Privacy Policy

January 15, 2026

This Privacy Policy governs the manner in which Flint Learning Solutions Inc. collects, uses, maintains and discloses information collected (“Personal Information”) from users (each, a "User") of the flintls.com website ("Site"). This privacy policy applies to the Site and all products and services offered by Flint Learning Solutions Inc. (collectively, the “Products”).

Collection of Personal Information

We may collect Personal Information from users in a variety of ways, including, but not limited to, when users visit our Site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site, including, without limitation, webinars and forums. Users may be asked for their email address, but also visit our Site anonymously. We will collect Personal Information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain site related activities, and if a User contacts us through the Site, we will keep a record of our correspondence.In addition, if a User contacts us directly, we may receive additional information about the User such as name, email address, phone number, the contents of the message and/or attachments the User may send us, and any other information the User may choose to provide. We may also receive a confirmation when a User opens an email from us.

Further, if a User elects to utilize any Products, we collect Personal Information, such as name and email address, to provide the Products. The types of information we may collect directly from Users include: names, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information (including Products purchased), as well as any other contact information a User chooses to provide or upload to our systems in connection with the Products (“Contact Information”).

Further, if a User has requested information or if a User has purchased Products from us in the past, or a User downloaded or accessed any demonstrations or training with respect to the Products, we may use this information to provide the User with news, offers for upgrades, discounts and other marketing information. If a User does not wish to receive such marketing communications from us, Users can opt-out or “unsubscribe” in the manner designated in the marketing communication or by contacting us at support@flintls.com.However, please note that even if a User opts-out or unsubscribes, we may still contact the User for informational, transactional, account-related, or similar purposes.

Information We Automatically Collect:

When using the Site:

When a User visits the Site, we collect certain information related to the User’s device, such as the device’s IP address, referring website, what pages the device visited, and the time that the device visited the Site.

When you use the Products:

Usage information – we may keep track of user activity in relation to the types of Products utilized, the configuration of their computers, and performance metrics related to their use of the Products.

Log information – we may log information about Users when they use the Products, including Internet Protocol (“IP”) address.

Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users’ computers, as more fully set forth below.

Web browser cookies

Our Site may use "cookies" to enhance the User’s experience. A cookie is a small piece of data (text file) that a website – when visited by User – asks the user’s browser to store on the device in order to remember information about the User. The User's web browser may place cookies on their device for record-keeping purposes and to track information such as login status, user preferences, and analyze how Users navigate the Site and Products. A User may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. If they choose to refuse certain cookies, some parts of the Site may not function properly.

How we use collected information

Flint Learning Solutions Inc. may collect and use Personal Information for the following purposes:

To improve customer service

Information you provide helps us respond to your customer service requests and support needs more efficiently.

To improve our Site and Products

We may use feedback you provide to improve our Site and Products.

To send periodic emails

Our use of your Personal Information includes direct marketing as requested or consented to by you, or to respond to inquiries, questions, and/or other requests from a User.

General

We will normally collect Personal Information from only (i) where we need the Personal Information to perform our obligations; (ii) where the processing is in our legitimate interests and not overridden by a User’s rights; or (iii) where we have a User’s consent to do so. We use the information we collect in various ways, including to:

Provide, operate, and maintain the Site and our Products;

Improve, personalize, and expand the Site and our Products;

Develop new products, services, features, and functionality;

To inform our marketing strategy, including to define customers for our Products

Keep our User information up to date;

Communicate with Users, either directly or through one of our partners, including for customer service, to provide Users with updates and other information relating to the Products; and

For other purposes as may be required in (a) the event of an emergency, (b) by applicable laws and regulations, (c) for the protection and safety of our employees and agents, our customers, or any other person or (d) requested by any judicial process or governmental agency.

How we protect your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information.

We regularly review our security and related policies to adapt the technology as new threats evolve, and in order to monitor Site. If you have any questions about our security practices, you can contact us at support@flintls.com.

Retention of Personal Information:

We will only retain Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances a User can ask us to delete Personal Information by sending a request to support@flintls.com. To protect a User’s privacy and security, we may take reasonable steps to verify the User’s identity before updating or removing Personal Information. Personal Information may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. A User’s ability to access and correct Personal Information may be temporarily limited where access and correction could: inhibit our ability to comply with a legal obligation; inhibit our ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to us or a third party.

Sharing your personal information

We do not sell, trade, or rent Personal Information to others. In some circumstances we may anonymize Personal Information (so that it can no longer be associated with a User) for research or statistical purposes in which case we may use this information indefinitely without further notice to a User. We may also share generic aggregated demographic information not linked to any Personal Information regarding Users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

As a result, Personal Information could be transferred out of the European Economic Area (the “EEA”), Switzerland or the United Kingdom (“UK”).Whenever we transfer Personal Information out of a User’s jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

when the countries receiving Personal Information have been deemed to provide an adequate level of protection for Personal Information by the European Commission; or

through the use of the standard contractual clauses adopted by the European Commission and/or the UK Information Commissioner’s Office (collectively, the “Standard Contractual Clauses”), as may be amended from time to time.

Business Transfers:

We may choose to buy or sell assets, and may share and/or transfer Personal Information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Your Rights under the General Data Protection Regulation (“GDPR”)

Under certain circumstances, Users have rights under data protection laws in relation to their Personal Information, as set forth below. If a User wishes to exercise any of rights, please contact us at support@flintls.com.We respond to all requests we receive from Users wishing to exercise their data protection rights in accordance with applicable data protection laws. Users have the right to:

access, correct, update, or request deletion of Personal Information (note, however, that we may not always be able to comply with a User’s request of erasure for specific legal reasons which will be notified to the User, if applicable, at the time of the User’s request).

object to the processing of Personal Information. A User may ask us to restrict the processing of Personal Information, or request portability of the Users’s Personal Information (however, in some cases, we may demonstrate that we have compelling legitimate grounds to process Personal Information which overrides such requests).

request restriction of processing of Personal Information. This enables a User to ask us to suspend the processing of Personal Information in the specific circumstances.

request the transfer of Personal Information to the User or to a third party. We will provide to the User, or a third party the User has chosen, Personal Information in a structured, commonly used, machine-readable format.

opt-out of marketing communications we send at any time. Users can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.

withdraw consent at any time for any Personal Information we have collected and processed with consent. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to withdrawal, nor will it affect the processing of Personal Information conducted in reliance on lawful processing grounds other than consent.

complain to a data protection authority about our collection and use of Personal Information. Contact details for data protection authorities in the EEA, the UK, Switzerland and certain non-European countries (including the US and Canada) are available here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

No Fee Usually Required.Users will not have to pay a fee to access Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.

What We May Need From aUser. We may need to request specific information from a User to help us confirm identity and ensure the User’s right to access Personal Information (or to exercise any of other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact a User to ask for further information in relation to a request to speed up our response.

California’s “Shine the Light” law.

California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing purposes; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (e.g., requests submitted in 2022 would be applicable to relevant disclosures (if any) in 2021). If a User is a California resident and would like to make such a request, please submit the request in writing by emailing us at support@flintls.com using the subject line “Request for California STL Information.” In any request, the User will need to attest to the fact that they are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address from which the request was submitted. Please note that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.

The California Consumer Privacy Act

This section describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information.For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA or information we collect from a User in the course of providing Products to a User.In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Personal Information We Collect. We collect identifiers (such as name, address, email, phone number, job title, and transactional information), commercial information (such as a record of the Products purchased or demos requested), and Internet or other electronic network activity information (such as usage information, IP address, cookie information, and customer feedback).

Why We Collect Personal Information. We use identifiers to provide the Products requested, such as to fulfill a request for a demo, provide access to a webinar, or provide a User with information about our Products. We use identifiers and commercial information for general website administration, which includes record keeping, troubleshooting, data analysis, testing, and survey purposes. We use identifiers, commercial information, and Internet or other electronic network activity for trend monitoring, marketing, and advertising, as well as to ensure website security.

How We Collect Personal Information. We collect identifiers and commercial information directly from Users. We collect Internet or other electronic network activity from a User’s use of the Site and Products.

With Whom We Share Personal Information. We share personal information as necessary for certain “business purposes,” as defined by the CCPA (Cal. Civ. Code 1798.140(d)). This includes sharing identifiers, commercial information, and internet or other electronic network activity with providers of payment processing, customer relationship management, consulting, email, product feedback, and helpdesk services.

  • Right to Opt-out of the “sale” of Personal Information.Like many companies, we may use services that help deliver marketing to Users.Our use of some of these services may be classified under California law as a “sale” of Personal Information to the companies that provide the services because they collect information from Users (e.g., device data and online activity data) to help them serve ads.You can request to opt-out out of this “sale” of your personal information here support@flintls.com.

We reserve the right to confirm a User’s California residency to process requests and will need to confirm a Users’s identity to process requests to exercise these rights.Government identification may be required.You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Right to Request Disclosure. Users have the right to request disclosure about what categories of Personal Information we have disclosed for a business purpose about a User and the categories of third parties to whom the Personal Information was disclosed. Additionally, Users have the right to request disclosure of specific pieces of information. Below is a full list of the information that Users can include in your request.

The categories of Personal Informationthat we have collected

The categories of sources from which we collected the Personal Information

The categories of third parties with whom we share Personal Information

The specific pieces of Personal Information we have collected about a User

The categories of Personal Information that we disclosed about a User for a business purpose

Right to Request Deletion. Users have the right to request that we delete any Personal Information about that we have collected. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation. If a User would like to exercise their right to delete, please contact us support@flintls.com. Our privacy team will examine any request and respond as quickly as possible.

The Right to Non-Discrimination. We will not discriminate against any User (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded under law.

Contact Information. In compliance with the CCPA, we commit to resolve complaints about privacy and our collection or use of Personal Information. California residents with inquiries or complaints regarding this Privacy Notice should first contact us: support@flintls.com

California and Delaware “Do Not Track” Disclosures

California and Delaware law require us to indicate whether we honor “Do Not Track” settings in a User’s browser concerning targeted advertising. We adhere to the standards set out in this Privacy Notice and do not monitor or respond to Do Not Track browser requests.

Children

We do not knowingly collect or solicit personal information from anyone under the age of 13. Anyone under the age of 13 should not send any Personal Information about to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If a User believes that a child under 13 may have provided us Personal Information, please contact us a support@flintls.com.

Linked Websites

For our Users’ convenience, hyperlinks may be posted on the Site that link to other websites (the “Linked Sites”). We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control. Linked Sites may collect information in addition to that which we collect on the Site. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage Users to seek out and read the privacy notice of each Linked Site that a User visits to understand how the information is collected, used and protected by such third party.

Changes to this privacy policy

Flint Learning Solutions Inc. has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

For questions about this Privacy Policy, contact:

Legal Department
Flint Learning Solutions
1655 Dupont St
Suite 300
Toronto, ON, M6P 3T1
info@flintls.com