Privacy Policy

1) Introduction & Controller Identity

This Privacy Policy applies to our website and to interactions where you contact us about training programs, learning resources, workshops, or participation certificates. For privacy and data protection purposes, the data controller is:

• Legal entity: FELLONI LATERAL OFFICE CANADA EDUCATION INC.
• Operating name: Felloni Lateral Office
• Registered address: First Canadian Place, 100 King St W, Suite 5700, Toronto, ON M5X 1C7, Canada
• Contact email: [email protected]
• Phone: +1 416 619 7843

We do not appoint a dedicated Data Protection Officer for our standard operations. If your request requires escalation, we will route it internally to a privacy lead.

Effective date of this policy: March 14, 2026.

2) Personal Data We Collect

The personal information we collect depends on how you use the site. We collect the categories below for the purposes described in Section 3.

Identity and contact data

When you submit a request for program information, we may collect your name, email address, phone number, organization name (if provided in your message), and any role or department details you include.

Form content and training context

We collect the content of your message and the program interest you select. This can include the document types you work with (for example: SOPs, meeting minutes, incident logs, reporting packages), delivery preferences (workshop vs. self-paced), scheduling constraints, and any constraints you describe (approval workflow, versioning approach, retention schedule expectations). This information helps us respond with relevant education materials rather than a generic reply.

Technical and device data

When you browse the site, our servers and security layers may record technical data such as your IP address, browser type and version, device type, operating system, language preference, approximate location derived from IP (city/region level), and timestamps. This information is typically collected through server logs and security services to keep the website reliable and to detect abuse.

Usage and engagement data

With your consent (where required), we may collect information about how you use the site, such as pages visited, time on page, referral source, and click paths. We use this data to understand which resources are useful and where visitors encounter friction (for example, unclear program descriptions or confusing navigation).

Cookies and identifiers

We use cookies and similar identifiers. Essential cookies are used to keep the site functioning and to remember your cookie preferences. Analytics and marketing cookies are optional and controlled through the cookie banner and preferences modal. For details and examples, see Section 4 and our Cookie Policy.

What we do not intentionally collect

Our education services do not require special-category data such as health information, religious beliefs, political opinions, biometric identifiers, or union membership. We do not ask for government ID numbers or financial account details. Please do not include sensitive personal information in the contact form.

3) Why We Process Personal Data & Legal Basis

We process personal data for specific purposes and, where applicable, rely on legal bases commonly referenced under GDPR Article 6. If you are in Canada, similar principles apply under Canadian privacy laws: we collect information for identified purposes, limit collection, and use it only as needed to respond to your request and operate the site.

Responding to enquiries and delivering program information

• Purpose: Respond to your request, recommend a learning path, coordinate schedules, and provide program materials you ask for.
• Legal basis (GDPR): Article 6(1)(b) (steps prior to entering a contract) and Article 6(1)(a) (consent) where you provide information voluntarily via the form.

Website analytics (optional)

• Purpose: Understand site performance, improve navigation, and refine program pages based on aggregated usage patterns.
• Legal basis (GDPR): Article 6(1)(a) (consent).

Marketing and conversion measurement (optional)

• Purpose: Measure whether advertising campaigns lead to enquiries, and support relevant advertising (for example, showing ads to people who previously visited program pages).
• Legal basis (GDPR): Article 6(1)(a) (consent).

Security, reliability, and fraud prevention

• Purpose: Protect the site against malicious traffic, form abuse, and operational failures.
• Legal basis (GDPR): Article 6(1)(f) (legitimate interests), balanced against your rights and expectations.

Legal compliance

• Purpose: Maintain records when required by law (for example, to respond to lawful requests or resolve disputes).
• Legal basis (GDPR): Article 6(1)(c) (legal obligation).

Automated decision-making

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects as described in GDPR Article 22.

4) Cookies & Tracking

Cookies are small text files stored on your device. We also use similar technologies such as pixel tags and, in some cases, server-side event forwarding. Cookies fall into three categories on our site: essential, analytics, and marketing. You can manage non-essential cookies using “Manage cookie preferences” in the footer or the cookie banner.

Essential cookies (always active)

Essential cookies are required for basic site functions, security features, and to remember your cookie choices. These cookies do not require consent in many jurisdictions because they are necessary to provide the service you request.

• Examples: _site_session (session continuity), cookie_consent (stores your preferences).
• Typical retention: Session to 12 months (depending on the cookie).

Analytics cookies (optional; consent-based)

With your permission, we may use Google Analytics 4 (GA4) to understand aggregated usage patterns. We configure analytics to reduce personal data collection where feasible, including IP anonymization where supported. Analytics data is used to improve content quality, not to make individual decisions about you.

• Examples: _ga (2 years), _ga_XXXXXXXXXX (2 years).
• Analytics retention setting: 14 months.

Marketing cookies (optional; consent-based)

With your permission, we may use marketing cookies to measure campaign performance and show relevant ads on third-party platforms. This may include conversion attribution, remarketing audiences, and measurement of form submissions.

• Examples: _gcl_au (Google Ads, 90 days), _fbp (Meta Pixel, 90 days), _fbc (Meta click ID, 90 days when present).
• How it is used: conversion measurement, remarketing, and audience creation (including lookalike audiences) where available.

Pixels and server-side signals

In addition to cookies, advertising and analytics platforms may use pixel tags (small code snippets) and server-side events. These signals can include page views, form conversions, and technical identifiers such as IP address and User-Agent. Where server-side forwarding is used, identifiers may be hashed before transmission. Non-essential pixels should only activate after consent where required.

5) Consent and Cookie Controls (EEA/UK)

Users in the EEA and UK receive a consent notice under GDPR/UK GDPR. Analytics and marketing cookies activate only after explicit, informed, freely given consent (GDPR Article 6(1)(a)). Your consent choice is recorded in the cookie_consent cookie for up to 12 months.

You can withdraw consent at any time by using “Manage cookie preferences” in the footer or by clearing your browser cookies. Withdrawal does not affect the lawfulness of processing before withdrawal.

6) Sharing With Advertising & Service Partners

We share limited data with service providers to operate the website and, where you consent, with analytics and advertising partners to measure and improve campaigns. We do not sell personal information.

Google LLC

If enabled, Google services may receive cookie identifiers, usage data, and conversion events for analytics and advertising measurement. Learn more: https://policies.google.com/privacy.

Meta Platforms, Inc.

If enabled, Meta services may receive page view and conversion events, as well as marketing identifiers such as _fbp and _fbc, to support measurement and audience features. Learn more: https://www.facebook.com/privacy/policy/.

Cloudflare

We may use Cloudflare for performance and security, including protection against malicious traffic. Cloudflare may process IP addresses and request metadata as part of these services. Learn more: https://www.cloudflare.com/privacypolicy/.

We do not permit these providers to use site data for their own independent commercial purposes outside of providing services to us, subject to their contractual terms and platform policies.

7) International Transfers

Some service providers may process data outside Canada, including in the United States. Where GDPR/UK GDPR applies, international transfers may rely on the EU–US Data Privacy Framework (and the UK Extension, where applicable), with Standard Contractual Clauses (EU 2021/914) or the UK International Data Transfer Agreement as fallback mechanisms.

We take a pragmatic approach: limit data shared, prefer aggregated analytics where feasible, and use consent controls for non-essential tracking.

8) Data Retention

We retain personal information only as long as needed for the purposes described in this policy. Retention periods may vary depending on the nature of your request and any legal requirements.

• Contact submissions: up to 2 years from the last interaction, so we can follow up on scheduling and program details.
• Email correspondence: duration of the relationship plus 1 year, unless a longer period is required for dispute resolution.
• Server logs: typically up to 90 days for security and troubleshooting.
• Analytics data: 14 months (where enabled and configured).
• Marketing cookies: per cookie lifetime (commonly 90 days), unless you withdraw consent sooner.
• Cookie consent record: up to 3 years for audit and compliance documentation, where applicable.
• Legal compliance: retained as required by applicable law.

9) Your Rights

Depending on your location and the law that applies, you may have rights regarding your personal information. Where GDPR/UK GDPR applies, these include:

• Right of access (Article 15)
• Right to rectification (Article 16)
• Right to erasure (Article 17)
• Right to restriction of processing (Article 18)
• Right to data portability (Article 20)
• Right to object (Article 21)
• Right to withdraw consent at any time (Article 7(3))
• Right to lodge a complaint with a supervisory authority (Article 77)

To exercise a request, email [email protected]. We respond within 30 days, and may extend by up to 60 additional days for complex requests. We may ask for reasonable information to verify identity before processing a request.

Supervisory authorities referenced for GDPR information include the European Data Protection Board: https://edpb.europa.eu, and the UK Information Commissioner’s Office: https://ico.org.uk.

If you are in Canada, you may also have rights under applicable Canadian privacy laws. For general federal guidance, you can consult the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca.

10) Children

This site is not directed at individuals under 16. We do not knowingly collect personal information from minors. If we learn that we have collected personal information from a child under 16 without appropriate consent, we will delete it promptly.

11) Do Not Track

This website does not respond to Do Not Track (DNT) browser signals. Third-party providers may have their own approaches to DNT and similar signals, which are described in their privacy documentation.

12) Account & Data Deletion Requests

We do not provide user accounts as part of this site. If you want us to delete personal information you submitted, email us with the subject line “Data Deletion Request” at [email protected].

We will complete deletion within 30 days after identity verification, unless we need to retain limited information to meet legal obligations or to defend a legal claim.

13) Business Transfers

If we are involved in a merger, acquisition, asset sale, financing, or insolvency, personal information may be transferred to a successor entity as part of that transaction. If such a transfer materially changes how personal information is used, we will provide notice on the website.

14) California (CCPA / CPRA)

If you are a California resident, you may have rights under the California Consumer Privacy Act as amended by the CPRA. In the past 12 months, we may have collected the following categories of personal information:

• Identifiers: name, email, IP address, cookie identifiers (shared with service providers and, if enabled by consent, with advertising partners).
• Internet/network activity: pages visited and engagement signals (used for analytics and advertising where enabled).
• Inferences: high-level interests based on page visits (used only for advertising where enabled).

We do not sell personal information as defined by CCPA. We may share personal information for cross-context behavioral advertising if you enable marketing cookies. California residents may opt out by using the cookie preferences panel (Manage cookie preferences in the footer).

You may request to know, delete, or correct personal information, and you have the right to opt out of sale/sharing and to non-discrimination. Submit requests by emailing [email protected] with the subject “California Privacy Request”. We may need to verify your identity. Authorized agents must provide proof of authorization.

15) Virginia (VCDPA)

If you are a Virginia resident, you may have rights to access, correct, delete, and obtain a copy of personal data, and to opt out of targeted advertising. We do not sell personal data and do not engage in profiling that produces legal or similarly significant effects.

Submit requests by emailing [email protected] with the subject “Virginia Privacy Request”. If we decline an action on a request, you may appeal by emailing with the subject “Appeal of Refusal — Privacy Request”. We will respond to appeals within 60 days.

16) Nevada

Nevada residents may submit a verified opt-out request by emailing [email protected] with the subject “Nevada Do Not Sell Request”. We do not currently sell personal information as defined by Nevada Revised Statutes Chapter 603A.

17) Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our practices, service providers, or legal requirements. Material changes will be announced via a website notice at least 14 days before taking effect where feasible. The “Last Updated” date at the top of this page will also be revised.

18) Contact

For privacy questions, access requests, or deletion requests, contact:

• FELLONI LATERAL OFFICE CANADA EDUCATION INC.
• First Canadian Place, 100 King St W, Suite 5700, Toronto, ON M5X 1C7, Canada
• Email: [email protected]
• Phone: +1 416 619 7843