The Debut Co.

Privacy Notice

Last modified: February 1, 2024

INTRODUCTION

THE DEBUT COLLECTIVE INCORPORATED (the “Company” or “We”) respect your privacy and are committed to protecting it by complying with this Privacy Notice (“Notice”). You may provide Personal Information to us on or through The Debut Co website (the “Website”), through electronic communication or through our platform (“Debut Platform”). Protecting your privacy and earning your trust is at the heart of what we do, and it is important to us that each individual has a personal experience.

This Notice describes:

• How we collect, use, disclose, and protect the Personal Information of our clients, potential clients, Debut Platform users, and Website users (“you”).
• Describes the types of information we may collect from you or that you may provide when you visit the Website and/or Debut Platform.
• Our practices for collecting, using, maintaining, protecting, disclosing, and deleting that information.

We will only use your Personal Information in accordance with this Notice unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

The Website and/or Debut Platform may include links to third-party websites or tools, such as links to Thinkific (www.thinkific.com), our learning management platform, plug-ins, payment processor, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy notices and we do not accept any responsibility or liability for their activities. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit. This Notice DOES NOT apply to information that you provide or is collected by any third party.

Please read this Notice carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, you should not use our Website or the Debut Platform. Should you decide not to access the Website or Debut Platform and not provide us with your information, this may result in us not being able to provide you with the same level of service. By accessing or using the Website or Debut Platform, you indicate that you understand, accept, and consent to the practices described in this Notice. This Notice may change from time to time (see Changes to Our Privacy Notice below). Your continued use of this Website or Debut Platform after we make changes indicates that you accept and consent to those changes, so please check this Notice periodically for updates.

1. INFORMATION WE COLLECT ABOUT YOU

When you interact with our Website or the Debut Platform, we may collect and use several types of information from and about you, including:

• Personal Information, that we can reasonably use to directly or indirectly identify you, such as your name, e-mail address, username, profile picture, gender, purchase information, including amount paid, your address, your employment information and other billing information (but never your complete card number, which we do not collect), information you voluntarily share on the Debut Platform related to your daily routine, physical or mental health, which you may disclose on the Debut Platform through the use of personal sessions, surveys or assessments, IP address and any other identifier we may use to contact you (“Personal Information”).
• Sensitive Information, that may be of a sensitive nature provided by you during your journey, including your pregnancy status (“Sensitive Information”)
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature or utilizing the Debut Platform and its features.

2. HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect information about:

• Directly from you when you voluntarily provide us with information: We collect Personal Information from you when you voluntarily provide us with that information, for example, when you communicate with us, when you interact on the Debut Platform or Website, or when you communicate with Debut’s coaches.
• Through automated technologies or interactions: We collect information that is non-identifiable, through usage information collected via the Debut Platform and Website, which includes your IP address, type of device you used, and your interactions on the Debut Platform or Website. The information automatically collected does not reveal your identity.
• Through third parties: If you are a user of our services through your employer or benefits provider, we may have received your name and email address through that third party.

Cookies and Other Technologies:

Similar to other websites you visit, when you visit our Website or Debut Platform, we may send your browser one or more cookies, which are small files containing a string of characters. The cookies are downloaded onto your computer that uniquely identifies your browser. Generally, we use cookies to improve the quality of our services by storing user preferences and tracking user trends.

How to Manage Cookies:

Although most browsers are set up to accept cookies, you can reset your browser to reject cookies. You will need to follow the instructions contained in your browser’s help file (usually located within the “Help,” “Tools,” or “Edit” settings). If you choose to disable cookies, some of the features and services on our Website or Debut Platform will not function properly.

3. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us for the following purposes:

• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts with you or our clients including for billing and collection or to comply with legal requirements.
• To provide our clients with aggregated and de-identified reports that reveals how our Debut Platform is being used by users they referred to our services.
• To register you on the Debut Platform.
• To track your progress on the Debut Platform and curate content to empower you.
• To respond to technical support requests.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To improve our Website, the Debut Platform, products or services, marketing, or customer relationships and experiences.
• To measure usage and develop new features on the Debut Platform.
• To allow you to participate in interactive features, social media, or similar features on our Website and Debut Platform.
• To investigate and prevent fraud, criminal activity, unauthorized access or use of services, breaches of terms and policies, and other wrongful or unlawful behaviour;
• To comply with legal obligations and legal processes and to protect our rights, privacy, safety, or property, and/or that of our affiliates, partners, or other third parties; and
• In accordance with or as may be required by law (e.g., the disclosure of Personal Information to law enforcement).
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

4. DISCLOSURE OF YOUR INFORMATION

We do not sell your Personal Information. There are certain circumstances in which we disclose, transfer or share your Personal Information with third parties. When we do so, we limit the information we share to only what is necessary in accordance with our instructions, and in compliance with appropriate privacy, confidentiality, and security measures. Below are examples of when or with whom your Personal Information may be shared:

• Clients: If your access to our services is facilitated through your employer or benefits provider, we may provide general information about your account to them. Your information is de-identified and aggregated. For example, we may provide your employer or benefits provider with de-identified information about trending habits of participants or the overall number of engaging users on the Platform.
• Service Providers: We disclose Personal Information to select service providers to help us perform functions related to our services. For example, we may use service providers to provide us with administrative, financial, or quality assurance services. These parties are bound by confidentiality and are limited in the way in which they can process, access or store Personal Information based on our instructions. We use Thinkific (thinkific.com) to host the Debut Platform. Please review Thinkific’s Privacy Policy.
• Business Transactions: We may transfer our assets and rights to our services, including information in our services, in the event of a merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. In such a case, you will be provided with notice via communications through the services.
• Legal Requirement: We may also disclose Personal Information if we are required to do so by court order, law or in the good faith belief that such action is necessary to (i) comply with a legal process or obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Website or Platform or the public, (v) protect against legal liability, or (vi) responding to any government or regulatory request (in accordance with applicable law).
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of others.
• Otherwise with your consent.

5. HOW WE PROTECT YOUR INFORMATION

The security of your Personal and Sensitive Information is very important to us. We use physical, electronic, procedural and administrative measures designed to secure your information from misuse, loss, unauthorized access, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or Debut Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Website. Any transmission of information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or Debut Platform.

6. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

7. CHILDREN’S INFORMATION

Our Website and Debut Platform are meant for those individuals who are 16 years old or older. If you have reason to believe that a child under the age of 16 has provided Personal Information to us through our Website or Debut Platform, please contact us at [email protected], and we will endeavour to delete that information.

8. YOUR RIGHTS RELATING TO YOUR PERSONAL INFORMATION

You have the right to:

• Access and correct your Personal Information. It is important that the information we hold about you is accurate and current. Please keep us informed if any of your information changes. Depending on applicable law, you may also have the right to delete your Personal Information.  To exercise your rights, please contact us at [email protected].
• Opt-out of marketing communication. When we send you marketing communications such as emails or newsletters, you may opt out of receiving these communications from us by clicking on the “unsubscribe” or “opt-out” link in the marketing messages we send you.
• Withdraw your consent. You have the right to withdraw your consent to have your Personal Information processed. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal or the processing of your Personal Information for any other lawful grounds other than consent.
• Delete your account. In order to delete your account from the Debut Platform, please contact us at [email protected]. If you delete your content (i.e., user contributions) from the Debut Platform or Website, copies of your content may remain viewable in cached and archived pages or might have been copied or stored by other Website users.

In order to facilitate the above rights, we may request specific information from you to confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

9. STORAGE OUTSIDE OF CANADA

Your information may be used or stored by us or our approved service providers and our corporate affiliates outside of Canada. In this circumstance we require that our service providers and our corporate affiliates safeguard your Personal Information using appropriate security measures and standards. If your Personal Information is used or stored outside of Canada, please note it will also be subject to the laws of the country in which it is used or stored.

10. CHANGES TO OUR PRIVACY NOTICE

Our Website, the Debut Platform or our general practices may change from time to time. If we make any updates to this Notice, we will post an updated version on this page unless the applicable law requires another type of notice. Please review this Privacy Notice from time to time.

11. CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this Privacy Notice and our privacy practices. Please contact us at:

Privacy Officer
The Debut Collective Incorporated
[email protected]

We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Notice, and with applicable privacy laws. To discuss our compliance with this Notice, please contact our Privacy Officer using the contact information listed above.