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Privacy Policy
Privacy Policy
1. Introduction
Free Agent Technologies Inc. ("Free Agent," "we," "our," or "us") is a corporation headquartered in Calgary, Alberta, Canada. We operate a platform that connects collegiate, professional, and Olympic-level athletes with brands, employers, and other opportunities through our website at gofreeagent.com, our iOS mobile application available on the Apple App Store, and related services (collectively, the "Platform").
This Privacy Policy (the "Policy") explains how we collect, use, disclose, retain, and safeguard your personal information when you access or use the Platform, and the rights you have under applicable privacy laws, including:
the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA");
the Personal Information Protection Act (Alberta) ("PIPA");
Quebec's Act respecting the protection of personal information in the private sector ("Law 25");
the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and other comparable U.S. state privacy laws (e.g., Virginia, Colorado, Connecticut, Utah, Texas); and
other applicable privacy and data-protection laws.
By creating an account or otherwise using the Platform, you acknowledge that you have read, understood, and agree to the data practices described in this Policy. If you do not agree, please do not access or use the Platform. For questions or to exercise your rights, contact our Privacy Office at help@gofreeagent.com.
2. Scope, Eligibility, and Children's Privacy
The Platform is intended for adults aged eighteen (18) years or older who have competed in sport for at least one (1) year at the collegiate, professional, or Olympic level. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will promptly delete the information and terminate the account. If you believe a minor has provided us with personal information, please contact help@gofreeagent.com.
3. Information We Collect
We collect personal information directly from you, automatically through your use of the Platform, and from third parties, as described below.
3.1 Information You Provide to Us
Account & Registration Data: full name, email address, phone number, date of birth, password (stored hashed and salted), and country/region.
Profile Data: sport, league, team, eligibility years, biographical and educational background, work history, languages, photos, videos, and any other content you choose to share.
Verification Data: a photocopy or digital image of a government-issued identification document (e.g., driver's licence or passport) that you upload through the Platform (including through our iOS mobile application) to verify your identity and athletic eligibility. The image is used solely as a visual confirmation that the name and date of birth you provided at registration match your government-issued identity. We do not programmatically extract or store data from the ID image. Verification is performed visually, and only the information already provided at registration (such as name and date of birth) is retained. Upon successful verification, the image is permanently and immediately deleted. For athletes who do not complete verification within ten (10) business days, all verification data including any ID image is permanently deleted and the athlete will be required to re-submit their information to complete verification. See Section 3.5 for full details on how government-issued ID images are handled.
Financial & Transaction Data: payment card details, billing address, and tax information for paid services or athlete compensation. Payment card numbers are processed and stored by our PCI-DSS-compliant payment processors (e.g., Stripe); Free Agent does not store full card numbers on its servers.
Communications & User Content: messages, posts, comments, support tickets, survey responses, and other content you create on or send through the Platform.
Sensitive Personal Information: where you voluntarily provide sensitive information (such as health, injury, biometric data, racial or ethnic origin, sexual orientation, religious beliefs, or trade-union membership), we will only process it with your explicit, opt-in consent and for the specific purpose disclosed at the point of collection. We do not collect government identifier numbers (e.g., SIN, SSN) except as required for tax reporting on athlete compensation
3.2 Information Collected Automatically
Device & Technical Data: IP address, device identifiers, browser type and version, operating system, time zone, mobile network, and crash logs.
Usage Data: pages and screens viewed, links clicked, search queries, time spent, referral and exit URLs, feature interactions, and engagement metrics.
Location Data: approximate location derived from IP address. Precise GPS location is collected only with your explicit device-level permission.
Cookies and Similar Technologies: see Section 7 (Cookies, Tracking, and Online Advertising).
3.3 Information from Third Parties
Identity Providers / Single Sign-On: where you log in via LinkedIn, Apple, Google, or another third-party provider, we receive the profile data those providers share consistent with the permissions you grant.
Sport Data Providers: statistics, rankings, and competitive history from leagues, conferences, governing bodies, and licensed data providers.
Corporate Partners and Recruiters: information shared by employers, agents, brands, scouts, or sponsorship partners in connection with hiring, evaluation, sponsorship, or Name, Image, and Likeness ("NIL") opportunities.
Publicly Available Sources: information you have published publicly on social networks, news articles, athletic-association websites, and similar public sources.
Service Providers: analytics, fraud-prevention, payment processing, identity verification, customer-support tools, security and observability providers, cloud hosting and storage, and other vendors that perform services on our behalf under written contracts.
3.4 Sensitive and Special-Category Data
We do not process special categories of personal data except where you voluntarily provide it and have given explicit, opt-in consent for a specific, disclosed purpose. You may withdraw that consent at any time without affecting the lawfulness of processing already conducted.
3.5 Government-Issued ID Documents — Collection, Use, and Apple App Store Compliance
As part of athlete eligibility verification, we ask you to upload a photocopy or digital image of your government-issued identification document (e.g., driver's licence or passport). This is used solely as a visual confirmation that the name and date of birth you have already provided during account registration match your government-issued identity. We do not extract, record, or retain any information from the ID image itself — including document numbers, ID numbers, or any other data appearing on the document. Upon successful verification, the image is permanently and immediately deleted. We collect and process government-issued ID information in accordance with data minimization principles, limiting collection strictly to what is necessary for identity verification.
Verification is primarily designed to be completed through our website at gofreeagent.com. Athletes are encouraged to complete the verification process via web browser, where the upload experience is fully supported. For convenience, athletes who prefer to verify on mobile may also upload their identification document directly through our iOS application — but this is an alternative path, not a requirement. You will never be required to use the iOS app to complete verification; the web flow is always available and fully equivalent.
When is ID verification required? Government-issued ID verification is required only for athletes who wish to obtain verified athlete status and participate in opportunities involving compensation, contracts, or brand partnerships where identity verification is necessary to prevent fraud and impersonation. Identity verification is necessary to prevent impersonation, fraud, and misuse of athlete identities in commercial and contractual opportunities, and we limit verification to what is required for this purpose. Providing a government-issued ID is otherwise optional. Athletes who choose not to complete verification may still use the Platform but will not have access to verified athlete features.
Consent. Before proceeding with identity verification, athletes are required to confirm that they have read and agreed to our Privacy Policy and Terms of Service. We intend to introduce a dedicated, purpose-specific disclosure screen at the point of ID upload in a future update — this screen will explain in plain language why the document is required, how it is used, and when it is deleted, and will require explicit acknowledgment before upload proceeds.
What we collect. A static image (photo or scan) of the front of your government-issued ID or passport biographical data page, used solely for visual identity matching. We do not request or retain the back of your ID unless required by applicable law. We do not extract, store, or retain any data from the image itself — including document numbers or ID numbers. The only information retained following verification is the name and date of birth you provided at registration, and a verification status flag on your account.
What we do not collect or retain. We do not store ID numbers, document numbers, or full images after verification is complete. We do not use ID images for marketing, profiling, analytics, product development, AI model training, or any purpose other than visual identity matching.
How it is collected. Whether you verify via web browser or iOS app, your ID image is transmitted and stored using industry-standard encryption. When using the iOS app, the image is uploaded through an in-app document picker or camera interface. The image is not cached, stored in your device's photo library, or retained in any application cache or device storage beyond the upload process. No local processing occurs that generates biometric templates or facial geometry data.
No biometric or automated processing. Free Agent does not perform facial recognition, automated biometric matching, selfie-to-ID comparison, liveness detection, or any similar automated processing of your ID image — whether submitted via web or iOS app. All review is conducted manually by a small number of trained Free Agent personnel subject to strict confidentiality obligations and access controls. Personnel reviewing ID documents are prohibited from copying, downloading, or using the information for any purpose other than verification. No biometric template of your face or other physical characteristics is created, stored, or shared.
Who has access. Access to uploaded ID images is restricted to a limited number of trained personnel for verification purposes only. Access is logged and audited. We do not share ID images with brands, employers, recruiters, or other Platform users under any circumstances.
Storage and encryption. ID images are transmitted and stored using industry-standard encryption in access-controlled storage infrastructure hosted by our cloud provider(s) subject to written data-processing agreements.
Retention. ID images are permanently deleted immediately upon successful verification. No image data, document data, or ID numbers are retained after this point — only the name and date of birth provided at registration and a verification status flag. ID images uploaded by athletes who do not complete verification within ten (10) business days are permanently deleted, and the athlete must re-submit their information to restart the process. We do not retain government-issued ID images beyond these periods under any circumstances. See Section 9 for full data retention schedules.
Verification alternatives. Where feasible, we may offer alternative verification methods that do not require government-issued ID. We will update this Policy if and when such alternatives become available.
Apple App Store compliance. Our iOS application's collection and handling of government-issued ID images is disclosed in our Apple App Store Privacy Nutrition Label as required by Apple's App Privacy Details requirements. The data type is classified as "Sensitive Info" under Apple's data category framework, linked to your identity, and used solely for App Functionality (identity and eligibility verification). This data is not used for tracking, advertising, or any third-party purpose. In-app ID upload is an optional convenience feature; athletes may always complete verification through our website at gofreeagent.com instead. If you have questions about how to review our App Store privacy label, visit our listing on the Apple App Store or contact help@gofreeagent.com.
Your choices. You may complete verification via our website at gofreeagent.com rather than through the iOS app at any time. You may also choose not to upload a government-issued ID at all, but doing so means you will not be able to obtain verified athlete status or access features requiring verification. You may request deletion of your ID image at any time by contacting help@gofreeagent.com.; we will action your request within 72 hours, subject to any applicable legal-hold obligations.
4. How We Use Your Information
We use personal information to:
create, secure, and operate your account, including verifying eligibility;
deliver the core Platform — matching, messaging, networking, recommendations, and content;
process payments, payouts, and financial transactions;
communicate with you about service updates, security alerts, support inquiries, and policy changes;
personalize content, recommendations, and the user experience;
conduct research, analytics, A/B testing, and product development;
detect, investigate, and prevent fraud, impersonation, abuse, security incidents, and policy violations;
enforce our Terms of Service and other contractual obligations;
comply with legal, tax, and regulatory obligations;
send marketing communications where permitted by law (you may opt out at any time); and
for any other purpose disclosed at the time of collection and to which you have consented.
We will not use your personal information for materially new purposes without first updating this Policy and, where required by law, obtaining your renewed consent.
5. Automated Decision-Making, Profiling, and Artificial Intelligence
5.1 Profiling for Recommendations
We use algorithms to suggest connections, opportunities, and content. These recommendations do not produce legal or similarly significant effects on you.
5.2 Use of Artificial Intelligence
Free Agent uses, and may in the future expand its use of, artificial-intelligence and machine-learning systems ("AI Systems") to: (i) detect fraud, abuse, and harmful content; (ii) generate insights, summaries, and recommendations; (iii) translate and transcribe content; and (iv) improve search and matching.
5.3 AI Model Training
Free Agent may use de-identified or aggregated information derived from the Platform to train, test, and evaluate proprietary AI Systems. We will not use the contents of your private messages, government-issued ID images, or other sensitive personal data to train AI Systems without your prior, explicit, opt-in consent.
5.4 Public Data and Web-Sourced Information
Free Agent does not currently scrape, harvest, or otherwise systematically collect publicly available information from third-party websites, forums, or social media to enrich athlete profiles. We may begin doing so in the future. If we do, we will update this Policy and provide users with notice before commencing such collection. Any future collection will be limited to data that is publicly available and lawful to collect, will respect technical access controls, will comply with the terms of source websites, and will honour valid requests to exclude information from our systems sent to help@gofreeagent.com.
5.5 No Solely-Automated Decisions With Legal Effect
We do not make decisions that produce legal or similarly significant effects about you (such as final hiring or contracting decisions) based solely on automated processing without meaningful human review.
5.6 Bias, Fairness, and Auditing
We test our AI Systems for accuracy and fairness, document their data sources and intended uses, conduct periodic reviews to identify and mitigate bias, and maintain records of significant model changes.
5.7 Identity Verification (Manual; No Biometric Processing)
Free Agent does not use biometric processing, facial recognition, voiceprint analysis, liveness detection, or automated decision-making to verify your identity or eligibility. Identity and eligibility verification are performed manually by trained Free Agent personnel who visually confirm that the name and date of birth you provided at registration match your government-issued ID, and confirm your competitive history through review of public sources. No automated systems make decisions about your eligibility, and no biometric templates of your face, voice, or other unique physical characteristics are created, stored, or shared. Manual reviewers are subject to confidentiality obligations and access controls, are prohibited from copying or downloading ID images, and all access to verification documents is logged. See Section 3.5 for full details on government-issued ID handling.
6. How We Share and Disclose Information
6.1 With Other Users
Your profile (name, photo, sport, statistics, biography, and content you have made public) is visible to other Platform users by default. You can adjust visibility in your account settings. Direct messages are visible to their recipients.
6.2 With Service Providers
We do not share government-issued ID images with third-party identity verification providers. Categories of service providers include cloud hosting and storage, payment processing, analytics and crash reporting, email/SMS/push-notification delivery, identity verification and anti-fraud providers, customer-support tools, security and observability providers, and professional advisors (auditors, lawyers, and accountants). We maintain an up-to-date list of key sub-processors; you may request a copy by contacting help@gofreeagent.com.
6.3 With Corporate Partners and Recruiters
With your consent or at your direction (e.g., when you apply for an opportunity), we share relevant profile information with employers, agents, brands, scouts, and sponsorship partners. We do not share government-issued ID images with any corporate partner, recruiter, or other Platform user under any circumstances.
6.4 Aggregated and De-Identified Data
We may share aggregated, de-identified, or anonymized data — from which you cannot reasonably be re-identified — with corporate partners, advertisers, and research institutions for industry insights, recruiting analytics, advertising effectiveness, and academic research.
6.5 We Do Not Sell or Share Personal Information for Cross-Context Advertising
Free Agent does not "sell" personal information for monetary or other valuable consideration, and does not "share" personal information for cross-context behavioural advertising, as those terms are defined under the CCPA/CPRA and comparable U.S. state privacy laws. We have reviewed our current data flows — including any third-party advertising pixels, analytics platforms, and partner integrations — to confirm this representation. If our practices change, we will update this Policy, provide users with notice as required by law, and make available a "Do Not Sell or Share My Personal Information" link in account settings and at gofreeagent.com/privacy. We honour Global Privacy Control ("GPC") signals where applicable.
6.6 Legal Process and Safety
We may disclose information when we have a good-faith belief that disclosure is required by applicable law, court order, lawful subpoena, or governmental request, or to: (i) protect our rights, property, or safety, or that of our users or the public; (ii) detect, prevent, or address fraud, security, or technical issues; (iii) enforce our Terms of Service; or (iv) cooperate with law-enforcement investigations.
6.7 Corporate Transactions
If Free Agent is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, your personal information may be transferred as part of the transaction. We will notify you of any such transfer, and any successor entity will be bound by this Policy until materially amended.
6.8 With Your Consent
We share information for any other purpose disclosed at the time of collection and to which you have consented.
7. Cookies, Tracking, and Online Advertising
We use cookies, pixels, software development kits, and similar technologies (collectively, "Cookies") to operate the Platform, remember your preferences, analyze usage, and deliver advertising. We classify Cookies as Strictly Necessary, Functional, Analytics/Performance, and Advertising/Targeting.
You can manage Cookies through (a) our cookie-consent banner shown on first visit, (b) the "Cookie Preferences" link in the website footer, (c) your browser settings, and (d) where applicable, industry opt-out tools such as the Network Advertising Initiative (networkadvertising.org/choices) and the Digital Advertising Alliance (aboutads.info/choices). We honour Global Privacy Control (GPC) signals where required by law. For full details, see our Cookie Policy at gofreeagent.com/cookies.
8. Your Privacy Rights
Depending on your jurisdiction, you have some or all of the following rights:
Access / Know: request a copy of the personal information we hold about you and details of how we use it.
Correction / Rectification: correct inaccurate or incomplete data.
Deletion / Erasure: request deletion of your personal data, subject to legal exceptions.
Portability: receive a machine-readable copy of certain data and transmit it to another controller.
Restriction: limit how we process your data while a request is pending.
Objection: object to processing based on legitimate interests, including direct marketing and profiling.
Withdraw Consent: at any time, where processing is based on consent (without affecting the lawfulness of prior processing). You may withdraw consent to the collection of your government-issued ID image by contacting help@gofreeagent.com; doing so will result in your account remaining unverified.
Opt-Out of Sale, Sharing, or Targeted Advertising: under CCPA/CPRA and other applicable U.S. state laws.
Non-Discrimination: we will not deny services, charge different prices, or reduce service quality because you exercised your privacy rights.
Lodge a Complaint: with a supervisory authority — e.g., the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca), the Commission d'accès à l'information du Québec, or the California Privacy Protection Agency (cppa.ca.gov).
To exercise any right, email help@gofreeagent.com. or use the controls in your account settings. We will respond within the timeframes required by law (generally 30 days under PIPEDA; 45 days under CCPA/CPRA, with one permitted extension). We will verify your identity before fulfilling requests. You may designate an authorized agent to act on your behalf where permitted by law.
California "Shine the Light" Notice. California residents may request, once per calendar year, a list of personal information disclosed to third parties for those parties' direct-marketing purposes. Free Agent does not currently make such disclosures.
Nevada Residents. Nevada residents may opt out of the future sale of certain personal information by emailing help@gofreeagent.com.
9. Data Retention
We retain personal information only as long as necessary for the purposes set out in this Policy or as required by law. Specific retention periods include:
Unverified Signup Data (including government-issued ID or passport images): retained for a maximum of ten (10) business days while verification is in progress. If verification is not completed within ten (10) business days of submission, all such signup data is permanently deleted and the athlete must re-submit to complete verification.
Verification Documents — Government-Issued ID Images (Verified Accounts): permanently deleted immediately upon successful verification. No image data, document numbers, or ID numbers are retained after this point under any circumstances. The only information retained is the name and date of birth provided at registration and a verification status flag on the account.
Account Data (Verified Accounts): for the life of the account, plus up to twenty-four (24) months after account closure for fraud prevention, dispute resolution, and legal-defence purposes.
Transaction & Tax Records: up to seven (7) years after the transaction to comply with Canadian tax and accounting requirements.
Marketing Data: until you unsubscribe or withdraw consent, plus up to twelve (12) months for suppression-list purposes.
Server Logs and Security Data: up to thirteen (13) months.
Support Communications: up to thirty-six (36) months.
Legal-Hold Data: as long as required to comply with legal obligations, regulatory inquiries, or pending matters.
Aggregated or De-Identified Data: may be retained indefinitely for analytics, research, and product development.
When applicable retention periods expire, we delete, destroy, or de-identify the data in accordance with our internal data-retention schedule.
10. Security
We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. Measures include:
industry-standard encryption of all data in transit and at rest;
role-based access controls and least-privilege principles;
multi-factor authentication for administrative and privileged accounts;
strict access controls and audit logging for all systems that store or process government-issued ID images;
regular vulnerability scanning, penetration testing, and secure-code review;
vendor risk-management and ongoing security-assessment programs;
mandatory privacy and security training for all personnel, with enhanced training for staff with access to verification documents; and
incident-response and breach-notification procedures aligned with PIPEDA, BC PIPA, CCPA/CPRA, and applicable U.S. state breach-notification laws.
In the event of a personal-data breach likely to result in a real risk of significant harm or to the rights and freedoms of individuals, we will notify the appropriate supervisory authorities and affected individuals as required by law (e.g., "as soon as feasible" under PIPEDA's Breach of Security Safeguards Regulations).
Consistent with the Breach of Security Safeguards Regulations under PIPEDA, Free Agent maintains internal records of every breach of security safeguards involving personal information for not less than twenty-four (24) months from the date Free Agent determined the breach occurred, regardless of whether the breach was reportable to the Privacy Commissioner of Canada or notifiable to affected individuals. These records are made available to the Privacy Commissioner upon request.
11. International Data Transfers
Free Agent is headquartered in Calgary, Alberta, Canada, and may use service providers in Canada, the United States, and other jurisdictions. When we transfer personal data across borders, we rely on one or more lawful transfer mechanisms, including appropriate safeguards permitted under applicable North American privacy laws.
Government-issued ID images are subject to the same cross-border transfer safeguards as all other personal information. We do not transfer ID images to other jurisdictions without implementing appropriate contractual safeguards.
You may request a copy of the relevant transfer safeguards by contacting help@gofreeagent.com.
Where personal information of Quebec residents is communicated outside Quebec, Free Agent will conduct a Privacy Impact Assessment consistent with section 17 of Quebec's Law 25 prior to the transfer, taking into account the sensitivity of the information, the purposes for which it will be used, the protection measures in place at the destination, and the legal regime applicable in the destination jurisdiction. Where the assessment indicates the information would not receive adequate protection, the transfer will not occur unless additional contractual safeguards are put in place.
12. Mobile Application — Apple App Store
Free Agent's iOS mobile application is distributed through the Apple App Store. The following disclosures are specific to the mobile application.
12.1 Apple App Store Privacy Nutrition Label
In accordance with Apple's App Privacy Details requirements, we disclose all data types collected by the Free Agent iOS application in our App Store Privacy Nutrition Label. The label is visible on the Free Agent listing page in the Apple App Store before you download the application. Data types disclosed include, but are not limited to: contact information, identifiers, usage data, and sensitive information (including government-issued ID images collected during the optional in-app verification flow). You are encouraged to review the Privacy Nutrition Label before downloading and using the application.
12.2 Data Linked to You
The following data types collected by our iOS application are linked to your identity: your name, email address, phone number, date of birth, athlete profile information, government-issued ID image (during the optional in-app verification flow only, deleted immediately upon successful verification), and usage data associated with your account. These are disclosed as "Data Linked to You" in our App Store Privacy Nutrition Label.
12.3 No Tracking
We do not use data collected through the Free Agent iOS application to track you across third-party apps and websites for advertising purposes. We do not share identifiers or behavioral data with advertising networks or data brokers for cross-app or cross-website tracking.
12.4 App Permissions
The Free Agent iOS application may request the following device permissions. Each permission is requested at the time it is needed, and you may decline or revoke permissions through your device settings:
Camera: to allow you to photograph your government-issued ID or other verification documents directly within the app. Required only for the optional in-app verification flow; not used for any other purpose.
Photo Library: to allow you to select an existing photo of your ID or other document from your device. Required only for the optional in-app verification flow; not used for any other purpose.
Notifications: to send you account alerts, job application updates, and other Platform notifications. Optional; you may decline or disable at any time.
Location (optional): precise location is not requested by default. If you grant location permission, it is used only for location-relevant features you have enabled. You may revoke this permission at any time through your device settings.
The application does not access your contacts, microphone, health data, or any other device data beyond the permissions listed above. Permissions are requested only when necessary and are not used for purposes beyond those disclosed at the time of the request.
12.5 Apple's Privacy Practices
When you use Sign in with Apple or other Apple platform features, Apple's own privacy practices govern the data Apple collects. We encourage you to review Apple's Privacy Policy at apple.com/privacy. Free Agent is not responsible for Apple's data practices.
13. Third-Party Links and Services
The Platform may contain links to third-party websites, applications, and services that we do not own or control. This Policy does not apply to those third parties. We encourage you to review the privacy notices of any third party before providing personal information.
14. Changes to This Policy
We may update this Policy from time to time. The "Last Updated" date at the top of this Policy reflects the most recent revision. Where changes are material, we will provide reasonable advance notice through email and/or in-app notification before they take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy. Where required by law, we will obtain renewed consent.
15. Dispute Resolution and Governing Law
This Policy is governed by the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without regard to conflict-of-laws principles.
15.1 Informal Resolution
Before filing a formal complaint, please contact our Privacy Office at help@gofreeagent.com. We will work in good faith to resolve your concern within thirty (30) days.
15.2 Regulatory Complaint
You may file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca) at any time. Quebec residents may also contact the Commission d'accès à l'information.
15.3 Other Disputes; Reference to Terms of Service
To the extent any dispute arising out of or relating to your use of the Platform is subject to mandatory arbitration, individual-action requirements, or other contractual dispute-resolution mechanisms, those provisions are set out in the Free Agent Terms of Service, which are incorporated into your relationship with Free Agent by reference. This Privacy Policy is a notice of our information-handling practices and is not, by itself, intended to create a binding agreement to arbitrate or to waive any class-action, representative-action, or other procedural right. Any such provisions, where applicable, are governed exclusively by the Terms of Service. Nothing in this Policy or the Terms of Service limits your right to seek injunctive relief in a court of competent jurisdiction or to pursue rights granted by mandatory consumer-protection or privacy laws.
16. Accountability and Privacy Office
Free Agent has appointed a Privacy Officer to oversee compliance with PIPEDA, BC PIPA, Quebec Law 25, and other applicable privacy laws. You can reach the Privacy Office at:
Email: help@gofreeagent.com.
Mail: Free Agent Inc., Attn: Privacy Officer, Centennial Place, East Tower, 520 3rd Avenue SW, Calgary, AB, Canada T2P 0R3
Designated Individual (PIPEDA Principle 1 / Quebec Law 25 s. 3.1): Kirsten Toth, CEO, Free Agent Technologies Inc. The designated individual is the person ultimately accountable for Free Agent's compliance with privacy law and is reachable through the Privacy Office contact details above.
If you are not satisfied with our response to a privacy concern, you have the right to escalate to the relevant supervisory authority listed in Section 8.
© 2026 Free Agent Technologies Inc. All rights reserved.
1. Introduction
Free Agent Technologies Inc. ("Free Agent," "we," "our," or "us") is a corporation headquartered in Calgary, Alberta, Canada. We operate a platform that connects collegiate, professional, and Olympic-level athletes with brands, employers, and other opportunities through our website at gofreeagent.com, our iOS mobile application available on the Apple App Store, and related services (collectively, the "Platform").
This Privacy Policy (the "Policy") explains how we collect, use, disclose, retain, and safeguard your personal information when you access or use the Platform, and the rights you have under applicable privacy laws, including:
the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA");
the Personal Information Protection Act (Alberta) ("PIPA");
Quebec's Act respecting the protection of personal information in the private sector ("Law 25");
the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and other comparable U.S. state privacy laws (e.g., Virginia, Colorado, Connecticut, Utah, Texas); and
other applicable privacy and data-protection laws.
By creating an account or otherwise using the Platform, you acknowledge that you have read, understood, and agree to the data practices described in this Policy. If you do not agree, please do not access or use the Platform. For questions or to exercise your rights, contact our Privacy Office at help@gofreeagent.com.
2. Scope, Eligibility, and Children's Privacy
The Platform is intended for adults aged eighteen (18) years or older who have competed in sport for at least one (1) year at the collegiate, professional, or Olympic level. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will promptly delete the information and terminate the account. If you believe a minor has provided us with personal information, please contact help@gofreeagent.com.
3. Information We Collect
We collect personal information directly from you, automatically through your use of the Platform, and from third parties, as described below.
3.1 Information You Provide to Us
Account & Registration Data: full name, email address, phone number, date of birth, password (stored hashed and salted), and country/region.
Profile Data: sport, league, team, eligibility years, biographical and educational background, work history, languages, photos, videos, and any other content you choose to share.
Verification Data: a photocopy or digital image of a government-issued identification document (e.g., driver's licence or passport) that you upload through the Platform (including through our iOS mobile application) to verify your identity and athletic eligibility. The image is used solely as a visual confirmation that the name and date of birth you provided at registration match your government-issued identity. We do not programmatically extract or store data from the ID image. Verification is performed visually, and only the information already provided at registration (such as name and date of birth) is retained. Upon successful verification, the image is permanently and immediately deleted. For athletes who do not complete verification within ten (10) business days, all verification data including any ID image is permanently deleted and the athlete will be required to re-submit their information to complete verification. See Section 3.5 for full details on how government-issued ID images are handled.
Financial & Transaction Data: payment card details, billing address, and tax information for paid services or athlete compensation. Payment card numbers are processed and stored by our PCI-DSS-compliant payment processors (e.g., Stripe); Free Agent does not store full card numbers on its servers.
Communications & User Content: messages, posts, comments, support tickets, survey responses, and other content you create on or send through the Platform.
Sensitive Personal Information: where you voluntarily provide sensitive information (such as health, injury, biometric data, racial or ethnic origin, sexual orientation, religious beliefs, or trade-union membership), we will only process it with your explicit, opt-in consent and for the specific purpose disclosed at the point of collection. We do not collect government identifier numbers (e.g., SIN, SSN) except as required for tax reporting on athlete compensation
3.2 Information Collected Automatically
Device & Technical Data: IP address, device identifiers, browser type and version, operating system, time zone, mobile network, and crash logs.
Usage Data: pages and screens viewed, links clicked, search queries, time spent, referral and exit URLs, feature interactions, and engagement metrics.
Location Data: approximate location derived from IP address. Precise GPS location is collected only with your explicit device-level permission.
Cookies and Similar Technologies: see Section 7 (Cookies, Tracking, and Online Advertising).
3.3 Information from Third Parties
Identity Providers / Single Sign-On: where you log in via LinkedIn, Apple, Google, or another third-party provider, we receive the profile data those providers share consistent with the permissions you grant.
Sport Data Providers: statistics, rankings, and competitive history from leagues, conferences, governing bodies, and licensed data providers.
Corporate Partners and Recruiters: information shared by employers, agents, brands, scouts, or sponsorship partners in connection with hiring, evaluation, sponsorship, or Name, Image, and Likeness ("NIL") opportunities.
Publicly Available Sources: information you have published publicly on social networks, news articles, athletic-association websites, and similar public sources.
Service Providers: analytics, fraud-prevention, payment processing, identity verification, customer-support tools, security and observability providers, cloud hosting and storage, and other vendors that perform services on our behalf under written contracts.
3.4 Sensitive and Special-Category Data
We do not process special categories of personal data except where you voluntarily provide it and have given explicit, opt-in consent for a specific, disclosed purpose. You may withdraw that consent at any time without affecting the lawfulness of processing already conducted.
3.5 Government-Issued ID Documents — Collection, Use, and Apple App Store Compliance
As part of athlete eligibility verification, we ask you to upload a photocopy or digital image of your government-issued identification document (e.g., driver's licence or passport). This is used solely as a visual confirmation that the name and date of birth you have already provided during account registration match your government-issued identity. We do not extract, record, or retain any information from the ID image itself — including document numbers, ID numbers, or any other data appearing on the document. Upon successful verification, the image is permanently and immediately deleted. We collect and process government-issued ID information in accordance with data minimization principles, limiting collection strictly to what is necessary for identity verification.
Verification is primarily designed to be completed through our website at gofreeagent.com. Athletes are encouraged to complete the verification process via web browser, where the upload experience is fully supported. For convenience, athletes who prefer to verify on mobile may also upload their identification document directly through our iOS application — but this is an alternative path, not a requirement. You will never be required to use the iOS app to complete verification; the web flow is always available and fully equivalent.
When is ID verification required? Government-issued ID verification is required only for athletes who wish to obtain verified athlete status and participate in opportunities involving compensation, contracts, or brand partnerships where identity verification is necessary to prevent fraud and impersonation. Identity verification is necessary to prevent impersonation, fraud, and misuse of athlete identities in commercial and contractual opportunities, and we limit verification to what is required for this purpose. Providing a government-issued ID is otherwise optional. Athletes who choose not to complete verification may still use the Platform but will not have access to verified athlete features.
Consent. Before proceeding with identity verification, athletes are required to confirm that they have read and agreed to our Privacy Policy and Terms of Service. We intend to introduce a dedicated, purpose-specific disclosure screen at the point of ID upload in a future update — this screen will explain in plain language why the document is required, how it is used, and when it is deleted, and will require explicit acknowledgment before upload proceeds.
What we collect. A static image (photo or scan) of the front of your government-issued ID or passport biographical data page, used solely for visual identity matching. We do not request or retain the back of your ID unless required by applicable law. We do not extract, store, or retain any data from the image itself — including document numbers or ID numbers. The only information retained following verification is the name and date of birth you provided at registration, and a verification status flag on your account.
What we do not collect or retain. We do not store ID numbers, document numbers, or full images after verification is complete. We do not use ID images for marketing, profiling, analytics, product development, AI model training, or any purpose other than visual identity matching.
How it is collected. Whether you verify via web browser or iOS app, your ID image is transmitted and stored using industry-standard encryption. When using the iOS app, the image is uploaded through an in-app document picker or camera interface. The image is not cached, stored in your device's photo library, or retained in any application cache or device storage beyond the upload process. No local processing occurs that generates biometric templates or facial geometry data.
No biometric or automated processing. Free Agent does not perform facial recognition, automated biometric matching, selfie-to-ID comparison, liveness detection, or any similar automated processing of your ID image — whether submitted via web or iOS app. All review is conducted manually by a small number of trained Free Agent personnel subject to strict confidentiality obligations and access controls. Personnel reviewing ID documents are prohibited from copying, downloading, or using the information for any purpose other than verification. No biometric template of your face or other physical characteristics is created, stored, or shared.
Who has access. Access to uploaded ID images is restricted to a limited number of trained personnel for verification purposes only. Access is logged and audited. We do not share ID images with brands, employers, recruiters, or other Platform users under any circumstances.
Storage and encryption. ID images are transmitted and stored using industry-standard encryption in access-controlled storage infrastructure hosted by our cloud provider(s) subject to written data-processing agreements.
Retention. ID images are permanently deleted immediately upon successful verification. No image data, document data, or ID numbers are retained after this point — only the name and date of birth provided at registration and a verification status flag. ID images uploaded by athletes who do not complete verification within ten (10) business days are permanently deleted, and the athlete must re-submit their information to restart the process. We do not retain government-issued ID images beyond these periods under any circumstances. See Section 9 for full data retention schedules.
Verification alternatives. Where feasible, we may offer alternative verification methods that do not require government-issued ID. We will update this Policy if and when such alternatives become available.
Apple App Store compliance. Our iOS application's collection and handling of government-issued ID images is disclosed in our Apple App Store Privacy Nutrition Label as required by Apple's App Privacy Details requirements. The data type is classified as "Sensitive Info" under Apple's data category framework, linked to your identity, and used solely for App Functionality (identity and eligibility verification). This data is not used for tracking, advertising, or any third-party purpose. In-app ID upload is an optional convenience feature; athletes may always complete verification through our website at gofreeagent.com instead. If you have questions about how to review our App Store privacy label, visit our listing on the Apple App Store or contact help@gofreeagent.com.
Your choices. You may complete verification via our website at gofreeagent.com rather than through the iOS app at any time. You may also choose not to upload a government-issued ID at all, but doing so means you will not be able to obtain verified athlete status or access features requiring verification. You may request deletion of your ID image at any time by contacting help@gofreeagent.com.; we will action your request within 72 hours, subject to any applicable legal-hold obligations.
4. How We Use Your Information
We use personal information to:
create, secure, and operate your account, including verifying eligibility;
deliver the core Platform — matching, messaging, networking, recommendations, and content;
process payments, payouts, and financial transactions;
communicate with you about service updates, security alerts, support inquiries, and policy changes;
personalize content, recommendations, and the user experience;
conduct research, analytics, A/B testing, and product development;
detect, investigate, and prevent fraud, impersonation, abuse, security incidents, and policy violations;
enforce our Terms of Service and other contractual obligations;
comply with legal, tax, and regulatory obligations;
send marketing communications where permitted by law (you may opt out at any time); and
for any other purpose disclosed at the time of collection and to which you have consented.
We will not use your personal information for materially new purposes without first updating this Policy and, where required by law, obtaining your renewed consent.
5. Automated Decision-Making, Profiling, and Artificial Intelligence
5.1 Profiling for Recommendations
We use algorithms to suggest connections, opportunities, and content. These recommendations do not produce legal or similarly significant effects on you.
5.2 Use of Artificial Intelligence
Free Agent uses, and may in the future expand its use of, artificial-intelligence and machine-learning systems ("AI Systems") to: (i) detect fraud, abuse, and harmful content; (ii) generate insights, summaries, and recommendations; (iii) translate and transcribe content; and (iv) improve search and matching.
5.3 AI Model Training
Free Agent may use de-identified or aggregated information derived from the Platform to train, test, and evaluate proprietary AI Systems. We will not use the contents of your private messages, government-issued ID images, or other sensitive personal data to train AI Systems without your prior, explicit, opt-in consent.
5.4 Public Data and Web-Sourced Information
Free Agent does not currently scrape, harvest, or otherwise systematically collect publicly available information from third-party websites, forums, or social media to enrich athlete profiles. We may begin doing so in the future. If we do, we will update this Policy and provide users with notice before commencing such collection. Any future collection will be limited to data that is publicly available and lawful to collect, will respect technical access controls, will comply with the terms of source websites, and will honour valid requests to exclude information from our systems sent to help@gofreeagent.com.
5.5 No Solely-Automated Decisions With Legal Effect
We do not make decisions that produce legal or similarly significant effects about you (such as final hiring or contracting decisions) based solely on automated processing without meaningful human review.
5.6 Bias, Fairness, and Auditing
We test our AI Systems for accuracy and fairness, document their data sources and intended uses, conduct periodic reviews to identify and mitigate bias, and maintain records of significant model changes.
5.7 Identity Verification (Manual; No Biometric Processing)
Free Agent does not use biometric processing, facial recognition, voiceprint analysis, liveness detection, or automated decision-making to verify your identity or eligibility. Identity and eligibility verification are performed manually by trained Free Agent personnel who visually confirm that the name and date of birth you provided at registration match your government-issued ID, and confirm your competitive history through review of public sources. No automated systems make decisions about your eligibility, and no biometric templates of your face, voice, or other unique physical characteristics are created, stored, or shared. Manual reviewers are subject to confidentiality obligations and access controls, are prohibited from copying or downloading ID images, and all access to verification documents is logged. See Section 3.5 for full details on government-issued ID handling.
6. How We Share and Disclose Information
6.1 With Other Users
Your profile (name, photo, sport, statistics, biography, and content you have made public) is visible to other Platform users by default. You can adjust visibility in your account settings. Direct messages are visible to their recipients.
6.2 With Service Providers
We do not share government-issued ID images with third-party identity verification providers. Categories of service providers include cloud hosting and storage, payment processing, analytics and crash reporting, email/SMS/push-notification delivery, identity verification and anti-fraud providers, customer-support tools, security and observability providers, and professional advisors (auditors, lawyers, and accountants). We maintain an up-to-date list of key sub-processors; you may request a copy by contacting help@gofreeagent.com.
6.3 With Corporate Partners and Recruiters
With your consent or at your direction (e.g., when you apply for an opportunity), we share relevant profile information with employers, agents, brands, scouts, and sponsorship partners. We do not share government-issued ID images with any corporate partner, recruiter, or other Platform user under any circumstances.
6.4 Aggregated and De-Identified Data
We may share aggregated, de-identified, or anonymized data — from which you cannot reasonably be re-identified — with corporate partners, advertisers, and research institutions for industry insights, recruiting analytics, advertising effectiveness, and academic research.
6.5 We Do Not Sell or Share Personal Information for Cross-Context Advertising
Free Agent does not "sell" personal information for monetary or other valuable consideration, and does not "share" personal information for cross-context behavioural advertising, as those terms are defined under the CCPA/CPRA and comparable U.S. state privacy laws. We have reviewed our current data flows — including any third-party advertising pixels, analytics platforms, and partner integrations — to confirm this representation. If our practices change, we will update this Policy, provide users with notice as required by law, and make available a "Do Not Sell or Share My Personal Information" link in account settings and at gofreeagent.com/privacy. We honour Global Privacy Control ("GPC") signals where applicable.
6.6 Legal Process and Safety
We may disclose information when we have a good-faith belief that disclosure is required by applicable law, court order, lawful subpoena, or governmental request, or to: (i) protect our rights, property, or safety, or that of our users or the public; (ii) detect, prevent, or address fraud, security, or technical issues; (iii) enforce our Terms of Service; or (iv) cooperate with law-enforcement investigations.
6.7 Corporate Transactions
If Free Agent is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of its assets, your personal information may be transferred as part of the transaction. We will notify you of any such transfer, and any successor entity will be bound by this Policy until materially amended.
6.8 With Your Consent
We share information for any other purpose disclosed at the time of collection and to which you have consented.
7. Cookies, Tracking, and Online Advertising
We use cookies, pixels, software development kits, and similar technologies (collectively, "Cookies") to operate the Platform, remember your preferences, analyze usage, and deliver advertising. We classify Cookies as Strictly Necessary, Functional, Analytics/Performance, and Advertising/Targeting.
You can manage Cookies through (a) our cookie-consent banner shown on first visit, (b) the "Cookie Preferences" link in the website footer, (c) your browser settings, and (d) where applicable, industry opt-out tools such as the Network Advertising Initiative (networkadvertising.org/choices) and the Digital Advertising Alliance (aboutads.info/choices). We honour Global Privacy Control (GPC) signals where required by law. For full details, see our Cookie Policy at gofreeagent.com/cookies.
8. Your Privacy Rights
Depending on your jurisdiction, you have some or all of the following rights:
Access / Know: request a copy of the personal information we hold about you and details of how we use it.
Correction / Rectification: correct inaccurate or incomplete data.
Deletion / Erasure: request deletion of your personal data, subject to legal exceptions.
Portability: receive a machine-readable copy of certain data and transmit it to another controller.
Restriction: limit how we process your data while a request is pending.
Objection: object to processing based on legitimate interests, including direct marketing and profiling.
Withdraw Consent: at any time, where processing is based on consent (without affecting the lawfulness of prior processing). You may withdraw consent to the collection of your government-issued ID image by contacting help@gofreeagent.com.; doing so will result in your account remaining unverified.
Opt-Out of Sale, Sharing, or Targeted Advertising: under CCPA/CPRA and other applicable U.S. state laws.
Non-Discrimination: we will not deny services, charge different prices, or reduce service quality because you exercised your privacy rights.
Lodge a Complaint: with a supervisory authority — e.g., the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca), the Commission d'accès à l'information du Québec, or the California Privacy Protection Agency (cppa.ca.gov).
To exercise any right, email help@gofreeagent.com. or use the controls in your account settings. We will respond within the timeframes required by law (generally 30 days under PIPEDA; 45 days under CCPA/CPRA, with one permitted extension). We will verify your identity before fulfilling requests. You may designate an authorized agent to act on your behalf where permitted by law.
California "Shine the Light" Notice. California residents may request, once per calendar year, a list of personal information disclosed to third parties for those parties' direct-marketing purposes. Free Agent does not currently make such disclosures.
Nevada Residents. Nevada residents may opt out of the future sale of certain personal information by emailing help@gofreeagent.com.
9. Data Retention
We retain personal information only as long as necessary for the purposes set out in this Policy or as required by law. Specific retention periods include:
Unverified Signup Data (including government-issued ID or passport images): retained for a maximum of ten (10) business days while verification is in progress. If verification is not completed within ten (10) business days of submission, all such signup data is permanently deleted and the athlete must re-submit to complete verification.
Verification Documents — Government-Issued ID Images (Verified Accounts): permanently deleted immediately upon successful verification. No image data, document numbers, or ID numbers are retained after this point under any circumstances. The only information retained is the name and date of birth provided at registration and a verification status flag on the account.
Account Data (Verified Accounts): for the life of the account, plus up to twenty-four (24) months after account closure for fraud prevention, dispute resolution, and legal-defence purposes.
Transaction & Tax Records: up to seven (7) years after the transaction to comply with Canadian tax and accounting requirements.
Marketing Data: until you unsubscribe or withdraw consent, plus up to twelve (12) months for suppression-list purposes.
Server Logs and Security Data: up to thirteen (13) months.
Support Communications: up to thirty-six (36) months.
Legal-Hold Data: as long as required to comply with legal obligations, regulatory inquiries, or pending matters.
Aggregated or De-Identified Data: may be retained indefinitely for analytics, research, and product development.
When applicable retention periods expire, we delete, destroy, or de-identify the data in accordance with our internal data-retention schedule.
10. Security
We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. Measures include:
industry-standard encryption of all data in transit and at rest;
role-based access controls and least-privilege principles;
multi-factor authentication for administrative and privileged accounts;
strict access controls and audit logging for all systems that store or process government-issued ID images;
regular vulnerability scanning, penetration testing, and secure-code review;
vendor risk-management and ongoing security-assessment programs;
mandatory privacy and security training for all personnel, with enhanced training for staff with access to verification documents; and
incident-response and breach-notification procedures aligned with PIPEDA, BC PIPA, CCPA/CPRA, and applicable U.S. state breach-notification laws.
In the event of a personal-data breach likely to result in a real risk of significant harm or to the rights and freedoms of individuals, we will notify the appropriate supervisory authorities and affected individuals as required by law (e.g., "as soon as feasible" under PIPEDA's Breach of Security Safeguards Regulations).
Consistent with the Breach of Security Safeguards Regulations under PIPEDA, Free Agent maintains internal records of every breach of security safeguards involving personal information for not less than twenty-four (24) months from the date Free Agent determined the breach occurred, regardless of whether the breach was reportable to the Privacy Commissioner of Canada or notifiable to affected individuals. These records are made available to the Privacy Commissioner upon request.
11. International Data Transfers
Free Agent is headquartered in Calgary, Alberta, Canada, and may use service providers in Canada, the United States, and other jurisdictions. When we transfer personal data across borders, we rely on one or more lawful transfer mechanisms, including appropriate safeguards permitted under applicable North American privacy laws.
Government-issued ID images are subject to the same cross-border transfer safeguards as all other personal information. We do not transfer ID images to other jurisdictions without implementing appropriate contractual safeguards.
You may request a copy of the relevant transfer safeguards by contacting help@gofreeagent.com.
Where personal information of Quebec residents is communicated outside Quebec, Free Agent will conduct a Privacy Impact Assessment consistent with section 17 of Quebec's Law 25 prior to the transfer, taking into account the sensitivity of the information, the purposes for which it will be used, the protection measures in place at the destination, and the legal regime applicable in the destination jurisdiction. Where the assessment indicates the information would not receive adequate protection, the transfer will not occur unless additional contractual safeguards are put in place.
12. Mobile Application — Apple App Store
Free Agent's iOS mobile application is distributed through the Apple App Store. The following disclosures are specific to the mobile application.
12.1 Apple App Store Privacy Nutrition Label
In accordance with Apple's App Privacy Details requirements, we disclose all data types collected by the Free Agent iOS application in our App Store Privacy Nutrition Label. The label is visible on the Free Agent listing page in the Apple App Store before you download the application. Data types disclosed include, but are not limited to: contact information, identifiers, usage data, and sensitive information (including government-issued ID images collected during the optional in-app verification flow). You are encouraged to review the Privacy Nutrition Label before downloading and using the application.
12.2 Data Linked to You
The following data types collected by our iOS application are linked to your identity: your name, email address, phone number, date of birth, athlete profile information, government-issued ID image (during the optional in-app verification flow only, deleted immediately upon successful verification), and usage data associated with your account. These are disclosed as "Data Linked to You" in our App Store Privacy Nutrition Label.
12.3 No Tracking
We do not use data collected through the Free Agent iOS application to track you across third-party apps and websites for advertising purposes. We do not share identifiers or behavioral data with advertising networks or data brokers for cross-app or cross-website tracking.
12.4 App Permissions
The Free Agent iOS application may request the following device permissions. Each permission is requested at the time it is needed, and you may decline or revoke permissions through your device settings:
Camera: to allow you to photograph your government-issued ID or other verification documents directly within the app. Required only for the optional in-app verification flow; not used for any other purpose.
Photo Library: to allow you to select an existing photo of your ID or other document from your device. Required only for the optional in-app verification flow; not used for any other purpose.
Notifications: to send you account alerts, job application updates, and other Platform notifications. Optional; you may decline or disable at any time.
Location (optional): precise location is not requested by default. If you grant location permission, it is used only for location-relevant features you have enabled. You may revoke this permission at any time through your device settings.
The application does not access your contacts, microphone, health data, or any other device data beyond the permissions listed above. Permissions are requested only when necessary and are not used for purposes beyond those disclosed at the time of the request.
12.5 Apple's Privacy Practices
When you use Sign in with Apple or other Apple platform features, Apple's own privacy practices govern the data Apple collects. We encourage you to review Apple's Privacy Policy at apple.com/privacy. Free Agent is not responsible for Apple's data practices.
13. Third-Party Links and Services
The Platform may contain links to third-party websites, applications, and services that we do not own or control. This Policy does not apply to those third parties. We encourage you to review the privacy notices of any third party before providing personal information.
14. Changes to This Policy
We may update this Policy from time to time. The "Last Updated" date at the top of this Policy reflects the most recent revision. Where changes are material, we will provide reasonable advance notice through email and/or in-app notification before they take effect. Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy. Where required by law, we will obtain renewed consent.
15. Dispute Resolution and Governing Law
This Policy is governed by the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without regard to conflict-of-laws principles.
15.1 Informal Resolution
Before filing a formal complaint, please contact our Privacy Office at help@gofreeagent.com. We will work in good faith to resolve your concern within thirty (30) days.
15.2 Regulatory Complaint
You may file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca) at any time. Quebec residents may also contact the Commission d'accès à l'information.
15.3 Other Disputes; Reference to Terms of Service
To the extent any dispute arising out of or relating to your use of the Platform is subject to mandatory arbitration, individual-action requirements, or other contractual dispute-resolution mechanisms, those provisions are set out in the Free Agent Terms of Service, which are incorporated into your relationship with Free Agent by reference. This Privacy Policy is a notice of our information-handling practices and is not, by itself, intended to create a binding agreement to arbitrate or to waive any class-action, representative-action, or other procedural right. Any such provisions, where applicable, are governed exclusively by the Terms of Service. Nothing in this Policy or the Terms of Service limits your right to seek injunctive relief in a court of competent jurisdiction or to pursue rights granted by mandatory consumer-protection or privacy laws.
16. Accountability and Privacy Office
Free Agent has appointed a Privacy Officer to oversee compliance with PIPEDA, BC PIPA, Quebec Law 25, and other applicable privacy laws. You can reach the Privacy Office at:
Email: help@gofreeagent.com
Mail: Free Agent Inc., Attn: Privacy Officer, Centennial Place, East Tower, 520 3rd Avenue SW, Calgary, AB, Canada T2P 0R3
Designated Individual (PIPEDA Principle 1 / Quebec Law 25 s. 3.1): Kirsten Toth, CEO, Free Agent Technologies Inc. The designated individual is the person ultimately accountable for Free Agent's compliance with privacy law and is reachable through the Privacy Office contact details above.
If you are not satisfied with our response to a privacy concern, you have the right to escalate to the relevant supervisory authority listed in Section 8.
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