Privacy Policy

PRIVACY STATEMENT

Effective Date: May 7, 2026

Last Updated: May 7, 2026

IMPORTANT: This Privacy Statement describes how we collect, use, and share your personal information — including your phone number, email address, and name — and explains your right to opt out of marketing communications at any time. Please read it carefully.

This Privacy Statement describes how Refrigeration Mentor Inc. (“Company,” “we,” “us,” or “our”), a corporation incorporated under the laws of Ontario, Canada, collects, uses, discloses, and protects your personal information when you visit https://refrigerationmentor.com, use our services, or communicate with us by phone, email, or SMS/text message — including as part of our lead generation, sales, and marketing activities.

We are committed to protecting your privacy in compliance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5), applicable provincial privacy laws, and, where applicable, U.S. state privacy laws including the California Consumer Privacy Act (CCPA/CPRA). By using our Services, you agree to the practices described in this Statement.

You are not required to provide us with personal information. If you do not wish to provide it, please do not submit it and avoid interactions that request it. Not providing information may limit your ability to access certain Services.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly:

  • Contact details: full name, email address, phone/mobile number, mailing address
  • Account credentials: username and password
  • Payment details: credit/debit card information and billing address (handled securely by our payment processors — we do not store full card numbers)
  • Communications: messages, inquiries, survey responses, and support requests
  • Course and enrollment information
  • Communication preferences: opt-in choices for email, SMS, and phone contact
  • Lead form submissions: information submitted through any form, landing page, lead magnet, free resource download, webinar registration, or paid advertisement
  • Feedback, testimonials, reviews, photos, and videos you voluntarily share with us

1.2 Information Collected Automatically:

  • Device and browser data: IP address, browser type, operating system, device identifiers
  • Usage data: pages visited, time on site, links clicked, referring URLs, session duration
  • Cookies and tracking technologies (see Section 6)
  • Approximate geographic location derived from IP address

1.3 Information from Third Parties:

  • Social media platforms if you connect accounts or engage with our content
  • Analytics providers (e.g., Google Analytics, Meta Pixel)
  • Payment processors and financial institutions
  • CRM, marketing automation, and SMS platform providers
  • Lead generation partners, paid advertising platforms, and referral sources where you consented to share your information

2. HOW WE USE YOUR INFORMATION

2.1 Service Delivery:

  • Process enrollments, purchases, and account registrations
  • Provide access to courses, materials, and member areas
  • Process and fulfill orders and transactions
  • Provide customer support and respond to inquiries

2.2 Marketing and Sales Communications:

  • Send transactional emails (receipts, account updates, password resets)
  • Send marketing and promotional emails to individuals who have provided CASL-compliant consent
  • Send SMS/text messages to individuals who have opted in
  • Make outbound telephone calls to individuals who have provided consent and are not on the National DNCL
  • Follow up with leads who have submitted contact information through our forms, funnels, ads, or lead magnets
  • Deliver lead nurture sequences via email, SMS, and phone based on your opt-in and engagement

2.3 Analytics and Improvement:

  • Analyse how users interact with our website and courses
  • Improve content, user experience, and platform performance
  • Monitor and prevent fraud, abuse, and security threats
  • Conduct product development and testing

2.4 Feedback and Testimonials:

  • Use voluntarily submitted feedback, testimonials, success stories, photos, and reviews in our marketing and promotional materials as described in Section 8 of our Terms of Service

2.5 Legal and Compliance:

  • Comply with PIPEDA, CASL, CRTC rules, applicable U.S. state privacy laws, and other applicable legislation
  • Enforce our Terms of Service and other agreements
  • Respond to legal requests, regulatory inquiries, or court orders
  • Protect our rights, property, and the safety of our users

3. LEGAL BASIS FOR PROCESSING

3.1 CASL Consent Framework

Before sending Commercial Electronic Messages (CEMs), we obtain your consent as required by CASL. Express consent: you actively opt in (e.g., checking an opt-in box, texting a keyword). Implied consent: arises from a purchase within the past 2 years, a written inquiry within the past 6 months, or conspicuous publication of contact information without a non-solicitation statement. We maintain consent records for a minimum of 5 years.

3.2 PIPEDA — Legitimate Purposes

We process personal information only for purposes a reasonable person would consider appropriate in the circumstances, in accordance with PIPEDA’s accountability and purpose limitation principles.

3.3 GDPR Legal Bases (EEA/UK Users)

For individuals in the EU/EEA, UK, or Switzerland, we process personal data on the bases of: Consent (direct marketing, cookies); Contract performance (service delivery); Legitimate interests (analytics, security, post-purchase communications); and Legal obligation (regulatory compliance).

3.4 U.S. Users

For U.S.-based users, we process personal information for the business purposes described in this Statement. We do not sell your personal information. Where applicable U.S. state law governs our processing of your data, we comply with those requirements including the CCPA/CPRA for California residents.

4. SMS, EMAIL, AND TELEPHONE COMMUNICATIONS

4.1 SMS / Text Messages

If you have opted in by submitting your number on a form and checking an opt-in box, texting a keyword, or otherwise affirmatively consenting, you consent to receive recurring automated and manually composed marketing, sales, nurture, and informational text messages from Refrigeration Mentor Inc..

Message frequency: Varies — you may receive multiple messages per week. Message and data rates may apply. Consent is not a condition of any purchase.

To opt out: Reply STOP to any message. You will receive one final confirmation. To resubscribe: reply START or re-opt in on our website. For help: reply HELP or contact legal@refrigerationmentor.com.

We retain a record of your SMS consent — including opt-in date, method, phone number, and confirmation — for a minimum of 5 years. We comply with CASL, CRTC Unsolicited Telecommunications Rules, EU/UK GDPR and ePrivacy Directive, and all applicable telecommunications laws.

4.2 Email Communications

We send marketing emails to individuals with express or implied CASL consent. Every commercial email clearly identifies Refrigeration Mentor Inc., includes an accurate mailing address, and contains a visible, functional unsubscribe link. Opt-out requests are processed within 10 business days as required by CASL. Opting out of marketing emails does not affect transactional messages related to active accounts or purchases.

We comply with CASL, EU/UK GDPR and ePrivacy Directive, and all other applicable anti-spam laws.

4.3 Telephone / Outbound Calling

Where you have provided a phone number and consented to be contacted, Refrigeration Mentor Inc. or its authorized representatives may call you for sales, follow-up, support, or marketing purposes. We comply with CRTC rules: calls only between 9:00 AM and 9:30 PM local time, not on statutory holidays, after checking the National Do Not Call List (DNCL). To revoke consent: contact us at legal@refrigerationmentor.com or in writing. Revocations honoured within 14 days.

4.4 Lead Follow-Up and CRM

When you submit contact information through any form, landing page, lead magnet, webinar registration, paid ad, or inquiry, your information is entered into our CRM and marketing automation systems for follow-up by SMS, email, and/or phone. You may request removal from specific follow-up sequences at any time by contacting us.

5. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, or trade your personal information to third-party data brokers or marketing companies. We may share it in the following limited circumstances:

5.1 Service Providers. We share data with trusted vendors under written data processing agreements, strictly for the purpose of delivering our services. These include:

  • Payment processors (e.g., Stripe, PayPal)
  • Email marketing platforms (e.g., ActiveCampaign, Mailchimp, Klaviyo)
  • SMS messaging platforms
  • CRM and sales automation tools
  • Video hosting and course delivery platforms (e.g., Kajabi, Teachable)
  • Analytics providers (e.g., Google Analytics, Meta Pixel)
  • Cloud hosting and infrastructure providers

All service providers are contractually bound to protect your data and use it only as directed by us.

5.2 Affiliates. We may share your information with affiliated companies within our corporate family, who will use it in accordance with this Privacy Statement.

5.3 Business Transfers. In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

5.4 Legal Requirements. We may disclose information where required by law, regulation, court order, or lawful government request, or to protect safety and enforce our rights.

5.5 With Your Consent. We may share information in other circumstances with your prior consent.

6. COOKIES AND TRACKING TECHNOLOGIES

We use cookies, pixel tags, web beacons, and similar technologies including:

  • Essential cookies: Required for website functionality. No consent required.
  • Analytics cookies: Help us understand how visitors use our site (e.g., Google Analytics)
  • Advertising/marketing cookies: Used to deliver relevant advertising and measure campaign performance (e.g., Meta Pixel, Google Ads)
  • Preference cookies: Remember your settings

You can manage or withdraw consent to non-essential cookies through our cookie consent tool or browser settings. For EU/UK/EEA users, we obtain prior informed consent for non-essential cookies per GDPR and ePrivacy Directive requirements. Our website is configured to recognize the Global Privacy Control (GPC) signal. When your browser sends a GPC signal, we will treat this as a valid opt-out request from the sale or sharing of personal information where required by applicable law (including CCPA for California residents).

Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout

7. DATA RETENTION

  • Account and profile data: Duration of account plus 3 years after closure
  • Purchase and transaction records: 7 years (Income Tax Act requirements)
  • CASL consent records: Minimum 5 years from date of consent or last contact
  • Lead inquiry and CRM records: Up to 3 years from last interaction
  • Customer support records: 3 years from resolution
  • Log and usage data: 12-24 months

When personal information is no longer required, we securely delete or anonymize it.

8. DATA SECURITY

We implement commercially reasonable technical, administrative, and physical safeguards including SSL/TLS encryption, data encryption at rest, role-based access controls, regular security assessments, employee privacy training, and data processing agreements with all service providers.

No electronic transmission or storage method is 100% secure. We cannot guarantee absolute security.

In the event of a privacy breach involving personal information that creates a real risk of significant harm, we will notify affected individuals and report to the Office of the Privacy Commissioner of Canada as soon as feasible, as required by PIPEDA’s mandatory breach reporting requirements. For GDPR-subject users, we will also notify relevant supervisory authorities within 72 hours where required.

9. YOUR RIGHTS AND CHOICES

9.1 All Users:

  • Opt out of marketing emails: Click ‘Unsubscribe’ in any email or contact legal@refrigerationmentor.com
  • Opt out of SMS: Reply STOP to any message
  • Request to be added to our internal Do Not Contact list for phone calls
  • Request a summary of personal information we hold about you

9.2 Canadian Residents — PIPEDA and Provincial Privacy Laws:

  • Right to access personal information we hold about you
  • Right to correct inaccurate or incomplete personal information
  • Right to withdraw consent (subject to legal and contractual restrictions)
  • Right to know the purposes for which your data is collected and used
  • Right to file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca or 1-800-282-1376)

Quebec residents are additionally protected under Law 25 (Act respecting the protection of personal information in the private sector), which provides rights including de-indexation and data portability. We respond to PIPEDA requests within 30 days.

9.3 U.S. Residents — State Privacy Laws:

For U.S. residents, depending on your state, you may have the following rights:

  • Right to Know: Request information about what personal information we collect, use, share, or sell
  • Right to Delete: Request deletion of your personal information, subject to exceptions
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Opt-Out: We do not sell personal information. Where sharing for cross-contextual behavioral advertising constitutes a ‘sale’ or ‘sharing’ under your state’s law, you may opt out by enabling the GPC signal in your browser or contacting us
  • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

California residents: We comply with the CCPA/CPRA. Submit requests at legal@refrigerationmentor.com. We respond within 45 days. You may authorize an agent to make requests on your behalf with written authorization. We do not use or disclose sensitive personal information beyond the purposes specified in CCPA Regulations Section 7027(m).

Other U.S. states (Virginia, Colorado, Connecticut, Texas, and others with enacted privacy laws): We will honor your applicable rights upon verification of your identity. Contact us at legal@refrigerationmentor.com.

9.4 EEA, UK, and Swiss Users — GDPR / UK GDPR:

  • Right of Access, Rectification, Erasure, Restriction, Portability, and Objection
  • Right to withdraw consent at any time without affecting prior lawful processing
  • Right to lodge a complaint with your local Data Protection Authority

We respond to GDPR requests within 30 days (extendable to 90 days for complex requests with notice).

9.5 Australian Residents — Privacy Act 1988:

  • Right to access and correct personal information we hold about you
  • Right to complain to the Office of the Australian Information Commissioner (oaic.gov.au)

9.6 Brazilian Residents — LGPD:

  • Rights of access, correction, anonymization, deletion, portability, and opposition to processing
  • Right to lodge a complaint with the ANPD

To exercise any right: email legal@refrigerationmentor.com. We may need to verify your identity before processing your request.

10. CHILDREN’S PRIVACY

Our Services are directed at adults 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn we have inadvertently collected such information, we will promptly delete it. Contact us at legal@refrigerationmentor.com if you believe we hold data from a minor.

11. INTERNATIONAL DATA TRANSFERS

Refrigeration Mentor Inc. is based in Brantford, Ontario, Canada. Your personal information is primarily stored and processed in Canada. Canada has been recognized by the European Commission as providing an adequate level of data protection for commercial organizations under PIPEDA (GDPR Article 45 adequacy decision), which facilitates transfers from the EU/EEA to Canada.

For U.S. users: your information is processed in Canada, which provides strong privacy protections under PIPEDA. By using our Services, you consent to this transfer.

Where we use service providers outside Canada, we ensure appropriate safeguards including Standard Contractual Clauses (SCCs), UK International Data Transfer Agreements (IDTAs), and contractual data processing protections.

12. ACCESSIBILITY

We are committed to making our website and this Privacy Statement accessible in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). If you require this Statement in an accessible format, contact us at legal@refrigerationmentor.com.

13. THIRD-PARTY LINKS

Our Services may link to third-party websites. This Statement does not apply to those sites. We are not responsible for third-party privacy practices. Review their privacy policies before providing personal information.

14. CHANGES TO THIS STATEMENT

We may update this Privacy Statement periodically. We will update the “Last Updated” date and, for material changes, provide notice by email and/or a prominent website notice. We will obtain fresh consent where required by applicable law.

15. CONTACT US — PRIVACY OFFICER

Privacy Officer, Refrigeration Mentor Inc., PO Box 25111, Brantford, Ontario, Canada

Email: legal@refrigerationmentor.com

Website: https://refrigerationmentor.com

Canada — Office of the Privacy Commissioner: www.priv.gc.ca or 1-800-282-1376

EU/UK — List of data protection authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_en