Privacy Policy

Effective date: October 6, 2026
Last updated: October 6, 2026

Who is this policy from?

This policy is from Freedom10 Inc. ("Freedom10", "we", "us"). We are an education and consulting company that teaches rental cash damming and the Smith Manoeuvre.

It explains what personal information we collect, why we use it, who we share it with and what choices you have. It covers freedom10.ca, our event site at events.freedom10.ca, our partner portal at partners.freedom10.ca, and our calls, forms, emails and text messages.

Is Freedom10 a mortgage brokerage?

No. Freedom10 is not a mortgage brokerage and does not arrange mortgages.

If you choose to get mortgage services, they are provided by licensed mortgage agents at Tango Financial (FSRA brokerage licence #13691). The brokerage handles that information under its own privacy policy. This policy covers only what Freedom10 does with your information.

What information do we collect?

We collect only what we need for the service you asked for. That depends on how you deal with us.

When you register for a webinar or masterclass: your name, email address, phone number, and whether you attended or watched the replay.

When you book a call: your name, contact details, answers to our screening questions and the time you booked.

We record and transcribe video calls (through Zoom and Fathom) so we can keep accurate notes; you'll see a notice in the call. If we record a phone call, we tell you when you book it. If you'd rather a call not be recorded, tell us at the start.

When you become a client: the details on our intake form. This can include your income, your properties and their values, your mortgages, your investments and other debts. We use it to prepare your plan.

When you use our accountant-review service: the information and documents needed for that review. See "Who do we share your information with?" below.

When you are a referral partner: your name, business, contact details, the email addresses you sign in with, and the referrals you send us.

When you visit our websites: basic technical data such as your browser, device, pages viewed, and the ad or link that brought you to us. See "Do we use cookies?" below.

When you contact us: the emails, texts and call notes from those conversations.

How do we use your information?

We use it to:

• register you for events and send you the reminders you asked for, by email and text message
• hold calls with you, and prepare for them
• build, deliver and support your plan as a client
• arrange the accountant-review service when you ask for it
• run our referral partner program
• send newsletters and marketing emails if you have agreed to receive them
• measure which ads and pages work, so we spend less on ones that do not
• keep business records and meet our legal obligations

We do not sell your personal information.

How do we use AI?

We use AI services to help run the business. Today these are Anthropic's Claude and OpenAI.

We use them to summarize client files and communications, sort and draft emails, prepare for client calls and analyze information we hold. Our staff also use AI assistants that can access our systems.

This means your personal information can be sent to these providers. That can include financial details, call transcripts and emails. We use OpenAI for an internal knowledge tool built from our team's chat messages.

We use these providers as service providers, not to sell or share your data for their own purposes. We choose business terms that do not allow our data to be used to train their models. People, not AI, make the decisions about your plan.

Who do we share your information with?

We share it only when needed to deliver our services, when you ask us to, or when the law requires it.

Mortgage agents at Tango Financial. If you want mortgage services, we pass your details to a licensed agent so they can help you.

Accountants. If you use our accountant-review service, the review is done by a Chartered Professional Accountant (CPA) we work with. They receive only the documents needed for the review. We will tell you who they are before we share anything with them.

Referral partners. If a partner referred you, they can see your name and the status of your file in our partner portal. They do not see your financial details.

Service providers. These companies run the tools we use. They process information on our behalf and may only use it to provide their service to us.

Legal requirements. We may disclose information if the law requires it, for example under a court order.

Is my information stored outside Canada?

Yes, some of it. Many of our providers are based in the United States, and your information may be stored or processed there.

While it is outside Canada, it may be accessible to courts, law enforcement and national security authorities there under their laws.

How do you get my consent?

We ask for your consent when we collect your information. Sometimes consent is express, such as ticking a box or signing our client agreement. Sometimes it is implied, such as when you register for a webinar and we send you the reminders for it.

For sensitive information, such as your financial details, we rely on express consent.

You can withdraw your consent at any time, subject to legal or contract limits. If you do, we will tell you what that means for the services we can still provide.

How do I stop marketing emails and texts?

We follow Canada's Anti-Spam Legislation (CASL). We send marketing messages only with your consent, and every one includes a way to unsubscribe.

You can unsubscribe from all marketing with one click. You can also use our preference centre to choose which topics you hear about.

Event reminders are tied to an event you registered for. You can stop our text messages by replying STOP. You will get one text confirming it, and no more after that.

When you unsubscribe, we keep your email address on a suppression list. That is how we make sure we do not email you again.

Do we use cookies?

Yes. Cookies are small files a website saves in your browser. Some tools save information in your browser's storage instead of a cookie. We treat those the same way.

On freedom10.ca there are two kinds:

• Essential. These are always on. Today the only one remembers your cookie choice.
• Analytics and advertising. Google Analytics counts visits and shows us which pages people use. The Meta Pixel tells us which of our Meta (Facebook and Instagram) ads bring people to the site. Both are off until you choose "Accept" in the cookie banner. If you choose "Decline", or make no choice, they do not load.

We remember your choice for 12 months, then ask again. You can change it at any time with the "Cookie settings" link at the bottom of every page. If you change from Accept to Decline, we remove the Google Analytics and Meta cookies from your browser and reload the page.

Videos. Our videos are hosted by Wistia. When a page with a video loads, Wistia's player loads too, and it may save information in your browser to play the video and count views.

Our event site. events.freedom10.ca, where you register for webinars and book calls, follows the same choice. Its pages load the Meta Pixel only if you accepted. If you accepted, registering for a webinar also sends Meta limited details through Meta's Conversions API: a scrambled (hashed) copy of your email address and first name, your IP address and browser details, and the ad that brought you. We use this to measure our ads. If you haven't chosen yet, the event site asks you with the same banner.

Whatever you choose, if you arrive from an ad or a tagged link, we pass that tag along when you register, so we know where your registration came from.

You can also block or delete cookies in your browser settings. Our sites will still work.

How long do we keep it?

We keep a client file for as long as you are a client, and then for 7 years.

If you never became a client, for example you registered for a webinar or booked a call, we keep your records for 7 years from the last time we were in contact, and then delete them.

The exception is an unsubscribe record. If you asked us to stop contacting you, we keep that record so we don't contact you again.

How do we protect it?

We use safeguards that match how sensitive the information is. They include:

• encryption of information in transit
• access limited to people who need it for their job
• two-step sign-in required for everyone with access to our systems
• database access controls
• an audit log of changes to records

No system is perfectly secure. We review our safeguards and improve them over time.

What happens if there is a breach?

We keep a record of every privacy breach, however small.

If a breach creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as soon as we can. We will also tell any other organization that can help reduce the harm.

What are my rights?

You have the right to:

• Access the personal information we hold about you. We will respond within 30 days.
• Correct information that is wrong or incomplete.
• Withdraw consent, as described above.
• Challenge our compliance with this policy or with Canadian privacy law.

To make a request, contact our Privacy Officer below. We may need to confirm your identity first.

If you are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

Is this for children?

No. Our services are for adults. We do not knowingly collect information from anyone under 18.

Will this policy change?

We may update this policy as our services or the law change. We will post the new version here with a new "last updated" date. If a change is significant, we will tell you by email or on our website.

How do I contact you?

Privacy Officer
Sean Smith, Co-founder
Freedom10 Inc.
802-201 Carlaw Avenue
Toronto ON M4M 2S3
Email: privacy@freedom10.ca