Privacy Policy

1. Overview and Controller

This Privacy Policy explains how Vas Group Inc., doing business as Freedom.co ("Freedom.co," "Company," "we," "us," or "our"), collects, uses, discloses, retains, transfers, and protects personal information in connection with the Freedom Pathfinder quiz, checkout, custom report, emails, bonus trial access, websites, software, and related services (collectively, the "Service").

For purposes of applicable privacy laws, Vas Group Inc. is the organization responsible for personal information processed through the Service, except where a third-party provider acts as an independent controller under its own terms and privacy policy.

By using the Service, you acknowledge this Privacy Policy and our Terms of Service. If you do not want us to process personal information as described here, do not use the Service.

2. Personal Information We Collect

We may collect the following categories of personal information:

• Identifiers and contact information: email address, first name where requested, purchase email, support contact information, and similar identifiers.
• Quiz and intake information: multiple-choice answers and written responses about your background, work history, skills, interests, strengths, personality, goals, constraints, available time, resources, investment range, business preferences, desired outcomes, and other information you choose to provide.
• Purchase and transaction information: payment status, amount, currency, purchase date, Stripe payment intent identifiers, receipt email, chargeback or dispute information, fraud signals, fulfillment state, and related records. We do not store your full payment card number.
• Generated report information: AI-assisted diagnosis, report JSON, report HTML, generated recommendations, email delivery status, sent email copy where stored, delivery attempts, support notes, and quality or audit records related to your report.
• Trial and community access information: information needed to create, verify, deliver, or support bonus Freedom OS, community, or course-platform access, such as email, invite status, claim token, claim status, access status, and related metadata.
• Communications: support requests, replies to emails, feedback, testimonials if submitted, complaints, privacy requests, dispute communications, and related history.
• Technical, device, and usage information: IP address, browser type, device information, operating system, pages visited, timestamps, referral URLs, log data, error records, security events, checkout events, provider diagnostics, and similar information collected by us or our service providers.
• Inferences and analytics: internal assessments, segmentation, aggregate metrics, product performance data, and business analytics derived from the information above.

We do not ask you to provide sensitive personal information that is unnecessary for the Service. Please do not submit government identifiers, full financial account numbers, passwords, health information, precise geolocation, biometric information, information about children, or confidential third-party information in quiz responses or support messages.

3. Sources of Personal Information

We collect personal information directly from you when you use the quiz, enter your email or name, complete checkout, request support, claim bonus access, or otherwise communicate with us. We also receive information automatically from your browser, device, hosting environment, payment processor, email provider, database provider, AI provider, community platform, security tools, and other service providers involved in operating the Service.

4. How We Use Personal Information

We use personal information for the following purposes:

• to operate, personalize, and provide the quiz, checkout, payment verification, report generation, report delivery, and bonus access flow;
• to create, store, audit, resend, regenerate, and support your Freedom Pathfinder report;
• to process payments, receipts, chargebacks, disputes, fraud checks, accounting records, and related fulfillment obligations;
• to send transactional emails, service messages, report delivery emails, trial access instructions, support responses, security notices, legal notices, and administrative communications;
• to provide customer support, investigate delivery issues, verify purchases, respond to requests, and resolve disputes;
• to secure, monitor, debug, test, maintain, and improve the Service and related systems;
• to prevent fraud, abuse, unauthorized access, spam, misuse, violations of law, and violations of our terms;
• to analyze aggregate usage, conversion, product quality, business performance, and operational reliability;
• to send marketing communications where permitted by law and subject to your available unsubscribe rights;
• to comply with legal, tax, accounting, regulatory, security, contractual, insurance, and dispute-resolution obligations;
• to enforce agreements, protect rights, and support business transactions such as a merger, acquisition, financing, reorganization, or sale of assets.

5. Legal Bases for Processing

Where applicable law requires a legal basis for processing personal information, we rely on one or more of the following bases: performance of a contract with you; your consent; compliance with legal obligations; our legitimate interests or the legitimate interests of others; protection of rights, safety, and security; and, where necessary, establishment, exercise, or defense of legal claims.

Our legitimate interests include operating and improving the Service, securing systems, preventing fraud and abuse, providing support, analyzing aggregate performance, communicating with users, enforcing our terms, and marketing our services where lawful.

6. AI Processing and OpenAI

To generate your custom report, we may send relevant quiz answers, intake details, report instructions, and internal Freedom Pathfinder knowledge materials to OpenAI through the OpenAI API. OpenAI processes this information to help produce structured analysis and report content.

We do not intentionally send your full payment card details to OpenAI. Free-text quiz responses may be included in AI prompts, so you should avoid submitting unnecessary sensitive, confidential, or third-party information.

OpenAI states that business API data is not used to train or improve OpenAI models unless the API customer opts in, and that API data may be retained for abuse monitoring or application-state purposes depending on endpoint, configuration, and applicable settings. OpenAI's data controls are available at platform.openai.com/docs/guides/your-data.

AI output may be inaccurate, incomplete, or unsuitable for your circumstances. We may store prompts, generated reports, structured analysis, and related records as needed to provide the Service, support delivery, audit quality, prevent duplicate fulfillment, improve reliability, and enforce our terms.

7. How We Disclose Personal Information

We do not sell quiz answers or generated reports for money. We may disclose personal information to the following categories of recipients as reasonably necessary for the purposes described in this Privacy Policy:

• Payment processors: Stripe or similar providers process payment, billing, receipt, transaction, fraud, dispute, and chargeback information.
• Database and infrastructure providers: Supabase, Netlify, hosting providers, serverless providers, storage providers, logging providers, and security providers help operate and secure the Service.
• AI providers: OpenAI or similar providers process quiz answers and report instructions to generate AI-assisted output.
• Email and communications providers: Resend or similar providers send report emails, transactional messages, support communications, and related delivery records.
• Community and course platforms: Circle or similar providers may receive information needed to create, verify, invite, or manage bonus trial or community access.
• Analytics, debugging, and security providers: vendors that help us measure performance, diagnose errors, secure systems, prevent abuse, and understand aggregate use.
• Professional advisors: lawyers, accountants, auditors, insurers, banks, payment dispute processors, and other advisors.
• Legal, regulatory, and safety recipients: courts, regulators, law enforcement, government authorities, or other parties where disclosure is required or appropriate to comply with law, protect rights, enforce agreements, prevent fraud, or address security issues.
• Business transaction parties: counterparties and advisors in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, subject to appropriate confidentiality or continuity protections where practical.

We may also disclose aggregated, anonymized, or deidentified information that does not reasonably identify you.

8. Cookies, Local Storage, Pixels, and Similar Technologies

The Service and our providers may use cookies, local storage, pixels, tags, logs, SDKs, and similar technologies to operate checkout, remember state, process payments, prevent fraud, secure the Service, diagnose errors, measure performance, and understand usage.

Stripe and other third-party providers may use their own cookies or similar technologies when their services are loaded. You can control cookies through your browser settings. Blocking cookies may interfere with checkout, payment confirmation, report delivery, or other Service functionality.

9. Email and Marketing Choices

We may send transactional or service-related messages about your quiz, payment, report, bonus access, support request, security, legal notices, or administrative matters. You cannot opt out of messages that are necessary to provide or administer the Service.

If we send promotional emails, you may unsubscribe using the unsubscribe link in the email or by contacting support@freedom.co. Unsubscribing from promotional emails does not stop transactional, legal, or service-related messages.

10. Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law, contract, security needs, backup practices, dispute resolution, fraud prevention, tax, accounting, or legitimate business needs.

Retention periods vary by data type. Payment and fulfillment records may be retained for tax, accounting, chargeback, fraud prevention, and legal purposes. Generated reports and related analysis may be retained so we can deliver, resend, support, audit, and improve the Service. Logs may be retained for security, debugging, and operational reliability. Marketing records may be retained until you unsubscribe or request deletion where applicable, and then as needed to maintain suppression records.

When personal information is no longer needed, we may delete, aggregate, anonymize, deidentify, or securely retain it where continued retention is permitted.

11. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and loss. These measures may include encrypted transport, access controls, payment processor tokenization, limited administrative access, secret management, provider security controls, monitoring, logging, and operational review.

No internet, email, payment, AI, database, hosting, or communications system can be guaranteed to be completely secure. You use the Service with the understanding that security risks cannot be eliminated entirely.

12. International Transfers

We are based in Canada, and our service providers may process and store personal information in Canada, the United States, and other jurisdictions. These jurisdictions may have privacy and government-access laws that differ from those where you live.

Where required, we rely on lawful transfer mechanisms, contractual safeguards, vendor commitments, and other appropriate measures for cross-border processing.

13. Canadian Privacy Rights

If Canadian privacy laws apply to you, you may have rights to request access to personal information we hold about you, request correction of inaccurate or incomplete information, withdraw consent where processing is based on consent, ask questions about our privacy practices, and challenge our compliance with applicable privacy obligations.

We may decline or limit requests where permitted or required by law, including to protect another person's privacy, preserve legal privilege, complete transactions, protect security, prevent fraud, comply with legal obligations, or retain required business records.

14. U.S. State Privacy Notices

If you reside in California or another U.S. state with a comprehensive privacy law, you may have rights to know or access personal information, request deletion, request correction, obtain a portable copy, opt out of certain sale, sharing, targeted advertising, or profiling activities, limit certain uses of sensitive information, and not be discriminated against for exercising privacy rights.

We do not sell personal information for money. We also do not knowingly sell or share personal information of individuals under 18. If we use advertising or analytics tools that are considered a "sale," "share," or targeted advertising under applicable law, you may request to opt out by contacting support@freedom.co.

We may need to verify your request before acting on it. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and verification of the individual concerned.

15. EEA, UK, and Swiss Privacy Rights

If you are located in the European Economic Area, United Kingdom, or Switzerland, you may have rights to request access, correction, deletion, portability, restriction, objection, withdrawal of consent where processing is based on consent, and information about international transfers. You may also have the right to lodge a complaint with your local data protection authority.

These rights are subject to legal limits and exceptions. Exercising a privacy right does not affect processing that occurred before a valid withdrawal of consent or processing that we are permitted or required to continue under law.

16. Exercising Privacy Rights

To make a privacy request, email support@freedom.co and include enough information for us to verify and process your request, such as the email address used for the Pathfinder purchase. We may ask for additional information to confirm your identity, clarify the request, prevent fraud, or protect security.

We will respond within the time required by applicable law. We may deny, limit, or charge a lawful fee for requests where permitted by law, including where requests are excessive, unfounded, impossible to verify, conflict with legal obligations, affect another person's rights, or require information we are legally permitted or required to retain.

17. Automated Processing and Profiling

The Service uses automated and AI-assisted processing to analyze quiz answers and generate report content. This processing is intended to provide educational recommendations and does not by itself produce legal, financial, employment, credit, housing, insurance, healthcare, or similarly significant decisions about you.

18. Children's Privacy

The Service is not intended for children under 18 or under the age of majority where they live. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact support@freedom.co so we can take appropriate action.

19. Third-Party Links and Platforms

The Service may link to third-party websites, payment forms, communities, course platforms, social platforms, support tools, or resources. Third-party services are governed by their own terms and privacy practices. This Privacy Policy does not apply to information processed by third parties as independent controllers.

20. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new "Last updated" date. If changes are material, we may provide additional notice or obtain consent where required by law. Your continued use of the Service after an updated policy is posted means you acknowledge the updated policy, except where additional consent is required.

21. Contact

Questions, complaints, or privacy requests may be sent to support@freedom.co or mailed to:

Vas Group Inc.
1 Rideau St, 7th Floor
Ottawa, ON K1N 8S7
Canada