PRIVACY POLICY

Last updated: January 27, 2026

INTRODUCTION

Foster Consulting Incorporated, operating as FC Congruent ("we," "us," "our," or "Company"), is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website fccongruent.com (the "Site") and use our services (collectively, the "Services").

This Privacy Policy applies to all personal information collected by FC Congruent and complies with:

  • The Personal Information Protection and Electronic Documents Act (PIPEDA)

  • Ontario's privacy legislation

  • Applicable Canadian privacy laws

  • Anti-Spam Legislation (CASL)

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OR USE THE SERVICES.


TABLE OF CONTENTS

  1. INFORMATION WE COLLECT

  2. HOW WE USE YOUR INFORMATION

  3. DISCLOSURE OF YOUR INFORMATION

  4. TRACKING TECHNOLOGIES AND COOKIES

  5. THIRD-PARTY WEBSITES AND SERVICES

  6. DATA RETENTION

  7. SECURITY OF YOUR INFORMATION

  8. YOUR PRIVACY RIGHTS

  9. CONTROLS FOR DO-NOT-TRACK FEATURES

  10. CHILDREN'S PRIVACY

  11. INTERNATIONAL DATA TRANSFERS

  12. EMAIL AND SMS COMMUNICATIONS

  13. CHANGES TO THIS PRIVACY POLICY

  14. CONTACT US


1. INFORMATION WE COLLECT

We collect information about you in various ways when you use our Services. The information we collect may include:

Personal Information You Provide to Us

We collect personal information that you voluntarily provide to us when you:

  • Register for a discovery call or webinar

  • Enroll in our coaching programs

  • Contact us with inquiries

  • Submit assignments or program materials

  • Provide testimonials or feedback

  • Subscribe to our newsletters or communications

  • Participate in surveys or assessments

The personal information we collect may include:

Contact Information:

  • Full name

  • Email address

  • Phone number (mobile and/or landline)

  • Mailing address

  • City, province/state, postal code, country

Professional Information:

  • Current and past employment details

  • Job titles and responsibilities

  • Career objectives and goals

  • Resume/CV information (when provided)

  • LinkedIn profile information (when provided)

  • Professional skills and experience

  • Educational background

  • Salary expectations and career preferences

Payment Information:

  • Billing address

  • Payment method information (processed securely through our payment processor)

  • Purchase history and transaction records

Program Participation Information:

  • Coaching program assignments and submissions

  • Worksheets and assessments completed

  • Progress tracking and session notes

  • Personal reflections and career development work

  • Session recordings (when recorded with consent)

  • Testimonials and success stories (when provided with consent)

Webinar and Event Information:

  • Webinar registration details

  • Attendance records

  • Questions submitted during webinars

  • Webinar chat participation (if applicable)

  • Poll responses and engagement data

Communications:

  • Messages you send to us via email, contact forms, or SMS

  • Feedback and survey responses

  • Support requests and inquiries

  • Correspondence related to coaching sessions

Marketing and Preferences:

  • Communication preferences

  • Marketing consent records

  • Newsletter subscription status

  • Areas of interest and career focus

Information Automatically Collected

When you access our Services, we automatically collect certain information about your device and usage patterns, including:

Device and Usage Information:

  • IP address

  • Browser type and version

  • Operating system

  • Device type (mobile, desktop, tablet)

  • Unique device identifiers

  • Referring website or source

Activity Information:

  • Pages viewed and content accessed

  • Time and date of visits

  • Time spent on pages

  • Clickstream data

  • Referring/exit pages

  • Search queries within our Services

  • Downloads of resources or materials

Location Information:

  • General geographic location (city/region level) based on IP address

  • Time zone information

Information from Third-Party Sources

We may receive information about you from third-party sources, including:

Social Media Platforms:

  • Public profile information from LinkedIn or other platforms you choose to connect to

  • Information you share when engaging with our social media content

Analytics Providers:

  • Website analytics data

  • Marketing campaign performance data

  • Webinar platform analytics (e.g., Zoom, WebinarJam)

Payment Processors:

  • Transaction confirmation and payment status

  • We do not store complete credit card information

Referral Sources:

  • Information provided by individuals who refer you to our Services

Information You Choose to Share

Program Assignments and Materials: During coaching programs, you may submit assignments, worksheets, assessments, and other materials that contain personal reflections, career goals, and professional information. This information is collected solely for the purpose of delivering coaching services to you.

Testimonials and Success Stories: If you choose to provide a testimonial or success story, you may share information about your experience, career outcomes, and personal journey. We will only use this information publicly with your explicit written consent.


2. HOW WE USE YOUR INFORMATION

We use the information we collect for various purposes in accordance with applicable law and the consent you provide. Specifically, we use your information to:

Provide and Manage Services

  • Schedule and confirm discovery calls and coaching sessions

  • Deliver coaching programs and consulting services

  • Process your enrollment in programs

  • Process payments and manage billing

  • Provide the (when requested)

  • Send session reminders and confirmations

  • Respond to your inquiries and support requests

  • Track your progress in coaching programs

  • Provide personalized coaching and guidance

  • Deliver program materials and resources

Webinars and Educational Events

  • Process webinar registrations

  • Send webinar reminders and access links

  • Track webinar attendance

  • Collect and respond to questions during webinars

  • Send follow-up materials after webinars

  • Analyze webinar engagement for improvement

  • Provide recordings to registered attendees (when applicable)

Improve and Develop Services

  • Understand how our Services are used

  • Analyze client outcomes and program effectiveness

  • Identify areas for improvement

  • Develop new programs and services

  • Conduct research and create anonymized insights

  • Test new features and methodologies

  • Troubleshoot technical issues

Communicate with You

  • Send program updates and session confirmations

  • Provide client support

  • Send administrative information

  • Notify you of changes to our Services or policies

  • Send newsletters and educational content (with consent)

  • Invite you to webinars and events

  • Request feedback and testimonials (with your permission)

Marketing and Promotional Activities (With Consent)

  • Send marketing communications about our Services

  • Promote new programs and offerings

  • Send personalized recommendations based on your interests

  • Share educational content and resources

  • Promote webinars and events

  • Share testimonials and success stories (only with explicit written consent)

Legal and Security Purposes

  • Comply with legal obligations

  • Enforce our Terms of Service

  • Protect our rights and property

  • Prevent fraud and unauthorized access

  • Investigate and address violations

  • Respond to legal requests

  • Protect the safety and security of our clients

Business Operations

  • Manage our business operations

  • Conduct internal audits and quality assurance

  • Maintain business and financial records

  • Analyze business performance

  • Facilitate business planning

With Your Consent

  • Any other purposes for which we obtain your specific consent

Legal Basis for Processing (PIPEDA Compliance)

Under PIPEDA, we process your personal information based on:

  • Consent: You have provided express or implied consent for specific purposes

  • Contractual Necessity: Processing is necessary to fulfill our service agreement with you

  • Legal Obligations: Processing is required to comply with applicable laws

  • Legitimate Interests: Processing is necessary for our legitimate business interests, provided these don't override your privacy rights

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.


3. DISCLOSURE OF YOUR INFORMATION

We may share your information in the following circumstances:

Service Providers and Business Partners

We engage trusted third-party companies and individuals to perform services on our behalf, including:

Technology and Infrastructure:

  • Website hosting providers

  • Cloud storage services (for program materials and client work)

  • Email service providers

  • SMS messaging platforms

  • Customer relationship management (CRM) systems

  • Video conferencing platforms (e.g., Zoom)

  • Webinar platforms

  • Calendar and scheduling tools

Payment Processing:

  • Payment processors (e.g., Stripe)

  • Fraud prevention services

  • These providers never receive your complete payment card information

Marketing and Analytics:

  • Email marketing platforms

  • Analytics providers (e.g., Google Analytics)

  • Social media platforms (for marketing purposes)

  • Webinar and event platforms

Professional Services:

  • Legal advisors

  • Accounting and financial advisors

  • Business consultants (under confidentiality agreements)

  • IT support services

These service providers are bound by confidentiality obligations and are only permitted to use your information to perform services on our behalf. They may not use your information for their own purposes.

Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, dissolution, or sale of company assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

Legal Requirements and Protection

We may disclose your information if required to do so by law or in response to:

  • Valid legal processes (subpoenas, court orders, warrants)

  • Regulatory requests

  • Government investigations

  • Requests from law enforcement

We may also disclose information to:

  • Enforce our Terms of Service or other agreements

  • Protect our rights, property, or safety

  • Protect the rights, property, or safety of our clients or others

  • Prevent fraud or illegal activities

  • Investigate security incidents

With Your Consent

We may share your information for purposes not described in this Privacy Policy with your specific consent. For example:

  • Using your testimonial or success story in marketing materials (requires explicit written consent)

  • Sharing your contact information with potential collaborators or partners (requires your permission)

  • Including your case study in research or publications (requires your consent and will be anonymized unless you agree otherwise)

Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. This may include:

  • Statistical data about program completion rates

  • General demographic information about our client base

  • Anonymized career outcome trends

  • Research and analytics based on aggregated client data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.


4. TRACKING TECHNOLOGIES AND COOKIES

What Are Cookies?

Cookies are small data files placed on your device when you visit a website. We use cookies and similar tracking technologies to:

  • Remember your preferences and settings

  • Understand how you use our Services

  • Improve your user experience

  • Provide personalized content

  • Analyze website performance

  • Measure marketing campaign effectiveness

Types of Cookies We Use

Essential Cookies:

  • Required for the Services to function properly

  • Enable core functionality like security, account access, and payment processing

  • Enable webinar registration and access

  • Cannot be disabled

Functional Cookies:

  • Remember your preferences and choices

  • Provide enhanced features and personalization

  • Remember your language and region preferences

  • Improve user experience

Analytics Cookies:

  • Help us understand how visitors use our Services

  • Collect information about page views, traffic sources, and user behaviour

  • Track webinar registration and attendance

  • Enable us to improve our Services and content

Marketing Cookies:

  • Track your browsing activity across websites

  • Used to deliver relevant advertisements

  • Measure advertising campaign effectiveness

  • Support retargeting efforts

  • Track conversions from marketing campaigns

Third-Party Cookies

We use third-party services that may place cookies on your device, including:

  • Google Analytics (website analytics)

  • Facebook Pixel (marketing and retargeting)

  • LinkedIn Insights (professional network analytics)

  • Webinar platforms (Zoom, WebinarJam, or similar)

  • Email marketing platforms

  • Other marketing and analytics platforms

These third parties have their own privacy policies governing their use of information.

Your Cookie Choices

Browser Controls: Most browsers allow you to:

  • View and delete cookies

  • Block all cookies

  • Receive a warning before a cookie is stored

  • Delete cookies automatically when you close your browser

Please note that blocking or deleting cookies may impact your experience, and some features may not function properly (including webinar access and registration).

Opt-Out Options:

Mobile Devices: Some mobile devices may offer settings to control or limit ad tracking. Check your device settings for options like "Limit Ad Tracking" (iOS) or "Opt out of Ads Personalization" (Android).


5. THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites, applications, and services that are not operated by us. This includes:

  • Social media platforms

  • Resource libraries and tools

  • Career development resources

  • Professional networking sites

  • Webinar and video platforms

  • Payment processors

We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of every website you visit and service you use.

When you click on a third-party link, you will be directed to that third party's site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Third-Party Integrations

We may integrate third-party services into our platform, such as:

  • Stripe: Payment processing

  • Zoom or similar platforms: Video conferencing and webinars

  • Google Workspace: Email and productivity tools

  • Calendar applications: Scheduling and appointments

  • Email marketing platforms: Newsletter delivery

Each of these services has its own privacy policy and terms of service. By using our Services, you may also be subject to these third-party terms.


6. DATA RETENTION

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, accounting, or reporting requirements.

Retention Periods

Active Clients:

  • We retain your information while you are actively engaged in our programs or services

After Program Completion:

  • Program materials and assignments: Retained for up to 1 year after program completion to facilitate the 30-day Post-Program Check-in and program improvements

  • Financial records: 7 years (as required by Canadian tax law)

  • Correspondence and communications: Up to 3 years

  • Marketing consent records: Until consent is withdrawn, plus 3 years

  • Testimonials: Retained indefinitely with your explicit consent (may be removed upon request)

Webinar Attendees:

  • Registration information: Up to 2 years after webinar date

  • Webinar recordings: Retained according to webinar-specific policies (communicated at registration)

  • Follow-up communications: Until you unsubscribe from marketing communications

Inactive Clients:

  • If you don't engage with our Services for an extended period (typically 3 years), we may archive or delete your information after notifying you

Legal Holds:

  • Information subject to legal proceedings, investigations, or regulatory requests will be retained until the matter is resolved

Secure Deletion

When we no longer need your information, we securely delete or anonymize it in accordance with applicable laws and our internal policies. Some information may be retained in backup systems for a limited period before being permanently deleted.

You may request deletion of your information at any time by contacting us at [email protected].


7. SECURITY OF YOUR INFORMATION

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, disclosure, alteration, or destruction.

Security Measures

Technical Safeguards:

  • Encryption of data in transit using SSL/TLS protocols

  • Encryption of sensitive data at rest

  • Secure password requirements and storage

  • Regular security assessments and updates

  • Firewall protection and intrusion detection

  • Secure backup systems

  • Access controls and authentication

  • Secure video conferencing and webinar platforms

Organizational Safeguards:

  • Limited access to personal information on a need-to-know basis

  • Confidentiality agreements with all service providers

  • Regular security training for our team

  • Regular security audits and reviews

  • Incident response procedures

  • Vendor security assessments

Physical Safeguards:

  • Secure facilities for any physical records

  • Controlled access to equipment

  • Secure disposal of physical documents

Session Recordings

When coaching sessions or webinars are recorded (with your consent):

  • Recordings are stored securely on encrypted cloud storage

  • Access is limited to authorized personnel only

  • Recordings are deleted after the retention period unless you request continued access

  • You will be notified before any session is recorded

Your Role in Security

You also play an important role in protecting your information:

  • Keep login credentials confidential (if applicable)

  • Use a secure internet connection for coaching sessions

  • Don't share sensitive information via unsecured channels

  • Report suspicious activity immediately

  • Keep your contact information current

Data Breach Response

In the unlikely event of a data breach that poses a real risk of significant harm, we will:

  • Notify affected individuals as required by law

  • Report the breach to the Privacy Commissioner of Canada if required

  • Take immediate steps to contain and remediate the breach

  • Provide information about steps you can take to protect yourself

  • Conduct a thorough investigation and implement additional safeguards

Limitations

No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. We cannot be held responsible for unauthorized access resulting from circumstances beyond our reasonable control.


8. YOUR PRIVACY RIGHTS

Under Canadian privacy law, including PIPEDA, you have certain rights regarding your personal information.

Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with:

  • Confirmation of whether we process your information

  • A copy of your personal information

  • Information about how we use and disclose it

  • Access to your program materials and assignments

Right to Correction

You have the right to request that we correct inaccurate or incomplete personal information. We will make corrections promptly and notify any third parties to whom we disclosed the information (where appropriate).

Right to Withdraw Consent

You may withdraw your consent to our processing of your information at any time, subject to:

  • Legal or contractual restrictions

  • Reasonable notice requirements

Please note that withdrawing consent may affect our ability to provide certain Services to you.

Right to Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format where technically feasible. This includes:

  • Your program assignments and materials

  • Your contact and profile information

  • Your communication history with us

Right to Object

You may object to:

  • Processing of your information for direct marketing purposes

  • Use of your testimonial or success story in marketing materials

Right to Deletion

You may request that we delete your personal information in certain circumstances:

  • It is no longer necessary for the purposes for which it was collected

  • You withdraw consent, and we have no other legal basis for processing

  • You object to processing, and we have no overriding legitimate grounds

  • The information was unlawfully processed

  • Legal obligations require deletion

However, we may retain information when:

  • Required by law (e.g., financial records for 7 years under tax law)

  • Necessary to exercise or defend legal claims

  • Necessary for legitimate business interests that override your rights

  • You have provided explicit consent for ongoing use (e.g., testimonials)

How to Exercise Your Rights

To exercise any of these rights, please contact us by email: [email protected]

We will respond to your request within 30 days or as otherwise required by applicable law. We may request additional information to verify your identity before processing your request.

Right to Complain

If you believe we have not addressed your privacy concerns adequately, you have the right to file a complaint with:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: https://www.priv.gc.ca

You may also contact your provincial privacy commissioner if applicable.


9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track ("DNT") feature or setting that signals your privacy preference not to have data about your online browsing activities monitored and/or collected.

At this time, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.


10. CHILDREN'S PRIVACY

Our Services are not intended for individuals under the age of 18 ("Minors"). We do not knowingly collect personal information from Minors.

If you are a parent or guardian and you believe your child has provided us with personal information, please contact us immediately at [email protected]. We will take steps to delete such information from our systems.

If we become aware that we have collected personal information from a Minor without verification of parental consent, we will take steps to remove that information from our servers.


11. INTERNATIONAL DATA TRANSFERS

Data Storage and Processing Locations

Your information may be transferred to, stored, and processed in:

  • Canada

  • United States

  • Other countries where our service providers operate

Please note: The privacy laws in these countries may differ from the laws in your jurisdiction. We take appropriate steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it.

Safeguards for International Transfers

When we transfer personal information outside of Canada, we:

  • Ensure the recipient country provides substantially similar privacy protections

  • Use contractual protections such as Standard Contractual Clauses

  • Obtain your consent when required

  • Comply with PIPEDA requirements for international transfers

United States

Some of our service providers are located in the United States (including video conferencing platforms, webinar services, payment processors, and cloud storage providers). By using our Services, you acknowledge that your information may be transferred to and stored in the United States, where it may be subject to access by law enforcement and national security authorities under U.S. law.

Your Consent

By using our Services and providing your information, you consent to the transfer of your information to these countries as described in this Privacy Policy.


12. EMAIL AND SMS COMMUNICATIONS

We may send you various types of communications as described below. You have control over which communications you receive.

Transactional Communications

We will send you transactional emails and SMS messages that are necessary for the Services, including:

  • Discovery call and coaching session confirmations

  • Session reminders

  • Program enrollment confirmations

  • Payment receipts and invoices

  • Webinar registration confirmations and access links

  • Important service updates

  • Responses to your inquiries

  • Program materials and resources

  • 30-day Post-Program Check-in scheduling (when applicable)

You cannot opt out of transactional communications as they are necessary to provide the Services.

Marketing Communications

With your consent, we may send marketing communications, including:

  • Newsletters with career development tips

  • Educational content and resources

  • Program announcements

  • Webinar invitations

  • Special offers and promotions

  • Success stories and testimonials

Your Communication Preferences

Email: You can opt out of marketing emails by:

  • Clicking "unsubscribe" at the bottom of any marketing email

  • Contacting us at [email protected]

  • Replying to any marketing email with "unsubscribe."

SMS/Text Messages: You can opt out of text messages by:

  • Replying "STOP" to any text message

  • Contacting us at [email protected]

  • Notifying us during a coaching session

Please allow up to 10 business days for your preferences to be updated in our systems.

Anti-Spam Compliance (CASL)

We comply with Canada's Anti-Spam Legislation (CASL). We will:

  • Only send commercial electronic messages with your consent (express or implied)

  • Clearly identify ourselves as the sender

  • Provide our contact information

  • Include an unsubscribe mechanism in all marketing messages

  • Honour unsubscribe requests promptly (within 10 business days)

Consent Records

We maintain records of:

  • How and when you provided consent

  • The content of the consent

  • When you withdrew consent

  • Your communication preferences


13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

  • Changes in our practices

  • Changes in applicable laws

  • New features or services

  • Feedback from clients or regulators

Notification of Changes

How We Notify You:

  • We will update the "Last updated" date at the top of this Privacy Policy

  • For material changes, we will provide prominent notice by:

    • Posting a notification on our website

    • Sending an email to the address associated with your account (for active clients)

    • Displaying a notice when you log in or visit our website

    • In some cases, obtaining your renewed consent

Your Continued Use: Your continued use of the Services after we post changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue using the Services and may request deletion of your information.

Review Recommendations

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.


14. CONTACT US

If you have questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us:

Foster Consulting Incorporated
Operating as FC Congruent
Privacy Officer

Email: [email protected]

Website: fccongruent.com


Response Time

We will respond to your inquiry within 30 days or as otherwise required by applicable law.


Privacy Complaints

If you have a complaint about how we handle your personal information:

  1. Contact us first: We want to resolve your concerns directly. Please contact our Privacy Officer using the information above.

  2. Escalate if needed: If you are not satisfied with our response, you may file a complaint with:

Office of the Privacy Commissioner of Canada, or

Information and Privacy Commissioner of Ontario (for Ontario-specific matters)

END OF PRIVACY POLICY


APPENDIX: KEY DEFINITIONS

PIPEDA: Personal Information Protection and Electronic Documents Act - Canada's federal privacy law for private-sector organizations.

CASL: Canada's Anti-Spam Legislation - regulates commercial electronic messages.

Personal Information: Information about an identifiable individual, including name, email, phone number, and other data that can identify you.

Consent: Your voluntary agreement to the collection, use, and disclosure of your personal information.

Express Consent: Consent that is clearly and explicitly given, either verbally or in writing.

Implied Consent: Consent that is inferred from your actions or inaction.

Cookies: Small text files stored on your device by websites you visit.

De-identified Information: Information that has been modified so it can no longer identify a specific individual without additional information.

Service Providers: Third-party companies or individuals that we engage to perform services on our behalf.

Contributions: Content you create and submit during coaching programs, including assignments, worksheets, and personal reflections.