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Privacy Policy

This Privacy Policy describes the collection, use and disclosure policies and procedures that govern your  information in connection with your interactions with FOM INC., (“FOM” or “We or “Us”). Such  interactions include but are not limited to your use of any applications, websites found and published at https://frameofmindcoaching.com, https://thejournalthattalksback.com, https://frameofmindjournal.com,  https://journalengineportal.com, https://journalengine.com and such other locations on the internet as made  available from time to time by us, content and products and services operated by FOM (collectively referred  to as the “Platform”), and any contact between you and our representatives (unless specifically excluded  herein) whether transmitted via the Platform, facsimile, electronic correspondence, texts, verbally or in person (collectively, the “Interactions”). 

When engaging in any of the Interactions regardless of whether you have requested or received any of the services offered via the Platform including but not limited to Coaching Services (collectively, the “Platform Services”), you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Where legally required (e.g., under GDPR/UK GDPR, CPPA, or CCPA/CPRA), we will only process your information when we have a lawful basis, such as: your consent, the performance of a contract, compliance with legal obligations, protection of vital interests, legitimate interests pursued by us or a third party, or other lawful grounds.

 

Irrespective of which country you reside in or create information from, your information may be used by us in Canada. If your information is transferred outside of your jurisdiction (e.g., EU/UK to Canada), we will implement appropriate safeguards as required by Canadian law to ensure adequate protection of your data.

The Interactions and Platform Services are collectively defined herein as the “Services”. For  clarity, the term “you” or “your” refers also to you on behalf of your Dependent(s), as defined below,  where applicable. 

This Privacy Policy is in accordance with the Personal Information Protection and Electronic Documents  Act (“PIPEDA”), as amended by the Digital Privacy Act (“DPA”), and anticipates requirements under the proposed Consumer Privacy Protection Act (“CPPA”). If you are located in the European Economic Area (“EEA”), the United Kingdom, or certain U.S. states (e.g., California, Virginia, Colorado, Connecticut, Utah), this Privacy Policy is also intended to comply with the General Data Protection Regulation (GDPR/UK GDPR) and applicable state privacy laws. . In the event of a conflict between any provision  of this Privacy Policy and the governing statute noted above, the governing statute will govern for such  provision.  

1. Definitions

“Dependent” means individuals for whom you have the legal authority to make decisions for whom you are the legal guardian; 

“Coach(es)” means individuals on contract or in the employment of FOM that serve to offer Services through our Website. 

“Personal Information” means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address) or information readily available to the public. This includes, but is NOT limited to, name, date of birth, home address, contact information, email address and payment information.

2. Collection of Personal Information 

Any Interaction may result in our collection of Personal Information. We collect Personal Information  directly from you, or indirectly from third party sources as otherwise permitted by applicable law. 

a) Information collected on the Platform including but not limited to, names, addresses, emails, phone  numbers, birthdates, sex, and other information will be stored in FOM’s electronic record, email  and phone system. 

b) Account: When you create or reconfigure an account on the Platform (the “Account”), you may provide Personal Information, such as your name, contact information, email address, etc. 

Registration for the Service requires a birth date and place of residence. Registration and access  to the Platform is restricted to persons of the age of 18 years and older. 

c) Log Data: Our servers automatically record information (“Log Data”) related to your actions on  the Platform. Log Data may include information such as your IP address, browser type, internet  service provider, date/time stamps, the referring domain, pages visited, products viewed and search  terms. Other actions, such as interactions with the Platform may be also included in Log Data. Log  Data may also be recorded by third party websites.  

d) Links: The Platform may keep track of how you interact with links by redirecting clicks or through  other means. We do this to help improve our Services, and to be able to share aggregate click  statistics such as how many times a particular link was clicked on. The Platform may also use  tracking technologies such as web beacons, tags and pixels to record information about how you  browse the Platform.  

e) Cookies: Like many websites, we use “cookie” technology to collect additional Platform usage  data and to improve our Services, but we do not require cookies for many parts of the Platform. A  cookie is a small data file that is transferred to your computer’s hard disk. The Platform may use  both session cookies and persistent cookies to better understand how you interact with our Platform,  to monitor aggregate usage by our users and web traffic routing, and to improve our Services. Most  Internet browsers automatically accept cookies. You can instruct your browser, by editing its  options, to stop accepting cookies or to prompt you before accepting a cookie from the websites  you visit. However, keep in mind that this may disrupt the Services being provided to you.  Where legally required (e.g., GDPR, CPRA), we will obtain your consent before placing non-essential cookies or using tracking pixels for analytics or advertising. You may manage your preferences through our cookie banner. 

f) Device Identifiers: When you use a mobile device like a tablet or cell phone to access our Platform,  we may access, collect, monitor, store on your device, and/or remotely store one or more “device  identifiers.” A device identifier may be data stored in connection with the device hardware, data  stored in connection with the device’s operating system or other software, or data sent to your  device.  

g) E-Mail: You may decide to send us Personal Information in an e-mail message whether or not you  have created an Account.  

h) Third Party Services: We use a variety of services hosted by third parties to help provide our  Services, and to help us understand the use of our Platform, such as Google Analytics. These  services may collect information sent by your browser as part of a web page request, such as cookies  or your IP request.  




3. How We Use Your Information  

We rely on implied consent for the basic information you provide when you join (like your name and email), as well as any optional details you choose to share.  If your local laws require it, we may also use your information to deliver our services or meet legal obligations. You have the right to withdraw consent at any time by contacting us via e-mail.

Automated Decision-Making: We do not use your Personal Information for automated decision-making or profiling that produces legal or similarly significant effects. If this changes, we will provide notice and your rights to opt out.

Platform: In addition to some of the specific uses of Personal Information we describe in this Privacy  Policy, we may use such information or share such information to:  

  1. a) confirm your eligibility to use the Platform, create an Account for you, authenticate you when you  log onto the Platform and personalize your experience on the Platform; 
  2. b) determine your eligibility for any requested Platform Services;  
  3. c) connect you to the appropriate Coach, and to disclose the Personal Information necessary to  facilitate the requested Platform Services;  
  4. d) help you efficiently access your Personal Information after you sign in to your Account; e) establish, maintain and manage client relations with you so that we may provide you with the  requested Services;  
  5. f) provide personalized content and information to you and others, which could include online ads or  other forms of marketing (you can choose not to receive any electronic marketing communications  from us by clicking the “Unsubscribe” function contained in all of our electronic communications  or by contacting us at [email protected]); 
  6. g) receive your feedback and provide ongoing customer service to you; 
  7. h) develop and test new products or services and features and improve our level of service;  i) communicate additional service offerings for products (e.g. coaching services, self-improvement  services, product resources) via email/text/phone or video; 
  8. j) provide information about the Platform including updates and notifications;  
  9. k) monitor metrics such as total number of visitors, users, traffic, and demographic patterns; 
  10. l) facilitate payments for Platform Services;  
  11. m) diagnose or fix technology problems;  
  12. n) meet legal and regulatory requirements; and  
  13. o) such other purposes consistent with these objectives and as may be permitted or required by  applicable law.  

Information about you and your use of the Services may be aggregated with other information in ways that  do not personally identify you (the “Aggregated Information”) or constitute Personal Information. This  type of aggregated or statistical information may be used by us to improve the quality of the Services or for  other purposes that we may deem appropriate. 

4. Information Sharing and Disclosure 

Our use of Personal Information is limited to the purposes described in this Privacy Policy and we do not  otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information that we have  obtained. We will not share your Personal Information with any third party except we may disclose your  Private Information in the limited circumstances described herein.  

a) Your Consent: We may share or disclose your information with your consent. Consent can be either  expressed (verbally, in writing or electronically) or implied, where permitted under applicable law. In  determining the appropriate form of consent, we will consider the sensitivity of the information. When  you provide your Personal Information voluntarily on the Platform or to a Coach, you imply that you  have consented to the collection, use and disclosure of such information. You may change or withdraw  your consent at any time, subject to legal or contractual restrictions and reasonable notice, by  contacting us at [email protected]. Please note that in some circumstances, a change in  or withdrawal of consent may severely limit our ability to provide the requested services.  

b) Without Consent: Please note that there are circumstances where the use and/or disclosure of your  Personal Information may be justified or permitted or where we are obliged to disclose information  WITHOUT consent. Such circumstances are consistent with PIPEDA and the DPA and may include,  but are not limited to the following: if we believe that it is reasonably necessary to comply with a law,  regulation or legal request; to protect the safety of any person; to address fraud, security or technical  issues; or to protect our rights or property.  

c) Non-Personal Information: We may share or disclose Aggregated Information derived from your  information or your non-Personal Information.  

d) Service Providers: We may share Personal Information with Coaches, our employees, and contractors  and business partners, to the extent required for them to provide the services you have requested or for  the purposes described in this Privacy Policy. We engage certain trusted third parties to perform  functions and provide services to us such as website hosting companies, payment processing  companies and other third-party service providers. We may share Personal Information with these third  parties, but only to the extent necessary to perform these functions and provide such services, and only  pursuant to obligations mirroring the protections of this Privacy Policy. 

e) Business Transfers: In the event that we are involved in a bankruptcy, merger, acquisition,  reorganization or sale of assets, your information may be disclosed or transferred as part of that  transaction. The promises and exceptions in this Privacy Policy will apply to your Personal Information  as transferred to the new entity with the same exceptions herein.  

f) Governmental: We may share Personal Information with government agencies and law enforcement  officials, when required to do so to respond to subpoenas, court orders or legal process, or to establish  or exercise our legal rights or defend against legal claims. 

g) “Do Not Sell or Share” Rights (California residents): We do not sell your Personal Information for money. However, under California law, “share” may include use of analytics or advertising providers. If applicable, you may exercise your right to opt out of such sharing by contacting us.

h) Cross-Border Transfers: If your data is transferred outside your jurisdiction (e.g., EU/UK to Canada or U.S.), we will ensure lawful transfer mechanisms are in place.

 

5. Accessing, Modifying and Disposing of Personal Information  

User Generated Personal Information: We endeavour to ensure that your Personal Information (referred  to here as the “User Generated Personal Information”) is accurate, current and as complete as possible  to fulfill the purposes for which the information has been collected, used, retained and disclosed. You may  email us at [email protected] to request access to review, challenge the accuracy of or  request deletion of the User Generated Personal Information held by us and to request corrections and we  will respond within a reasonable time. To guard against fraudulent requests, we may require sufficient  information to allow us to confirm that the person making the request is authorized to do so before granting  access or modifying any User Generated Personal Information. We may also deny your request if permitted  or required by law and if so, provide you with the reasons for the denial.  

If you successfully demonstrate the inaccuracy or incompleteness of any of the User Generated Personal  Information, we will amend or delete such information as required. If we do not agree on the resolution to  your satisfaction, we will document the substance of the unresolved challenge.  

Where appropriate, we will transmit the amended information or the existence of the unresolved challenge,  as the case may be, to third parties having access to the information in question so that they may modify  their records accordingly. We are however, not responsible nor liable for the failure of such third parties to  update their records. 

Protection of Personal Information and Disclaimer: We endeavor to maintain appropriate physical,  procedural and technical security with respect to our offices and information storage facilities so as to  prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This  also applies to the disposal or destruction of Personal Information. We further protect your Personal  Information and any financial or payment information by restricting its access to those employees and  contractors who need to have knowledge of that information in order for us to provide our Services, as  determined by our management. While we continue to work hard to protect your Personal Information, no  data transmission over the internet can be guaranteed to be absolutely secure, and we cannot ensure or  warrant the security of any information you transmit to us via the Platform or otherwise; any transmission  is at your own risk.  

Depending on your jurisdiction, you may have the following additional rights:

  • Right to erasure (“right to be forgotten”).
  • Right to restrict processing.
  • Right to data portability.
  • Right to object to processing (including marketing and profiling).
  • Right not to be subject to automated decision-making.

We will respond to rights requests within the timelines required by law (e.g., 30 days under GDPR, 45 days under CCPA).

6. Information Retention  

Account Personal Information: We will retain your User Generated Personal Information in your Account  on your behalf for as long as your Account exists subject to legal requirements and our notice to you. 

7. Confidentiality 

All Parties agree to and understand that all content, whether submitted to a Coach, other members or any  user within the site, whether proprietary or otherwise, remains private and confidential and may not be  used outside of this site without the express written permission of the owner. It is further understood that  the privacy settings available for each post are to be used at the sole discretion of the user in accordance  with their preferred privacy setting. 

The Parties shall use all reasonable efforts to maintain the confidentiality of the information and materials,  whether oral, written or in any form whatsoever, of the other users that may be reasonably understood, the  nature of such information itself and/or the circumstances of such information’s disclosure, to be  confidential and/or proprietary thereto (collectively, “Confidential Information”); The foregoing shall not  require separate written agreements with employees and agents already subject to written agreements  substantially conforming to the requirements of this Section nor with legal counsel, certified public  accountants, or other professional advisers under a professional obligation to maintain the confidences of  clients. 

8. Security and Breach Notification

We implement physical, technical, and organizational safeguards consistent with industry standards. Where required by law (e.g., PIPEDA, CPPA, GDPR, U.S. state laws), we will notify you and/or relevant regulators of a data breach that poses a risk of significant harm to you, within legally mandated timelines.

9. Changes to this Policy  

We may revise this Privacy Policy from time to time. The most current version of the policy will govern  our use of Personal Information and will be located on this page unless we notify you otherwise. If we make a material change, we will notify you by e-mail where possible and, where required by law, obtain your renewed consent. Please  check this page periodically for updates. By continuing to access or use the Services after those changes  become effective, you agree to be bound by the revised Privacy Policy. 

10. Contact Us 

If you have any questions, concerns, complains, requests or comments regarding your Personal Information  or our Privacy Policy, please contact us at:  [email protected] 

Last Updated: September 18, 2025