to contact a representative in your own time zone and language who will manage your privacy-related questions and requests on our behalf.

Our designated EU Representative is:
DataRep
Address: 77 Camden Street Lower, Dublin, D02 XE80, Ireland
Email: info@datarep.com

If you are a resident of the European Economic Area (EEA) and wish to exercise your data protection rights, please contact DataRep through their online data request form at: www.datarep.com/data-request

IMPORTANT: When contacting them, please be sure to provide our company's name: Internet Marketing Group FlightAce Inc.

8.2 Legal Basis for Processing

We process personal data on the following legal bases:
(a) To Perform a Contract: When we provide our Services to you as described in our Terms of Service.
(b) With Your Consent: For specific purposes, such as sending marketing communications or processing sensitive data for your personalized AI coaching experience.
(c) For Our Legitimate Interests: To improve our services, for security purposes, and for other activities, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.

Section 9: Children's Privacy

Our Services are not intended for or directed at individuals 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 believe that your child has provided us with personal information without your consent, please contact us at the address provided below. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to remove that information from our servers.

Section 10: Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this document. We may also provide notice to you via email or through our Services. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of the Services after any changes to this Privacy Policy have been posted will be deemed your acceptance of those changes.

Section 11: Contact Us

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise any of your rights, please contact us at:

Internet Marketing Group FlightAce Inc.
Attn: Privacy Officer
2001 Boul Robert Bourassa
Montreal, QC, H3A 2A6
Email: privacy@enneagramMatrix.com