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.

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.

9.     Cookies and Tracking Technologies. The Platform may use cookies, pixels, and similar tracking technologies to enable core functionality, maintain user sessions, improve user experience, and analyze usage patterns. Such technologies may collect technical and usage information but are not used by Momentum to independently identify individuals except as required to provide 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 designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. While no security measures can guarantee absolute security, Momentum regularly reviews and updates its safeguards to align with industry standards.

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.

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. 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 T1K 7R8 Canada