1.     This Privacy Policy describes how Momentum EQ Inc. ("Momentum", "we", "us", or "our") collects, uses, discloses, stores, and protects personal information in connection with access to and use of the coachstudio.io platform (the "Platform").

2.     This Privacy Policy forms part of, and is incorporated by reference into, the Momentum Growth Suite User Agreement and the applicable Terms and Conditions governing use of the Platform.

3.     By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, disclosure, and processing of personal information as described herein. If you do not agree with this Privacy Policy, you must not access or use the Platform.

4.     User as Data Controller. Users of the Platform act as the data controllers with respect to all personal information relating to their own clients, customers, and end users that is uploaded to, generated through, or otherwise processed using the Platform ("User Data"). Users determine the purposes and means of processing such personal information and are responsible for ensuring compliance with all applicable privacy and data protection laws.

5.     Momentum as Data Processor. Momentum acts solely as a technology service provider and data processor in respect of User Data.

6.     Momentum processes personal information only on documented instructions from Users and for the limited purposes of providing, operating, maintaining, and supporting the Platform, except where processing is otherwise required by applicable law.

7.     Information We Collect. Personal information processed through the Platform may include, without limitation:

a.     account and business Information, such as name, business name, contact details, login credentials, and billing or payment-related information;

b.     User-provided content and data, including client contact information, communications, messages, files, records, automation workflows, and other information uploaded to or generated through use of the Platform;

c.     usage and technical Information, such as IP addresses, device identifiers, browser type, operating system, log files, timestamps, and information relating to interactions with the Platform; and

d.     support and communications information, including correspondence with Momentum’s support personnel.

e. Mobile phone numbers and SMS consent records, including the date, time, and method of opt-in consent, for the purpose of delivering requested text message communications through the Momentum Growth Suite platform.

8.     Purposes of Processing. Momentum will process personal information solely to:

a.     provide, operate, maintain, and improve the Platform;

b.     authenticate users and administer accounts;

c.     provide technical support and respond to inquiries;

d.     process payments and manage billing;

e.     monitor platform performance, security, and integrity;

f.       comply with applicable legal, regulatory, and contractual obligations; and

g.     enforce the User Agreement and Terms and Conditions.

h. send SMS text message communications to individuals who have provided express written consent to receive such messages, solely for the purpose of delivering the message types to which the individual consented (including lead follow-up, appointment reminders, client onboarding, and promotional communications related to the Momentum Growth Suite).

9.     Cookies and Tracking Technologies. The Platform may use cookies, pixels, and similar tracking technologies, including session cookies (which expire when you close your browser), persistent cookies (which remain on your device for a set period), and analytics pixels used to understand how users interact with the Platform. These technologies may collect technical and usage information such as pages visited, time spent, and device type. Momentum does not use these technologies to independently identify individuals for marketing purposes except as required to operate the Platform. You may disable cookies through your browser settings; however, doing so may affect the functionality of certain Platform features.

SMS Communications. Momentum EQ Inc. may send SMS text messages to individuals who have provided express written consent through a web form, landing page, or other consent-capture mechanism operated by Momentum EQ Inc. By opting in, you agree to receive text messages related to lead follow-up and sales outreach, appointment reminders, client onboarding, and promotional offers related to the Momentum Growth Suite platform.

Message frequency may vary. You may opt out of SMS communications at any time by replying STOP to any message. For assistance, reply HELP. Message and data rates may apply as determined by your mobile carrier.

Consent to receive SMS messages is not a condition of any purchase or use of the Platform.

10. Third Party Service Providers. Momentum may engage third-party service providers and subprocessors, including hosting providers, payment processors, analytics providers, and communications service providers, to support delivery of the Platform.

11. These third parties may process personal information on Momentum’s behalf and in accordance with contractual obligations that are substantially similar to the protections described in this Privacy Policy.

12. Personal information processed through the Platform may be stored or processed in jurisdictions outside Canada, including the United States. Such cross-border processing may be subject to the laws of those jurisdictions.

13. Momentum uses commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction, having regard to the sensitivity of the information and applicable legal requirements.

14. Users are solely responsible for:

a.     providing appropriate privacy notices to their clients and end users;

b.     obtaining all necessary consents and authorizations for the collection, use, and disclosure of personal information;

c.     responding to requests from individuals to access, correct, delete, restrict, or transfer their personal information;

d.     establishing and implementing appropriate data retention and deletion policies; and

e.     complying with all applicable privacy and data protection laws.

15. Momentum does not respond directly to data subject requests relating to User Data except at the direction of the applicable User or as required by law. Momentum will reasonably cooperate with Users to enable them to respond to such requests.

16. Information Disclosure. Momentum may disclose personal information where required or permitted by law, including to comply with legal processes, court orders, or regulatory requirements, or where necessary to protect the rights, property, or safety of Momentum, Users, or others.

17. Security Safeguards. Momentum implements commercially reasonable administrative, technical, and physical safeguards to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption of data in transit using industry-standard protocols, access controls limiting data access to authorized personnel, and regular review of security practices in alignment with industry standards. In the event of a confirmed security incident affecting personal information under Momentum’s control, Momentum will notify affected Users in accordance with applicable privacy legislation. No security measures can guarantee absolute protection, and use of the Platform is at the User’s own risk.

18. Data Retention and Deletion. Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, to provide the Platform, or to comply with legal obligations. Upon termination of a User’s account, personal information may be deleted or anonymized in accordance with contractual obligations and applicable law, subject to any required retention periods.

Your Rights. Individuals whose personal information is processed through the Platform may have the right to: (a) request access to their personal information held by Momentum; (b) request correction of inaccurate or incomplete personal information; (c) request deletion of personal information, subject to applicable legal retention obligations; (d) withdraw consent to receive SMS communications at any time by replying STOP to any text message, or by contacting Momentum directly at the address below; and (e) request that their personal information not be used for direct marketing purposes.

To exercise any of these rights, please contact: Momentum EQ Inc., 392 Red Crow Blvd., Lethbridge, Alberta T1K 7R8, Canada, or by email at the address listed on our website.

19. Security Incidents. In the event of a security incident involving personal information under Momentum’s control, Momentum will notify affected Users in accordance with applicable privacy legislation. Users remain responsible for assessing and fulfilling any notification obligations to their clients, end users, regulators, or other parties.

20. No Sharing of SMS Opt-In Data. Mobile opt-in data — including mobile phone numbers and SMS consent records collected through Momentum EQ Inc.’s web forms, landing pages, or other consent mechanisms — will not be shared with, sold to, rented to, or disclosed to any third party for their own marketing, advertising, or promotional purposes. This data is used solely to deliver the SMS communications to which the individual has consented.

Third-party service providers engaged by Momentum EQ Inc. to assist in delivering SMS communications (such as messaging platform providers) may process this data on Momentum’s behalf, subject to confidentiality obligations, and solely for the purpose of sending the consented communications. Such providers are not permitted to use this data for their own independent marketing purposes.

20. Changes to this Privacy Policy. Momentum may amend this Privacy Policy from time to time. Updated versions will be made available through the Platform. Continued use of the Platform following any update constitutes acceptance of the revised Privacy Policy.

21. Contact Us. Questions regarding this Privacy Policy may be directed to: Momentum EQ Inc. 392 Red Crow Blvd Lethbridge, Alberta, Canada T1K 7R8