Privacy Policy

(Effective July 23, 2024)

Welcome!

Welcome to Future Firm®! We hope you will enjoy and appreciate using our “Services”, which may be visiting or using either of the Websites at https://futurefirm.co or https://futurefirmaccelerate.com (“Future Firm Accelerate®”) or any subdomain thereof (collectively, the “Websites”), or purchasing a “Membership” to receive coaching and training materials (“Materials”) from Future Firm® Accelerate, and access related and additional functionalities in the Services. The Services also include the Future Firm “Application” for iOS (the “iOS Application”) or Android (the “Android Application”), that you download for use onto your handheld or tablet “Device”.

Future Firm® Inc., the company that owns and operates the Websites and Services, want you to know we take your privacy and protection of personal data very seriously. We are providing this Privacy Policy (the “Policy”) to tell you about who we are, what personal data we collect from you and about you, and what we do with your personal data, all while you use the Services or otherwise interact with us. The Policy also explains your rights under the law, and how you can contact us and the necessary authorities to enforce those rights. We ask that you please read it carefully.

Key Elements of this Policy

Here are the key elements of this Policy so you can know the important parts right away to make an informed decision about your consent for our collection, use and disclosure of your personal data. By submitting any personal data to us via any means, you consent to such collection, use and disclosure. You can find the details in the rest of the Policy.

Personal data we collect from you but only with your consent	What we do with it	Third parties we share it with
Contact Information	Communicate with you and manage our relationship, depending on your relationship with us; verification of your identity for posting of blog comments; evaluate your application for a Premium+ Membership	Companies that provide our communications services, such as ConvertKit, and companies that provide the infrastructure and software for the Services such as Cloudways and MemberPress
Membership Information	Manage your Membership, and enable logging in to the Services	Companies that provide the infrastructure and software for the Services, such as Cloudways and MemberPress
Billing Information	Process the payments of your Membership Fees	Payment processors such as Stripe

Some Terms

Before we get started with the details, here are a few terms we think you should know as you read this Policy.

“Data Protection Laws” refers to the laws that are designed to protect your personal data and privacy in the place where you live. These include: (1) the “GDPR”, the European Data Protection Law which stands for “General Data Protection Regulation”, with the official name Regulation (EU) 2016/679 of the European Parliament and of the Council; (2) the “UK GDPR” which applies to our activities in the United Kingdom; please note that when this Policy refers only to the “GDPR”, this includes the UK GDPR as applicable; (3) “PIPEDA” (Personal Information Protection and Electronic Documents Act), which is the Canadian Data Protection Law that applies to our commercial activities in Canada; and (4) the Act Respecting the Protection of Personal Information in the Private Sector as amended by Law 25 (the “Quebec Private Sector Act”), which applies to our activities and users in Quebec. Future Firm® is committed to adhering to these Data Protection laws, and any other applicable Data Protection Laws. 

“Personal data” – this is information we collect from you or about you and which is defined in the GDPR as “any information relating to an identified or identifiable natural person.” It can be as simple as your name or your email, or something more complicated like an online identifier (usually a string of letters and / or numbers) that gets attached to you. Under PIPEDA, the equivalent concept is “personal information”, which is roughly the same. Any mention of “personal data” in this Policy shall also mean personal information. 

Other terms and definitions used in this Policy may be found in our Terms of Service, and will have the same meaning in this Policy as they do there. 

About Us and Contacting Us

Future Firm® Inc. is a duly-incorporated company in the Province of Quebec, Canada that owns and operates the Websites and Services. Where this Policy refers to “Future Firm®”, it may refer to Future Firm® Inc. and / or its shareholders, officers, directors, employees, agents, partners, principals, representatives, successors and assigns, depending on the context.

Under the GDPR, Future Firm® Inc. is a “data controller”. That means we collect personal data directly from you and determine the purpose and means of “processing” that data. “Processing” is a broad term that means collection, use, storage, transfer or any other action related to your personal data; it is used in this Policy in that way. Under PIPEDA, Future Firm is an “organization”, and under the Quebec Private Sector Act, Future Firm is an “enterprise”. Under PIPEDA, Future Firm “collects, uses, and discloses” your personal data, and under the Quebec Private Sector Act, Future Firm “collects, holds, uses or communicates to third persons” your personal data. When you read “processing” in this Policy, you can substitute either of those phrases.

If you want to ask us anything about what’s in this Policy, or anything else privacy- or data- related, or exercise any of your available privacy rights, you can email:

Future Firm® Privacy Officer
[email protected] 

Here is the mailing address for you as well:

Future Firm® Privacy Officer
1395 rue Fleury East,
Suite 102.2 Montreal, QC
Canada
H2C 1R7

Your Rights

You have the following rights regarding your personal data held by Future Firm®, and other privacy rights. Please note that not necessarily all of these rights may be available to you; this depends on the Data Protection Laws where you are located that apply to you. These rights may be exercised without affecting the price you pay for any of the Services. Notwithstanding that, exercising certain of these rights may affect your ability to use some or all of the Services.

• The right to withdraw at any time your consent for Future Firm® to process your personal data;
• The right to have your personal data erased from Future Firm®’s records;
• The right to have any hyperlink from the Services that is attached to your name removed;
• The right to access your personal data and any relevant information around its processing and use; 
• The right to have a copy of your personal data given to you in an easy-to-read format so that you can transfer it to another data processor;
• The right to have your personal data corrected or updated if you believe it is inaccurate or out of date;
• The right to opt out of marketing communications we send you, at any time;
• The right to know whether Future Firm® sells or shares your personal data (and if so, who gets it). Please refer to that information elsewhere in this Policy, though you can contact our Privacy Officer if you need additional information or clarifications;
• The right to restrict the processing of your personal data if it is inaccurate or if our processing or use of it is against the law; and 
• The right to refuse any marketing or advertising targeted at you by Future Firm®.

If you wish to exercise any of these rights, please contact our Privacy Officer at the contact information above, or refer to certain relevant sections further in this Policy.

Personal Data Collected from You and What We Use It For

In the table below, please find all the personal data we may collect from you directly, what we use it for, and the legal basis under the GDPR for us having and processing this personal data. Under PIPEDA and the Quebec Private Sector Act, the legal basis is your informed consent, and by submitting this personal data you acknowledge having granted this consent to Future Firm®.

Personal data category	Personal data processed	What we use it for (the “purpose” of processing)	Legal basis for processing under the GDPR
Contact Information	Name and email address	To communicate with you	Your consent in giving us this information
Contact Information	Name and email address	Verification of your identity for posting of blog comments	Your consent in giving us this information
Contact Information	Name, email address and your firm name	Evaluate your application to get a Plus Membership	Your consent in giving us this information
Membership Information	Name, mailing address, and email address	Manage your Membership, and enable logging in to the Services	Your consent and performance of a contract between you and us
Billing Information	Credit card number, credit card expiry date, card security code (CVV), and possibly billing address	Process the payments of your Membership Fees	Your consent in giving us this information

Where you have provided personal data further to the contract between you and us, if you fail to provide such data or withdraw your consent to use such data, we will no longer be able to provide certain Services to you. 

Personal Data Collected About You from Third Parties and What We Use It For

Sometimes we get personal data about you from third parties. This table explains the details about this personal data – what it is, where it came from and what we do with it. Under the GDPR, PIPEDA and the Quebec Private Sector Act, the legal basis for the processing of this personal data is your informed consent, and by using the Services, you agree that you have granted such consent. None of this data comes from publicly-available sources.

Personal data category	Personal data collected by the third party	Who collects the personal data	What we use it for
Membership Information	Name, mailing address, and email address	A Referral Partner where you signed up for a Membership	Validate your Membership, manage your Membership, and enable your logging in to the Services

 Furthermore, to the extent that analytics identifiers are generated from third parties, these may be considered personal data collected from third parties, and you can find details about that elsewhere in this Policy.

Sensitive Personal Data

We do not collect any of what the GDPR or the Quebec Private Sector Act considers sensitive personal data from you, unless you voluntarily submit it in User Content, which we encourage you not to do.

Who We Transfer Your Personal Data To

We routinely share some of your personal data with certain types of third parties who are identified in the table below along with what they do with it. Some of those third-party recipients may be based outside your home jurisdiction. If you are in the European Economic Area or the U.K., please see the “Transfer of Your Personal Data Outside of the European Economic Area” further down in this Policy for more information including on how we safeguard your personal data when this occurs. If you are in Quebec, please see the “Transfer of Your Personal Data Outside of Quebec” section further down in this Policy for information on how we safeguard your personal data when this occurs.

We will share personal data with law enforcement or other public authorities if: (1) we are required by applicable law in response to lawful requests, including to meet national security or law enforcement requirements; (2) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of Future Firm®’s Terms of Service; or (3) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming or denial of service attacks). 

We may also share personal data: (1) to a parent company, subsidiaries, joint ventures, or other companies under common control with Future Firm® (in which case we will require such entities to honour this Policy); or (2) if Future Firm® merges with another entity, is subject to a corporate reorganization, sells or transfers all or part of its business, assets or shares (in which case we will require such entity to assume our obligations under this Policy, or inform you that you are covered by a new privacy policy).

We will never share your personal data with other third parties except under these circumstances. We do not sell or rent your personal data to any third party for direct marketing purposes or any other purpose.

Personal data category	Who we transfer it to	What they do with it
Contact Information	Companies that provide email services, specifically ConvertKit, as detailed more fully in the Email Communications section below	Send you emails
Membership Information	Companies providing technical infrastructure and software for the Services, specifically  Cloudways and MemberPress	Control your logging in to the Services so they can be provided to you, send you emails, and record-keeping
Billing Information	Payment processing companies, specifically Stripe	Process the payments of your Membership Fees
Analytics identifiers and IP addresses	Companies that provide data analytics, specifically Google Analytics, Profitwell, WP Fusion, Hotjar and Mouseflow	Provide us with analytics as to how the Services are used, and to trace fraudulent activities

Tracking Technology (“Cookies” and Related Technologies)

Future Firm® uses tracking technology (“cookies” and related technology such as tags, pixels and web beacons) in the Services and by interacting with the Services you agree to their use. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the website or service and to improve the user experience by storing certain data on your computer or device. 

Specifically, we use cookies and related technologies for the following functions:

• to enable your logging-in to the Services and track your logged-in status to the Services;
• to coordinate logging in between your Device and anywhere else you may sign in to the Services;
• for the proper functioning of the Services, including the proper functioning of payment processing;
• to provide general internal and user analytics on the Websites and to conduct research to improve the content of the Services using Google Analytics as listed above in this Policy; 
• to track information about emails you receive, for example whether you opened it or clicked on any links in it; and
• to assist in identifying possible fraudulent activities.

Your browser can be set to refuse cookies or delete them after they have been stored. You can refer to your browser’s help section for instructions, but here are instructions for the most commonly-used browsers and operating systems:

• Google Chrome
• Mozilla Firefox
• Microsoft Edge
• Opera
• Apple Safari
• iOS
• Android

Please note that deleting or blocking certain cookies may reduce your user experience by requiring you to re-enter certain information, including information required to use our Services. Furthermore, deleting certain cookies may prevent certain functions, or the entirety of the Services, from working at all.

Email Communications and Compliance with Anti-Spam Laws

Future Firm® uses ConvertKit to manage our mailing list and send out our newsletter, and MemberPress to send out emails related to various Services functions (ConvertKit and MemberPress, collectively the “Email Service Providers”). Personal data is transferred to the Email Service Providers in order to manage the mailing list and for the emails to be sent out properly. Your Contact Information is only used to send out emails; the Email Service Providers do not use this personal data for any other purpose, and will not transfer or sell your personal data to any other third party. For more information, please refer to ConvertKit’s Privacy Policy and MemberPress’ Privacy Policy. 

You may unsubscribe from Future Firm®’s mailing list at any time, by following the link at the bottom of all Future Firm® emails. Other types of emails, such as transactional, relational, and other emails related to certain Services functions will not have an opt-out option as they are necessary for the use of the Services. 

Future Firm®’s practices in regards to its email are designed to be compliant with anti-spam laws, specifically the law unofficially called “CASL”, or Canada’s Anti-Spam Law (S.C. 2010, c. 23). If you believe you have received email in violation of these laws, please contact us using the contact information further up in this Policy.

How We Protect Your Personal Data

We have implemented very strict technical and organisational procedures for ensuring that, by default, only the personal data which is necessary for each specific purpose of the processing are processed by us. These procedures prevent your personal data from being lost; or used or accessed in any unauthorised way.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory authority of a suspected data security breach where the Data Protection Laws requires us to do so, and within the time frame required by the applicable Data Protection Law.

Future Firm® uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including personal data) secure. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Services, and these third parties have been selected for their high standards of security, both electronic and physical. For example, Future Firm® uses Cloudways, a recognized leader in secure data, for hosting of the Services and related data, and storage of data including personal data.

All information, including personal data, is transferred with encryption using Secure Sockets Layer (“SSL”) or Transport Layer Security (“TLS”), robust security standards for Internet data transfer and transactions. You can use your browser to check Future Firm®’s valid SSL security certificates on both Websites.

Future Firm® uses Stripe for processing of secured credit card payments for payments of Membership Fees made through the Services. Stripe is certified as a PCI-DSS (Payment Card Industry Data Security Standard) Service Provider Level 1, the highest-volume level for credit card transaction companies. 

Internal Procedures and Policies

In addition to the measures to protect your personal data described in the previous section, we have drafted and implemented certain internal procedures and policies regarding personal data, including the following:

1. A framework for the keeping and destruction of the personal data, including where we may keep anonymized data;
2. Defining and describing the roles and responsibilities of the members of Future Firm® personnel throughout the life cycle of the personal data; and
3. A process for dealing with individual complaints and requests for personal data and exercising of the individual’s rights under Data Protection Laws.

Transfer of Your Personal Data Outside of the European Economic Area (EEA) and the U.K.

For our European users, we endeavour to keep your personal data inside the EEA or the U.K. (as applicable). However, certain of our data processors (and Future Firm®) are in other countries where your personal data may be transferred. However, these countries are limited to countries with particular circumstances that protect your data, specifically:

• Canada. Canada has been determined to have an “adequate level of protection” for your personal data under European data protection law. 
• The United States. Your personal data is only transferred to companies in the United States that: (1) have signed agreements with us or have informed us that they are GDPR-compliant; and (2) have concluded the Standard Contractual Clauses for the transfer of personal data outside the EEA and the U.K. 

That’s it! You have the right, however, to refuse to have your data transferred outside the EEA. Please contact our Privacy Officer to make that request. Please note that making this request may prevent you from being able to use a portion or all of the Services.

Transfer of Your Personal Data Outside of Quebec

For our Quebec users and visitors, we endeavour to keep your personal data in Quebec. However, certain of our third-party service providers (and Future Firm) are in other provinces or countries where your personal data may be transferred. When this happens, we do the following to safeguard your personal data:

1. We will perform what the Quebec Privacy Act calls an “Assessment of the privacy-related factors” (what is generally called a “Privacy Impact Assessment,” or “PIA”) prior to the personal data leaving Quebec. If the PIA does not meet our standards and the standards required by the Quebec Privacy Act, we will not transfer your personal data to such a service provider; and
2. If the PIA allows us to transfer the personal data to such a service provider outside Quebec, we will sign what is generally called a “Data Processing Agreement,” or DPA, with the service provider, which protects the person data transferred to them and limits their use of it to what we have contracted with them to do. This DPA will adhere to the requirements of the Quebec Privacy Act. 

Supervisory Authorities and Complaints

If you are in the EEA or the U.K, under the GDPR you have the right to make a complaint to the appropriate supervisory authority. If you are not satisfied with the response received or the actions taken by our Privacy Officer, or if you would like to make a complaint directly about Future Firm®’s data practises, we invite you to contact the supervisory authority in your country. For example, if you are in the U.K., you should contact the Information Commissioner’s Office who is the supervisory authority. You can reach them in a variety of ways, including by phone (0303 123 1113 in the UK) and mail (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF). If you are in France, you should contact the Commission Nationale de l’Informatique et des Libertés who is the supervisory authority there. Their contact information can be found here. 

The full listing of all Data Protection Authorities (the supervisory authorities) across the EEA can be found here. 

If you are in Canada, you can make a complaint to the Office of the Privacy Commissioner here. If you are in Québec, you can make a complaint to the Commission d’accès à l’information, with the instructions for contacting them on their website.

Data Retention

Your personal data will only be kept for as long as it is necessary for the purpose needed for that processing. For example, we will only retain your Membership Information for as long as you have a Membership with us. We may, however, keep certain information for longer periods of time when required to by any law or regulation. 

Automated Decision-Making

Future Firm® does not use any automated decision-making processes in providing the Services.

Children’s Privacy Statement

The Services are not intended for children under the age of 18. We do not knowingly collect any personal data from a child under 18. If we become aware that we have inadvertently received personal data from a person under the age of 18 through the Services, we will delete such information from our records.

Changes to This Privacy Policy

The date at the top of this page indicates when this Policy was last updated. Every now and then, we will have to update this Policy, and we will update it no less than once every 12 months. You can always find the most updated version at this URL, and we will always post a notice on the Services if we make significant changes. If you have a Future Firm® Accelerate Membership, we will also email you to tell you the Policy has been updated, and what the important changes are. 

© Future Firm® Inc. 2024