PRIVACY POLICY

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service, and explains Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation
Words with initial capital letters have meanings defined below. The following definitions shall have the same meaning whether they appear in singular or plural.

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Definitions
For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Business (CCPA) refers to the Company as the legal entity that collects Consumers’ personal information and determines purposes and means of processing, that does business in California.

• Company (referred to as “the Company”, “We”, “Us” or “Our”) refers to Ethos Solutions Inc., British Columbia, Canada.

  • For the purpose of the GDPR, the Company is the Data Controller.

• Consumer (CCPA) means a natural person who is a California resident.

• Cookies are small files placed on Your Device that store browsing details.

• Country refers to British Columbia, Canada.

• Data Controller (GDPR) means the legal person that determines purposes and means of processing Personal Data.

• Device means any device that can access the Service (computer, phone, tablet).

• Do Not Track (DNT) is a browser setting that signals a preference to not be tracked.

• Facebook Fan Page is our public profile “Think Yourself Slim” at https://www.facebook.com/thinkyourselfslimprogram

• Personal Data is any information relating to an identified or identifiable individual.

  • GDPR: any information relating to You such as a name, ID number, location data, online identifier, or factors specific to identity.

  • CCPA: information that identifies, relates to, describes, or could reasonably be linked with You.

• Sale (CCPA) means sharing personal information with a third party for valuable consideration.

• Service refers to the Website.

• Service Provider means any person or company that processes data on behalf of the Company (Data Processor under GDPR).

• Usage Data is data collected automatically (e.g., IP address, browser type, pages visited).

• Website refers to Think Yourself Slim, accessible at www.thinkyourselfslim.com.

• You means the individual using the Service, or the company/other legal entity on whose behalf that individual is using the Service, as applicable. Under GDPR, You may be a Data Subject or User.

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While using Our Service, We may ask You to provide certain personally identifiable information, including but not limited to:

• Email address

• First and last name

• Postal address (where required for tax or delivery purposes)

• Interests or topic preferences (e.g., program interests, email preferences)

• Usage Data (see below)

Usage Data is collected automatically when using the Service and may include: Your IP address, browser type/version, pages visited, time and date of visit, time spent on pages, unique identifiers, and diagnostic data. When accessed via mobile, we may collect device type, unique device ID, mobile OS, mobile browser type, and similar diagnostic data.

We use Cookies and similar technologies (beacons, tags, scripts) to track activity and store information to improve and analyze Our Service.

• Cookies/Browser Cookies: You can instruct Your browser to refuse Cookies or alert You when a Cookie is sent. Some features may not function without Cookies.

• Flash Cookies: Certain features may use local stored objects (Flash Cookies). See Adobe’s guidance for disabling Flash Cookies.

• Web Beacons: Certain pages/emails may contain small files (e.g., pixel tags) that help us count visits, understand usage, and verify system integrity.

Cookies may be Session (deleted when You close Your browser) or Persistent (remain until they expire or are deleted). We use:

• Necessary/Essential Cookies (Session; administered by Us) — to provide core functionality and security.

• Cookies Policy/Notice Acceptance Cookies (Persistent; administered by Us) — to remember consent choices.

• Functionality Cookies (Persistent; administered by Us) — to remember preferences (e.g., language, login).

• Tracking and Performance Cookies (Persistent; administered by third parties) — to analyze traffic and usage and test features.

For more details on cookie choices, see the Cookies section of this Policy.

The Company may use Personal Data to:

• Provide and maintain the Service (including monitoring usage).

• Manage Your Account and access to Service features.

• Perform a contract for products/services You purchased.

• Contact You regarding updates, security alerts, and administrative messages.

• Provide news, offers, and information about goods/services similar to those You purchased or inquired about (unless You opt out).

• Manage and respond to Your requests.

• Analyze data, identify trends, evaluate and improve Our Service, products, and marketing.

We may share Your information with:

• Service Providers (e.g., analytics, payment processing, email sending, course hosting).

• Other users if You share information in public areas (e.g., comments).

• With Your consent or as otherwise disclosed at the time of collection.

• To meet legal requirements as required by a court of law (see below Disclosure of Your Personal Data)

We retain Personal Data only as long as necessary for the purposes set out in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Usage Data is retained for a shorter period unless needed to improve security/functionality or required by law.

Your information may be processed at our operating offices and other locations where involved parties are located, which may be outside Your jurisdiction. We will take reasonable steps to ensure Your data is treated securely and in accordance with this Policy, and that no transfer occurs without appropriate safeguards.

Law Enforcement: We may disclose Your data if required by law or valid government requests.

Other Legal Requirements: We may disclose data to comply with legal obligations; protect and defend Our rights or property; prevent wrong-doing; protect the personal safety of users or the public; or protect against legal liability.

We use commercially acceptable means to protect Personal Data; however, no method of transmission or storage is 100% secure.

Below is a list of analytics systems we use and the data that is both captured and processed:

We may use third-party providers to monitor and analyze Service usage.

• Google Analytics — tracks and reports website traffic, and may share aggregated data with other Google services. You can opt out via the Google Analytics Opt-out Browser Add-on. See Google’s Privacy & Terms for details.

We act as Joint Controllers with Facebook for Insights data on our page https://www.facebook.com/thinkyourselfslimprogram. Facebook places a cookie to provide anonymized statistics. See Facebook’s Terms and Privacy Policy for details.

Below is a list of all marketing, sales, payment processing and product hosting and delivery systems we use and the data that is captured, stored and processed

We use Podia to host and deliver courses, digital programs, and related community or messaging features (if enabled). When You purchase or enroll, Podia may collect and process (on our behalf) information necessary to provide access and fulfill legal obligations, including:

• Name

• Email address

• Postal address (for tax purposes, invoicing, or where legally required)

• Interests/preferences (e.g., program topics You select or subscribe to)

• Purchase details, access logs, and support interactions as needed to operate the Service.

Data is stored securely on Podia’s systems and used to deliver Your products, manage enrollments, provide support, and, if You opt in, send emails via Podia Email (see below).

For any past/legacy digital purchases fulfilled by SendOwl, SendOwl (as our processor) may have processed on our behalf information necessary to deliver Your purchase and meet tax/anti-fraud requirements, including: buyer email address (for delivery), IP address (for tax determination), date/time of purchase, currency and amount, discounts applied, payment method (e.g., PayPal or Stripe), download counts and timestamps, product names and product IDs.

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We no longer use SendOwl as of November 12, 2025. Ethos Solutions Inc. remains the data controller for legacy purchase records we must keep for lawful purposes (e.g., tax, accounting, fraud prevention). We retain only what is necessary and only for as long as required by applicable laws (typically up to 7 years in Canada), after which we securely delete or anonymize the data.

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For details on how SendOwl handles data in its systems (including retention for inactive merchant accounts), please refer to SendOwl’s privacy/data processing documentation or contact SendOwl directly.

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Historically, some SendOwl purchase data, including buyer email address, purchase currency and amount, IP address, country, product interests, and product(s) purchased , was transmitted to GetResponse for email delivery and automation purposes.

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We no longer use GetResponse as of 2025.

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We have discontinued all new data transfers to GetResponse and have taken steps to remove or minimize any residual data within their system, subject to our legal record-keeping obligations (e.g., tax, transaction confirmation, or compliance requirements).

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We may use Your Personal Data to send newsletters, marketing or promotional materials, and other information that may interest You.

You can opt out at any time using the unsubscribe link in our emails or by contacting Us.

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We use email service functionality as follows:

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• Podia Email (provided by Podia) — If You opt in, Your name, email address, postal address (where required for tax receipting/invoicing), and interests (topics or product categories You select) may be stored and used to segment communications so You receive relevant updates and offers. Emails are sent in compliance with applicable laws. You can update preferences or unsubscribe at any time via the links in Podia-sent emails.

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We provide paid products/services. We use third-party payment processors; We do not store full payment card details.

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• Stripe processes payments in accordance with its Privacy Policy and PCI-DSS standards.

• PayPal processes payments in accordance with its Privacy Policy and PCI-DSS standards.

Legal Basis for Processing

We may process Personal Data under these bases: Consent, Performance of a Contract, Legal Obligation, Vital Interests, Public Interest, Legitimate Interests. We will clarify the specific basis where needed.
 

You have the right to: access, rectify, erase, object, restrict, port, and withdraw consent. If You cannot exercise these within Your account (where applicable), contact Us. We may request identity verification. You may also lodge a complaint with Your local supervisory authority.

We are a Canadian business operating under the privacy laws of Canada, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, British Columbia’s Personal Information Protection Act (PIPA).

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While we are not directly subject to the California Consumer Privacy Act (CCPA) or other U.S. state-specific privacy laws, we believe in upholding the same spirit of transparency and respect for personal data for all customers, regardless of location.

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Accordingly, regardless of where You live, You have the right to:

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• Request access to the personal information we hold about You;

• Request correction of any inaccurate or incomplete information;

• Request deletion of information we no longer need for legal or business purposes; and

• Withdraw consent to marketing communications at any time.

Requests can be made at any time using our Contact page. We may ask You to verify Your identity before fulfilling a request, and we may retain limited information as required for tax, accounting, or legal compliance purposes.

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal privacy law governing the collection, use, and disclosure of personal information in commercial activities.

Under PIPEDA, You have the right to:

• Know why Your personal information is collected and how it will be used;

• Access the personal information We hold about You and request corrections;

• Withdraw consent to future collection, use, or disclosure of Your information, subject to legal and contractual restrictions; and

• File a complaint if You believe We have not complied with PIPEDA.

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If You have a privacy concern or wish to exercise any of these rights, please contact us. If a matter remains unresolved, You may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

Our Service is intended for adults. We do not knowingly collect, use, or store personal information from individuals under the age of 16.

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If You are a parent or guardian and believe that a minor under 16 has provided Us with personal information, please contact Us so that We can take appropriate steps to delete that information.

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If We become aware that We have collected personal data from a minor without verified parental or guardian consent, We will delete that information from our systems as soon as reasonably possible.

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Where parental consent is legally required, We may request proof of consent before providing access to any Service or program.

Our Service may contain links to third-party sites. We are not responsible for their content or privacy practices. Review each site’s privacy policy.

We may update this Policy from time to time. We will post the new Policy on this page and update the “Last updated” date. We may also notify You by email and/or a prominent on-site notice where appropriate.

If You have questions or requests regarding this Privacy Policy, You can contact us:

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• Via our website

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• By mail:
  Unlock Your Life / Think Yourself Slim
  PO Box 36
  506 Tod Mountain Road
  Heffley Creek Post Office
  Heffley Creek, BC V0E 1Z0
  Canada