PRIVACY POLICY

Effective Date: August 1, 2025

Cluney Co Ltd, "Cluney Co", "we", "our", or "us", operates websites, pages, applications, communities, and events that link to this page, together the "Site" or "Services". By visiting or using the Services, you agree that your use is governed by this Privacy Policy and these Terms of Service. If you do not agree, please stop using the Services.

Privacy Policy

Who we are and how to contact us

Controller, Cluney Co Ltd, Ottawa, Ontario, Canada. Email, [email protected]. Mail, Cluney Co Ltd, Attn, Privacy, 152-110 Didsbury Rd, Kanata, ON, K2T 0C2, Canada.

Scope

This Privacy Policy explains what personal information we collect on the Site, how we use it, with whom we share it, and the choices you have. It covers online collection on our websites and pages. It does not cover information you may give us offline, for example at a live event, over the phone, or by mail, which may be subject to separate notices.

How we collect and use information

We may collect and store personal or other information that you voluntarily provide while using the Site, for example when you request resources, subscribe, register for events, purchase programs, submit forms, or contact us. Common data elements include name, email, postal address, phone, business name, role, login data, and limited billing details, for example billing address and card last four digits. Full card numbers are processed by our payment providers, not stored by us.

We also collect information that is generated automatically as you navigate the Site, for example IP address, device and browser type, pages viewed, links clicked, session timestamps, and approximate location based on IP. We use cookies, pixels, tags, and similar technologies to remember preferences, measure performance, secure the Site, and personalize content and ads. You can control some cookies in your browser, however some features may not function without them.

We use your information to, provide and improve the Services, process orders and payments, communicate with you about your account and our programs, personalize content and ads, manage communities and events, analyze usage, prevent fraud, comply with law, and enforce our terms.

When we share information

We do not sell personal information for money. We may share it with, service providers that help us operate the Site, for example hosting, email, CRM, analytics, advertising, payments, customer support, and event logistics, business partners, for joint offerings you choose to join, authorities or others, to comply with law or protect rights, and parties to a business transaction, for example a merger or asset sale.

Google Analytics, Meta, and advertising tools

We use Google Analytics, including advertising features such as demographics, interests, remarketing, and impression reporting. Google and partners may use first party cookies and identifiers together with third party cookies or identifiers to understand activity on the Site. You can manage Google Ads settings and opt out via industry tools. We also use Meta Pixel and related tools to measure campaigns, build audiences, and improve relevance. We require our vendors and partners to handle data consistent with their public terms and applicable law.

Canada’s Anti Spam Legislation, CASL

We send commercial electronic messages only with consent or as otherwise permitted by law. Emails from us identify our business and include an unsubscribe link. You can withdraw consent at any time. We maintain consent records as required.

Your rights

Canada, PIPEDA, you may request access to your personal information, ask for corrections, withdraw consent, and ask about our privacy practices.

EEA and UK, GDPR, if GDPR applies to your data, you may have rights to access, correct, delete, restrict or object to processing, and data portability. You may contact your supervisory authority.

California, CPRA, if CPRA applies to your interactions with us, you may have rights to know, access, correct, delete, and limit certain uses of sensitive personal information, and to opt out of certain sharing. We do not sell personal information for money.

Children’s privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected such information, we will delete it. If practices change, we will obtain verifiable parental consent before any collection from children.

Storage, retention, and security

We store information with trusted providers and keep it only as long as necessary for the purposes described, and as required by law. We use administrative, technical, and physical safeguards appropriate to the nature of the information. No system is perfectly secure, so please contact us right away if you believe your information or account is at risk.

International transfers

We are based in Canada, and we use providers that may process information in Canada, the United States, and other countries. We use reasonable safeguards for cross border transfers, for example contractual protections.

Changes to this Privacy Policy

We may update this Policy, and we will post the revised version with a new effective date. Continued use of the Site after updates means you accept the changes.

Contact

Questions or requests, email [email protected], or write to the address above.

Terms of Service

Date Effective, August 21, 2025

The following Terms of Service apply to your use of the Site and Services. We may change these Terms at any time in our discretion, and we will post updates here. Continued use after updates means you accept the revised Terms.

General

This Site is owned and operated by Cluney Co Ltd. By using the Site, you agree to be bound by these Terms, our Privacy Policy, our refund or cancellation policies for specific products or events, and any additional terms that apply to particular offerings.

Accessing the Site in any manner, automated or otherwise, constitutes use of the Site and your agreement to these Terms.

Intellectual property rights

Our limited license to you, the Site and its content are owned by us or our licensors and are protected by intellectual property laws. You may view the Site for your personal, non commercial use. Except as permitted by law or by us in writing, you may not copy, reproduce, modify, publish, upload, post, transmit, translate, sell, create derivative works, or distribute any content. You may download or print one copy of individual pages for personal, non commercial use, provided you keep all notices intact.

Your license to us, if you submit or post content, for example comments, testimonials, photos, videos, or materials in our groups or to our team, you represent that you own or have permission for that content and that you are at least thirteen years of age. You grant us a non exclusive, worldwide, royalty free, perpetual license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, perform, and display your content in any media for any lawful business purpose. Where applicable law deems eligible works created for us to be works made in the course of employment or works made for hire, we will own those works from creation, otherwise you assign to us all rights necessary to achieve the same result, subject to any rights you cannot assign under law.

Linking and framing, you may link to the Site, provided the link does not state or imply any sponsorship or endorsement. You may not frame or inline link Site content or incorporate our materials into another service without written permission.

Disclaimers

We may provide links and pointers to third party sites. These do not constitute an endorsement. We do not control third party sites or services. Opinions and content provided by third parties are their own. The Site and all information, products, and services are provided "as is" and "as available" without warranties of any kind, express or implied, including implied warranties of merchantability, fitness for a particular purpose, and non infringement, to the extent permitted by law. We do not warrant that the Site will be uninterrupted or error free, that defects will be corrected, or that the Site or servers are free of harmful components. Your use is at your own risk.

Online commerce

Some areas of the Site allow purchases from us or third parties. If you transact with a third party, that party’s terms and privacy practices apply. We are not responsible for third party sites, stores, products, services, policies, or actions. You agree to use the Site to make legitimate purchases only, not for speculative or fraudulent purposes, and to provide accurate information. You agree to be financially responsible for purchases made by you or by someone acting on your behalf.

Interactive features

The Site or related platforms may include groups, communities, chats, comments, forums, or similar features. You are solely responsible for what you post. You agree not to, restrict or inhibit other users, impersonate any person, interfere with networks, encourage illegal activity, gain unauthorized access, harvest personal information for marketing, or post material that is unlawful, defamatory, obscene, infringing, invasive of privacy, or that contains viruses or advertising without permission. We may, but are not required to, monitor or remove content at our discretion.

Registration and passwords

Some features may require registration. You agree to provide accurate, current, and complete information. You are responsible for safeguarding your credentials and for all activity under your account. Notify us promptly of any unauthorized use.

Educational and professional disclaimers

We provide education and general information only, not legal, accounting, investment, medical, psychological, or other professional advice. You should consult your own professionals. Any examples, testimonials, or case studies illustrate possible outcomes, not promises of results. Your results vary.

Limitation of liability

To the maximum extent permitted by law, Cluney Co Ltd and its affiliates will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits or revenues, arising from or related to your use of the Site or any products or services, even if advised of the possibility. Where liability cannot be excluded, it is limited to the amount you paid for the relevant product or service, or one hundred Canadian dollars if no purchase occurred, whichever is greater.

Termination

We may suspend or terminate your access to the Site at any time without notice. Upon termination, your right to use the affected parts of the Site ends, and provisions that by their nature should survive, for example ownership, licenses, disclaimers, limitations of liability, and dispute terms, will continue.

Refunds

Your purchase of a product, service, or event may include a separate refund or cancellation policy, which will govern that purchase. Please review the policy presented at checkout or in the offer terms.

Copyright concerns

If you believe material on the Site infringes your copyright, please send a notice that includes, your contact details, identification of the work and the material claimed to be infringing, the location of the material, and a statement of good faith belief and accuracy, signed by you or your agent, to [email protected]. We will respond as required by applicable Canadian law, including the notice and notice regime.

Governing law, venue, and dispute resolution

These Terms are governed by the laws of Ontario and the federal laws of Canada that apply. Any dispute will be resolved by binding arbitration in Ottawa, Ontario, conducted in English under the Arbitration Act, 1991, Ontario, on an individual basis. You and we waive any right to participate in class or representative actions, to the extent permitted by law. If any provision is unlawful, void, or unenforceable, it will be severed, and the remaining provisions will continue in full force.

Assignment

These Terms bind and benefit Cluney Co Ltd and our assigns, successors, and legal representatives. You may not assign these Terms without our prior written consent. We may assign our rights and obligations to an affiliate or successor without notice.

Contact

Cluney Co Ltd, [email protected], or the mailing address listed above.

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