Privacy Policy

Effective Date: May 31, 2026
Last Updated: May 31, 2026

At First Class Leaders, trust is the runway everything else takes off from. You share information with us when you visit our website, join our community, take an assessment, work with us as a coaching client, or sign up for our content. This policy explains, in plain language, what we collect, why we collect it, how we store and protect it, who we share it with, and the rights you have over it. We wrote it to be clear rather than clever. If anything is unclear, reach out and we will explain it.

First Class Leaders (“First Class Leaders,” “FCL,” “we,” “us,” or “our”) is the operating name of 13334007 Canada Inc., a corporation registered in Canada and located at 96 Young Street, St. Jacob’s, ON, N0B 2N0. We provide aviation leadership coaching, workshops, assessments, community membership, digital tools, and related content and services. For the purposes of this policy, 13334007 Canada Inc. is the organization responsible for the personal information described here.

1. Scope of This Policy

This policy applies to personal information we collect through our websites, landing pages, and funnels, our online community and membership spaces, our coaching engagements, workshops, and facilitation sessions, our assessments and diagnostic tools, our email lists and newsletters, our podcast and related media, our software, applications, and AI assisted tools, our social media pages and direct messaging, and any other interaction where you provide information to us.

It applies to clients, prospective clients, community members, workshop participants, newsletter subscribers, podcast guests and listeners, website visitors, and contractors or vendors who work with us.

2. The Law We Follow

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the federal private sector privacy law of Canada, and the ten fair information principles it sets out.

Depending on where you live or work, additional rules may also apply to your information, and we honour them where they do:

• Quebec Law 25 for residents of Quebec

• Canadian anti spam legislation, known as CASL, which governs the commercial electronic messages we send

• The General Data Protection Regulation (GDPR) for individuals located in the European Economic Area or the United Kingdom

• The California Consumer Privacy Act and California Privacy Rights Act for residents of California

• Other applicable provincial, state, or national privacy laws

Where more than one rule applies to the same information, we aim to meet the higher standard.

3. The Information We Collect

We collect only the information we reasonably need to deliver our services, run our business, and communicate with you. The categories below describe what we may collect, though not every category applies to every person.

• Identity and contact information: your name, email address, phone number, mailing address, company or operator name, job title or rank, and the aircraft type or fleet you fly.

• Professional and aviation background: your role, experience level, career stage, training history, leadership challenges, and goals.

• Assessment and diagnostic information: your responses, results, and reports from tools such as our Leadership Gap Assessment, our Pilot Reputation Assessment, our Needs and Values Assessment, and DiSC Catalyst profiles. Some of this information reflects personality style, behaviour preferences, and self reported beliefs.

• Coaching and session information: notes, reflections, goals, action items, beliefs, wins, and challenges discussed during coaching sessions and workshops. Because coaching can touch on personal and emotional topics, we treat this information as sensitive. See Section 10.

• Payment and billing information: billing name and address, the products or services you purchased, transaction history, and the limited payment details required to process a payment. We do not store full payment card numbers ourselves. Payments are processed by our payment service providers.

• Community and engagement information: your profile, posts, comments, messages, event attendance, and activity within our online community and membership spaces.

• Communications: the content of emails, direct messages, contact form submissions, support requests, your responses to our newsletters and campaigns, and your contact preferences and consent records.

• Technical and usage information: IP address, device and browser type, operating system, pages visited, links clicked, referring source, time on page, and similar analytics data collected automatically through cookies and tracking tools. See Section 6.

• Podcast and media information: if you appear as a guest, the information you provide for the recording and its promotion. If you are a listener, limited analytics provided by our hosting and distribution platforms.

• Vendor and contractor information: for people who work with or for us, this may include business and tax information such as a completed W8BENE form, banking details for electronic funds transfer, contracts, and related records.

4. How We Collect Your Information

We collect personal information in three main ways:

• Directly from you, when you fill out a form, book a call, register for a workshop, take an assessment, join the community, purchase a service, subscribe to our content, message us, or sign a contract.

• Automatically, through cookies and similar technologies when you use our websites and digital tools.

• From third parties, such as our service providers, assessment platforms, payment processors, analytics tools, social media platforms, and, in a business context, the operator or company that arranges a workshop or coaching engagement for its team.

5. Why We Use Your Information

We use personal information to provide our coaching, workshops, facilitation, assessments, community, and digital tools, to deliver assessment results, session notes, follow up materials, and personalized guidance, to process payments and keep financial and tax records, to communicate with you and provide support, to send newsletters, content, offers, and updates where you have consented to receive them, to run, secure, maintain, and improve our websites, funnels, community, and applications, to understand how people use our services so we can improve them, to manage our relationships with vendors, contractors, and business partners, and to protect our business, enforce our agreements, and meet legal and regulatory obligations.

We will not use your personal information for a new purpose that is materially different from the ones above without first obtaining your consent, unless the law permits or requires it.

6. Cookies and Tracking Technologies

Our websites and funnels use cookies, pixels, and similar technologies to make pages work, remember your preferences, measure performance, and support our marketing. These tools may collect technical and usage information as described in Section 3. We may use essential cookies that are necessary for the site to function, analytics tools that help us understand traffic and engagement, and marketing and tracking pixels that help us measure campaigns and reach relevant audiences.

You can control cookies through your browser settings, and you can opt out of many marketing tools through the settings offered by the relevant platform. Turning off some cookies may affect how parts of our site work. Where the law requires it, we will ask for your consent before placing nonessential cookies.

7. How and With Whom We Share Information

We do not sell your personal information. We share personal information only in the following situations:

• Service providers. We work with trusted companies that perform services on our behalf, and we share information with them only as needed to deliver those services. These providers are required to protect your information and use it only for the purposes we specify. They include categories such as customer relationship management, website, and funnel hosting, online community and membership hosting, payment processing, assessment and psychometric platforms, email delivery and marketing, analytics and performance measurement, podcast hosting and distribution, scheduling, document signing, and file storage, and banking and accounting. A current list of the specific providers we use is available on request.

• Business clients. When an operator, employer, or company arranges coaching or a workshop for its people, we may share limited information with that organization, such as attendance and high level program outcomes. We do not share the private contents of an individual coaching conversation with an employer. See Section 10.

• Legal and protective reasons. We may disclose information where required by law, in response to a valid legal request, to protect our rights, property, or safety, or that of others, and in connection with the sale or reorganization of our business, in which case privacy commitments will continue to apply.

• With your direction. We share information with others when you ask us to or otherwise direct us to do so.

8. Where Your Information Is Stored and Cross Border Transfers

Some of our service providers store and process information on servers located outside Canada, including in the United States. When information is handled outside Canada, it may be subject to the laws of the country where it is stored, including lawful access by courts, law enforcement, and government authorities in that country. We take reasonable steps to ensure that any provider handling your information offers a comparable level of protection to what is required in Canada. By using our services and providing your information, you understand that your information may be processed and stored outside your province or country. If you would like more information about how cross border handling applies to your information, contact us.

9. Consent

In most cases we rely on your consent to collect, use, and disclose your personal information. Express consent is obtained where the information is sensitive or where the law requires it, for example before sending you commercial electronic messages. Implied consent may apply where the purpose is obvious and you voluntarily provide the information, for example when you email us a question and we use your email to reply.

You can withdraw your consent at any time, subject to legal and contractual limits and reasonable notice. Withdrawing consent for certain uses may mean we can no longer provide some of our services to you. You can unsubscribe from our marketing emails at any time using the unsubscribe link in the message or by contacting us.

10. Coaching Confidentiality

We understand that coaching often involves personal, professional, and emotional topics, and that trust is essential. We treat the contents of individual coaching sessions as confidential. Session notes and reflections are used to support your growth and to prepare for your sessions. We do not disclose the private contents of your coaching conversations to your employer or operator, even where that organization is paying for the engagement, except with your consent or where disclosure is required by law. Where an organization sponsors a program, we may share only limited information such as participation and general program outcomes, agreed in advance.

There are narrow limits to confidentiality. We may disclose information without consent where the law requires it or where there is a serious and imminent risk to the safety of you or another person. We will limit any such disclosure to what is necessary.

11. How Long We Keep Your Information

We keep personal information only for as long as it is needed for the purposes described in this policy, or for as long as required by law, contract, tax rules, or legitimate business needs. When information is no longer required, we take reasonable steps to securely destroy, erase, or anonymize it. Retention periods vary by the type of information and the reason we hold it. For example, financial and tax records are kept for the periods required by Canadian law, while marketing contact records are kept until you unsubscribe or ask us to remove them, subject to our record keeping needs.

12. How We Protect Your Information

We use reasonable physical, technical, and administrative safeguards to protect personal information against loss, theft, and unauthorized access, use, disclosure, copying, or modification. These measures include access controls, the use of reputable service providers, password protection, and limiting access to information to those who need it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach of security safeguards that creates a real risk of significant harm, we will notify affected individuals and the appropriate authorities as required by law, and we will keep records of breaches as PIPEDA requires.

13. Your Privacy Rights

Subject to applicable law, you have the right to access the personal information we hold about you and receive an account of how it has been used and disclosed, to correct information that is inaccurate or incomplete, to withdraw consent to our use of your information subject to legal and contractual limits, to unsubscribe from our marketing communications at any time, and to ask questions about our privacy practices.

Depending on where you live, you may also have additional rights, such as the right to request deletion or portability of your information, or to object to certain processing. We honour the rights that apply to you under the laws listed in Section 2. To exercise any of these rights, contact us using the details in Section 16. We will respond within the time required by law. We may need to verify your identity before acting on a request. There is generally no charge to access your own information, though in limited cases a minimal cost recovery fee may apply, and we will tell you in advance if so.

14. Children’s Privacy

Our services are intended for adults and aviation professionals. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us and we will take reasonable steps to delete it.

15. Links to Other Sites and Changes to This Policy

Our websites, emails, and content may contain links to third party websites, tools, and platforms that we do not control. This policy does not apply to those sites, and we encourage you to review their privacy policies before providing your information.

We may update this policy from time to time to reflect changes in our practices, services, or the law. When we make material changes, we will update the effective date at the top of this page and, where appropriate, notify you. Your continued use of our services after an update means you accept the revised policy. We encourage you to review this page periodically.

16. How to Reach Us and How to Complain

If you have a question, concern, or complaint about your privacy or how we handle your information, please contact us first. We take privacy concerns seriously and will work with you to resolve them.

First Class Leaders (13334007 Canada Inc.)
96 Young Street, St. Jacob’s, ON, N0B 2N0
Email: kyle@firstclassleaders.com

If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner of Canada, the federal regulator that oversees PIPEDA. Residents of Quebec may also contact the Commission d’accès à l’information du Québec. Individuals in other regions may contact the privacy authority that applies to them.

This policy is governed by the laws of the Province of Ontario and the applicable federal laws of Canada.

First Class Leaders. Take the Lead.