Getting Clear with Em, a brand of Em International, the operating name of 12894173 Canada Inc. (“we,” “us,” “our,” or “Getting Clear with Em”), is committed to handling personal information responsibly. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit https://myclearframework.com, contact us, join our email list, purchase or access the CLEAR Framework Toolkit, or otherwise interact with us.
This Policy is intended to describe our actual privacy practices in clear language. It applies to personal information, meaning information about an identifiable individual.
1. Person Responsible for Personal Information
Mannon Malo, Founder, is responsible for the protection of personal information at 12894173 Canada Inc.
Email: [email protected]
Mailing address: 479 Av. Mousseau-Vermette, Dorval, QC H9S 0A6, Canada
You may contact this person with questions, requests for access or correction, concerns, or complaints about our handling of personal information.
2. Personal Information We Collect
Information you provide directly
Your name.
Email address
Billing address and other information needed to process a purchase
Account or login information for the learning platform
Information you submit through contact forms, waitlists, surveys, feedback forms, emails, or customer-support requests
Communications you send to us.
Please do not submit sensitive personal information (such as health, medical, or financial records). The CLEAR Framework Toolkit is a self-reflection resource and is not designed to collect this type of information. Weekly check-in and the reflection journal are for your own use; we do not ask you to submit them to us.
Purchase and payment information
Payments are processed by Stripe. We receive information associated with your purchase, such as your name, email address, billing details, purchase amount, transaction status, and limited payment-reference information. We do not store complete payment-card numbers or security codes.
Information collected automatically
When you visit our website or use our learning platform, we or our service providers may automatically collect:
IP address.
Browser type and device information.
Operating system.
Pages viewed, links clicked, and approximate visit times.
Referring website or source.
Cookies and similar technologies.
Learning-platform activity, such as log-ins, content progress, and download activity.
3. Why We Collect and Use Personal Information
We use personal information only for purposes connected to our business and your interaction with us, including to:
Operate, maintain, and improve our website and Services.
Process purchases, payments, refunds, and customer-support requests.
Create and manage your learning-platform account and access.
Deliver the CLEAR Framework Toolkit and related communications.
Send transactional messages, such as purchase confirmations, access instructions, service notices, and policy updates.
Send newsletters, invitations, or offers when you have consented. You may unsubscribe at any time.
Respond to questions, feedback, privacy requests, or complaints.
Detect and help prevent fraud, misuse, security incidents, or violations of our Terms.
Understand how visitors use our website so we can improve its content and usability.
Meet legal, tax, accounting, and record-keeping obligations.
4. Consent
We obtain your consent before collecting, using, or disclosing your personal information, except where the law permits otherwise. You give consent, for example, when you submit a form, opt in to our email list, create an account, or complete a purchase.
You may withdraw consent at any time, subject to legal and contractual limits. Withdrawing consent may affect our ability to provide some Services, such as account access or purchase support.
To stop receiving marketing emails, use the unsubscribe link in any email or contact [email protected].
5. Cookies and Analytics
We use cookies and similar technologies to make our website function, remember preferences, and understand how the website is used.
These technologies may be placed by us or by our service providers, including GoHighLevel / LeadConnector (website and learning platform), Google Analytics (website analytics), and Stripe (secure checkout and fraud prevention).
Google Analytics helps us understand, in aggregate, how visitors find and use our website. You can learn more at https://policies.google.com/technologies/partner-sites and opt out using the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout.
We do not currently use advertising or retargeting pixels (such as the Meta Pixel).
You can control cookies through your browser settings. Disabling some cookies may affect website features. Where required, we ask for your consent before placing non-essential cookies.
6. How We Share Personal Information
We do not sell personal information.
We share personal information only with service providers that help us operate our business, and only as needed:
Stripe — payment processing and fraud prevention.
GoHighLevel / LeadConnector — website hosting, forms, customer records, email delivery, automation, learning-platform access, and customer support.
Google Analytics — website analytics.
Cloudflare (R2 storage) — secure hosting of downloadable Toolkit files and storage of our backups, which include customer records from our CRM (such as names, email addresses, and purchase history) and customer conversations (such as support and refund correspondence). The downloadable files themselves contain no customer information. When you download a file, Cloudflare may process technical information such as your IP address and browser details to deliver the file securely.
Professional advisers (such as our accountant or lawyer), where necessary.
Government authorities, courts, or law enforcement, where required or permitted by law.
A buyer or successor in connection with a sale, merger, or restructuring of our business, where permitted by law.
Our service providers may use personal information only to provide services to us and are subject to obligations to protect it.
7. Information Processed Outside Québec or Canada
Stripe, GoHighLevel / LeadConnector, Google, and Cloudflare store or process information outside Québec and Canada, primarily in the United States. When personal information is processed outside Québec, it may be subject to the laws of that jurisdiction, including lawful access by authorities there.
Before transferring personal information outside Québec, we assess whether it will receive adequate protection, and we rely on providers that maintain recognized security and privacy safeguards. Questions about these transfers can be directed to [email protected].
8. Retention and Destruction
We keep personal information only as long as needed for the purposes described in this Policy or as required by law:
Purchase, invoice, tax, and accounting records: kept for the period required by Canadian and Québec tax law (generally six years).
Customer-support and refund correspondence: kept as long as needed to resolve the request and maintain appropriate records.
Email-list information: kept until you unsubscribe or we determine it is no longer needed.
Website analytics data: kept according to our Google Analytics retention settings.
Learning-platform account information: kept while your account is active and for a reasonable period afterward, unless you request deletion and no legal retention requirement applies.
Backups: we keep rolling backups of our CRM records and customer conversations for 30 days to protect against data loss. Each backup is automatically overwritten or deleted after 30 days.
When personal information is no longer needed, we securely destroy or anonymize it. If we delete your information at your request, copies may remain in our backups until they are automatically deleted, up to 30 days later. During that time, backups are kept secure and are not used for any other purpose.
9. Security
We use reasonable administrative, technical, and organizational safeguards to protect personal information against loss, theft, and unauthorized access, use, or disclosure. These safeguards include access controls on our accounts and 30-day rolling backups to help us recover information if a technical failure occurs.
No online transmission or electronic storage is completely secure, and we cannot guarantee absolute security. Please keep your account credentials confidential and tell us promptly if you believe your account has been accessed without authorization.
10. Your Privacy Rights
Subject to applicable law, you may:
Access the personal information we hold about you.
Correct inaccurate, incomplete, or outdated information.
Withdraw consent to certain uses or disclosures.
Ask how your personal information has been collected, used, or disclosed.
Ask us to stop disseminating or to delete your information where permitted or required by law.
Receive certain computerized personal information in a commonly used technological format.
Make a complaint about our privacy practices.
To make a request, contact Mannon Malo, Founder, at [email protected]. We may need to verify your identity. We will respond within 30 days, as required by Québec law.
11. Confidentiality Incidents
If a confidentiality incident involving personal information occurs, we will take reasonable steps to reduce the risk of harm. Where the incident presents a risk of serious injury, we will notify affected individuals and the Commission d’accès à l’information du Québec, as required by law. We keep a register of confidentiality incidents.
12. Children
Our Services are intended for adults. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, contact [email protected].
13. Third-Party Links
Our website may link to third-party websites or platforms. We are not responsible for their privacy practices, content, or security. Please review their privacy policies before sharing personal information.
14. Changes to This Policy
We may update this Privacy Policy to reflect changes in our practices, Services, legal obligations, or technology. We will post the updated Policy on this page with a new effective date and, for material changes, notify you by email or a website notice.
15. Contact Us or Make a Complaint
Mannon Malo, Founder — Person Responsible for Personal Information
12894173 Canada Inc., operating as Em International (Getting Clear with Em)
479 Av. Mousseau-Vermette, Dorval, QC H9S 0A6, Canada
Email: [email protected]
If you are not satisfied with our response, you may contact the Commission d’accès à l’information du Québec (https://www.cai.gouv.qc.ca).