Privacy POLICY

YOUR PRIVACY AT A GLANCE

  • We collect information you provide to us and information generated through your use of our Services.

  • We use your information to deliver our services, communicate with you, and improve our business.

  • We do NOT sell your personal data or your mobile number to third parties.

  • We do NOT share your SMS opt-in data with third parties for marketing.

  • You have rights over your personal data — including the right to access, correct, or delete it.

  • You can opt out of marketing messages at any time by replying STOP.

1. Introduction & Who We Are

FlexDealer Solutions Ltd. ("Agency," "we," "us," or "our") is a professional services agency providing digital marketing, consulting, creative services to clients in the United States and Canada. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you:

Visit our website at https://www.flexdealer.com (the "Site");

Engage our professional services;

Communicate with us via email, phone, or SMS/text messaging;

Submit forms, inquiries, or other information through our Site or client portals; or

Interact with us in any other way.

We are committed to protecting your privacy and handling your personal information responsibly, in compliance with applicable privacy laws in the United States and Canada, including the Telephone Consumer Protection Act (TCPA), Canada's Anti-Spam Legislation (CASL), the Personal Information Protection and Electronic Documents Act (PIPEDA), and applicable US state privacy laws including the California Consumer Privacy Act (CCPA/CPRA).

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide to us, including:

Contact information: name, email address, phone number (including mobile number), mailing address, and company name;

Account and project information: login credentials, project briefs, files, and communications;

Payment information: billing address and payment method details (processed securely through our payment processor — we do not store full card numbers);

Communications: emails, messages, meeting notes, and any other content you send us;

SMS opt-in data: your mobile phone number and explicit consent record when you opt into our text messaging program; and

Survey or feedback responses.

2.2 Information Collected Automatically

When you visit our Site, we automatically collect certain technical data, including:

Log data: IP address, browser type and version, pages visited, time spent, and referring URL;

Device data: device type, operating system, and screen resolution;

Cookie and tracking data: see Section 7 for our Cookie Policy; and

Analytics data: traffic patterns and usage behavior collected through tools such as Google Analytics.

2.3 Information from Third Parties

We may receive information about you from third-party sources, such as:

Referral partners or affiliate agencies;

Publicly available business information (e.g., LinkedIn, company websites); and

CRM platforms, scheduling tools, or project management software we use to deliver our Services.

3. How We Use Your Information

We use personal information for the following purposes:

  • Purpose

  • Examples

  • Legal Basis (US/Canada)

  • Delivering Services

  • Managing projects, client communication, billing

  • Contractual necessity / Legitimate interest

  • SMS Communications

  • Appointment reminders, project updates, marketing texts (with consent)

  • Express consent (TCPA / CASL)

  • Account Management

  • Creating/managing client portal accounts

  • Contractual necessity

  • Marketing & Outreach

  • Email campaigns, promotional offers (opt-in only)

  • Consent / Legitimate interest

  • Analytics & Improvement

  • Analyzing Site usage to improve our services

  • Legitimate interest

  • Legal Compliance

  • Responding to legal requests, audits, regulatory compliance

  • Legal obligation

  • Security

  • Detecting and preventing fraud or unauthorized access

  • Legitimate interest

4. SMS / Text Messaging & Mobile Data

This section specifically addresses how we collect, use, and protect information related to our SMS messaging program, in compliance with TCPA (US), CASL (Canada), Twilio's Messaging Policy, and CTIA guidelines.

4.1 What Mobile Data We Collect

Your mobile phone number (provided directly by you);

Your opt-in consent record (date, time, method, and the exact language of consent presented);

Message interaction data (delivery status, opt-out requests); and

Any content you send to us via SMS.

4.2 How We Use Your Mobile Data

To send you text messages you have consented to receive (transactional, operational, and/or marketing);

To maintain accurate records of your consent as required by TCPA and CASL;

To process and honor opt-out requests; and

To improve our messaging program and ensure compliance.

4.3 No Selling or Sharing of Mobile Data

IMPORTANT: Mobile opt-in data, including your phone number and SMS consent records, will NOT be sold, rented, leased, shared, or transferred to any third party or affiliate for their marketing purposes under any circumstances.

This applies absolutely and without exception.

4.4 Third-Party SMS Infrastructure

We use Twilio, Inc. as our SMS communications platform. Twilio processes message data on our behalf as a data processor and is subject to contractual obligations to protect your data. Twilio's privacy policy is available at twilio.com/legal/privacy. We do not permit Twilio or any other sub-processor to use your personal data for their own marketing purposes.

4.5 Opting Out of SMS

You may opt out of SMS messages at any time by replying STOP to any message. You will receive one confirmation message and then no further texts. You may re-subscribe by replying START or contacting us at [support@youragency.com].

Canadian residents may also submit an opt-out request by email to [support@youragency.com]. We will process all Canadian opt-out requests within 10 business days as required by CASL.

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

5.1 Service Providers & Sub-Processors

We share personal information with trusted third-party vendors who assist us in operating our business, including:

  • CRM and project management platforms (e.g., [HubSpot, Asana, Monday.com]);

  • SMS and communications platform (Twilio);

  • Payment processors (e.g., [Stripe, QuickBooks]);

  • Website hosting and analytics (e.g., [hosting provider, Google Analytics]);

  • Email service providers (e.g., [Mailchimp, SendGrid]); and

  • Cloud storage providers (e.g., [Google Drive, Dropbox]).

All service providers are contractually required to protect your data and use it only to provide services to us. They are not permitted to use your data for their own marketing.

5.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or government authority, or if we believe disclosure is necessary to protect our rights, prevent fraud, or protect the safety of any person.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, your personal information may be transferred to the acquiring entity. We will provide notice of such a transfer and any material changes to privacy practices.

5.4 With Your Consent

We may share your information with third parties when you have provided explicit consent for us to do so.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to comply with legal obligations, resolve disputes, and enforce our agreements. General retention guidelines:

  • Client data & project records: Retained for [e.g., 7 years] after the end of the client relationship to meet tax and legal record-keeping requirements;

  • SMS consent records: Retained for a minimum of 4 years from the date of consent or last interaction, as recommended for TCPA compliance;

  • Website analytics data: Retained for [e.g., 26 months] per our analytics provider settings;

  • Marketing contact data: Retained until you unsubscribe or request deletion; and

  • Payment records: Retained as required by applicable tax law.

You may request deletion of your personal data at any time (see Section 9 for your rights).

7. Cookies & Tracking Technologies

Our Site uses cookies and similar tracking technologies to enhance your experience and collect analytics data. Types of cookies we use:

  • Essential cookies: Required for the Site to function (e.g., session management). These cannot be disabled.

  • Analytics cookies: Help us understand how visitors use our Site (e.g., Google Analytics). These are set only with your consent where required.

  • Marketing cookies: Used to deliver relevant advertising. These are set only with your explicit consent.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, loss, destruction, or alteration. Our measures include:

  • Encryption of data in transit (TLS/SSL) and at rest where applicable;

  • Access controls and role-based permissions limiting data access to authorized personnel only;

  • Regular security assessments and employee training on data handling;

  • Use of reputable, SOC 2-compliant third-party service providers; and

  • Incident response procedures to address potential data breaches.

While we take reasonable precautions, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that affects your rights and freedoms, we will notify you as required by applicable law.

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

9.1 Rights for All Users (US & Canada)

  • Right to access: Request a copy of the personal information we hold about you.

  • Right to correction: Request that we correct inaccurate or incomplete personal information.

  • Right to deletion: Request that we delete your personal information, subject to legal retention requirements.

  • Right to opt-out of marketing: Unsubscribe from marketing emails or SMS at any time.

  • Right to withdraw consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

9.2 Additional Rights for California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

  • Right to know: Know the categories and specific pieces of personal information we collect, use, and disclose.

  • Right to delete: Request deletion of personal information we have collected (subject to exceptions).

  • Right to opt-out of sale or sharing: We do not sell or share personal information for cross-context behavioral advertising.

  • Right to limit use of sensitive personal information.

  • Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights.

To submit a CCPA request, contact us at [privacy@youragency.com] or call [Your toll-free number]. We will respond within 45 days.

9.3 Additional Rights for Canadian Residents (PIPEDA / Provincial Laws)

If you are a Canadian resident, you have rights under PIPEDA and applicable provincial privacy laws (including Quebec's Law 25):

  • Right of access: Request access to your personal information held by us.

  • Right to correction: Challenge the accuracy and completeness of your personal information and have it amended.

  • Right to withdraw consent: Withdraw consent to the collection, use, or disclosure of your personal information at any time, subject to legal and contractual restrictions.

  • Right to complain: File a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca or your applicable provincial privacy commissioner.

  • Quebec residents have additional rights under Bill 64 (Law 25), including the right to data portability and the right to de-index personal information published online.

9.4 How to Exercise Your Rights

To exercise any of your privacy rights, please contact us:

Email: team@flexdealer.com

Mail: FlexDealer Solutions Ltd., Attn: Privacy, 118 Lakeview Crescent, Beaumont Alberta, T4X 1T4

Phone: +1(877) 525-4709

We will respond to your request within 30 days (US) or 30 days (Canada / PIPEDA). We may need to verify your identity before processing your request.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18 without parental consent, we will take steps to delete that information promptly. If you believe we have collected information from a minor, please contact us at team@flexdealer.com.

11. Cross-Border Data Transfers

We are based in the United States and our Services are primarily operated from the US. If you are located in Canada, your personal information may be transferred to and processed in the United States, where privacy laws may differ from those in your province or territory.

By using our Services or providing us with your personal information, you acknowledge and consent to this transfer. We take steps to ensure that personal information transferred across borders is protected with appropriate safeguards, including contractual protections with our service providers.

12. Third-Party Websites & Links

Our Site may contain links to third-party websites, tools, or services not owned or controlled by us. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

Post the updated Privacy Policy on our Site with a new "Last Updated" date;

Notify you by email or SMS if the changes materially affect how we use your personal information; and

Where required by law (e.g., Quebec's Law 25), provide advance notice before changes take effect.

Your continued use of our Services after the effective date of any updated Privacy Policy constitutes your acceptance of the changes.

14. Contact Us & Privacy Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Privacy Officer:

Agency Name: FlexDealer Solutions LTD.

Privacy Officer: Michael Cirillo

Address: 118 Lakeview Crescent, Beaumont, Alberta, T4X 1T4

Email: team@flexdealer.com

Phone: +1(877) 525-4709

Website: https://www.flexdealer.com

Canadian residents who are not satisfied with our response may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or 1-800-282-1376. Quebec residents may contact the Commission d'acces a l'information du Quebec at www.cai.quebec.ca.

California residents who are not satisfied with our response may contact the California Privacy Protection Agency at www.cppa.ca.gov.