Privacy Policy


Flex U., LLC and our affiliated entities (including Flex U., LLC) (collectively, “Flex U.,”  “we,” “us,” or “our”) respects the privacy concerns of our customers, the members of Flex U.-powered businesses, and all users of our website, and any other website or mobile application owned, operated, or controlled by us (the “Flex U. Site,” and together with the insights, analytics, and other features we make available through our products and services, is collectively referred to as the “Platform”).  We are committed to protecting and respecting your privacy.  This Privacy Policy (the “Privacy Policy”) and any other documents referred to in it sets forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Product will be processed by us. We are providing this Privacy Policy so that you can better understand how we collect, use, and share information that is gathered using our Platform.

Our privacy practices are subject to the applicable laws of the places in which we do business, so we have added region-specific terms that only apply to customers located in certain geographic regions, or as required by applicable laws. 

This Privacy Policy includes the following sections: 

  • Scope of this Notice
  • Personal Data We Collect and How We Use It
  • Personal Information You Give Use
  • Personal Information We Derive Through Your Use of Our Platform
  • Personal Information We Collect From Third Parties
  • What We Do With Your Personal Information
  • Our Legal Grounds for Processing Your Personal Information
  • Our Sharing of Your Personal Information
  • Publicly Posted Content
  • Data Retention
  • Data Security
  • International Data Transfers
  • Your Privacy Rights and Choices
  • Children’s Data
  • Jurisdiction-Specific Privacy Disclosures
  • Changes to this Notice
  • Contact us

Scope of This Notice

This Privacy Policy describes our practices for collecting, using, maintaining, protecting and disclosing (“processing”) your personal information when you use our Platform, such as when you: 

  • Visit the Flex U. Site and any other sites or applications or mobile applications that link to this Privacy Policy;
  • Create and maintain an account on our Platform;
  • Visit a site residing on the Platform;
  • Make a payment through Flex U;
  • Attend a virtual event or webinar hosted by us, or otherwise engage with our interactive or pre-recorded content;
  • Make a purchase or other transaction with us;
  • Subscribe to or engage with our newsletters or other electronic communications;
  • Interact with our social media pages;
  • Click on our ads posted on third-party sites;
  • Communicate with our customer support representatives or features (including via chat functions, email, text, or phone);
  • Use our Platform; or
  • Anywhere else we collect information from you and refer to this Privacy Policy.

This Privacy Policy also applies to the personal information we collect from third parties about you. 

This Privacy Policy does not apply to 

  • Third-Party Sites. Websites, apps, videos (embedded or direct links), or other content (each a “Linked Site”) to which we link that are not operated by us. Linked Sites have their own personal information collection and use practices, and we are not responsible for those practices. We encourage you to read each Linked Site’s privacy disclosures to understand how your personal information is processed. 
  • Personal Information We Process for Customers. Flex U acts as a processor of personal information for its customers (e.g., Heroes), and others. This Privacy Policy does not apply to the processing of personal information we undertake on the Heroes’ behalf at their direction. These parties’ respective privacy policies or notices govern their collection and use of the personal information for which they are the controller. Any processing of this information that we conduct on behalf of Heroes or partners is governed by the contracts that we have in place with these parties and not this Privacy Policy. Any questions or requests relating to this data collection or processing by Heroes or partners should be directed to those parties.
  • Workforce Members and Candidates. Our processing of the personal information of job applicants/candidates and workforce members is not governed by his policy. That processing is described in our Candidate Privacy Notice.
  • Non-Personal Information. Our processing of information that cannot be linked to an identifiable or identified individual. We may process this data for any legitimate business purpose.

Personal Data We Collect and How We Use It

Personal information (sometimes called “personal data”) is a broadly defined term whose legal definition varies across jurisdictions. When used in this Privacy Policy, “personal information” includes information that is reasonably capable of identifying a particular individual (including through their device) either alone or when combined with information from other sources. 

The personal information we collect about you depends on the nature and context of your interaction with our Flex U and our Platform.  It may also depend on various choices you make about how to use the Platform we offer, the functionality and features you choose or enable, your location, the devices you use to interact with our Platform, and applicable law.  The following describes the personal information we collect about you and the way we collect it. 

Personal Information You Give to Us

We may collect the following categories of personal information you provide to us, including the following: 

  • Your Personal Details. For example, your first and last name, email address, phone number, physical address, job titles, and other contact information you provide. 
  • Account and Other Identifiers. For example, a username, screen name, handle, account ID, assigned user ID, customer number, or similar identifier that can be used to identify a user or account. 
  • User Content. For example, emails and text messages, photos, videos, audio recordings, customer support communications, comments/feedback, and any other content submitted by you. 
  • Survey Data. We may contact some individuals to request participation in a survey or other general research. If you choose to take part in these, you may provide personal information, in or along with your survey responses, or in any other feedback or comments you give us. 
  • Contests, Sweepstakes, and Prize Drawings Data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide personal information, feedback, or comments to enter, or as part of the contest, sweepstakes, or prize drawing.
  • Messages and Email Data. We collect information about you when you send, receive, open, read or otherwise engage with messages, email, or other communications in connection with our Platform, including whether you have opened or acted on those communications.
  • Social Media Content. For example, interactions with our social media pages and content you post on them. If you use a social media provider to register or login to your Flex U account, we will receive your personal information from them. 
  • Other Personal Information You Provide. If you provide us personal information other than that described above, we will collect it and use it for the purposes for which you provide it or other consistent purposes. 
  • Inferences. In certain instances, we may infer personal information about you based on the information you have provided to us or that we have collected about you. 
  • Chat Modules. We may collect certain categories of personal information from you when you use our interactive chat module. By interacting with the chat box, you consent to our collection practices and understand and acknowledge that we may use this data to communicate with you about our Platform.
  • Payment Processing Information. For example, the form of payment, payment card number and details, bank account number, payment service provider, and other payment information you provide.
  • Demographic Information. For example, information that reveals your racial or ethnic origin, religious or philosophical beliefs, union membership, political opinions, or sex life or sexual orientation. 
  • Precise Geolocation. You may choose to grant our Platform permission to access your device’s precise geolocation, which we may use to confirm your address and help us operate or personalize our Platform, including by tagging posts, providing information on or adding information to a map, and helping us show you more relevant content or ads.

Personal Information We Derive Through Your Use of Our Platform

We and our third-party partners use cookies, web beacons, clear GIF, pixels, internet tags, and other similar tracking technologies (collectively, “tracking technologies”) to gather information when you interact with our websites, mobile apps, and email communications. We use some of these tracking technologies to help us optimize and maintain the security of our websites and your account. We also use them for compatible purposes like saving your preferences, fixing errors, and ensuring consistent service of our websites and mobile apps. For additional information on our use of cookies, please visit our Cookie Notice

We permit third parties to use tracking technologies on our websites for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, and provide metrics on advertising effectiveness. The third parties use their technology to provide advertising about products and services tailored to your interests which may appear either on our websites or on other websites.     

The information we collect using these technologies includes: 

  • Device and Browser Identifiers. For example, an assigned user ID, IP address, or similar identifier that can be used to identify your device. 
  • Coarse Location Information. A general approximation of your location that is not based on global position system (GPS) information. 
  • Browsing and Search History. Information about the content you view and searches you make on the Flex U Site. 
  • Website Log and Usage Data. Information related to our pages you viewed, the services and features you used or interacted with, your browser type and details about any links or communications with which you interacted.
  • Advertising Metrics. Information about the advertisements you have viewed on our Website.

Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, our Website(s) currently does not respond to those signals.

Personal Information We Collect From Others

We mostly collect personal information directly from you or based on your interaction with the Flex U Site. However, we also may collect personal information from third-party sources. These include Heroes, your colleagues, employers, business representatives, our Business Services Providers, Marketing and Advertising Providers, government entities, our Flex U affiliates, security services providers, other individuals, social media platforms, and other users of our Platform.

Even if you aren’t a registered user of our Platform, your information might still be collected. Some users may choose to share information about their contacts, including their name, email address, phone number, or other information. Users may also post or comment with personal information about other users.

Flex U.'s uses Google’s Application Programming Interface (API) Services to enable the use of certain Platform features (i.e. use of your Gmail account to calendar events from the Platform’s Coaching feature). Flex U.'s use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The information collected and used with these API services includes personal data such as email addresses, calendar information, and first and last names. Your Google information is used by our system developers to provide or improve user-facing features that are prominent to your user experience.

What We Do with Your Personal Information

We may use your personal information for a variety of reasons. Depending on how you interact with our Platform, these include using personal information: 

  • Delivering Our Platform to you and providing related customer support, communication, and security. 
  • Policy Enforcement, including enforcing our terms of service, acceptable use policies, anti-spam policies, and similar policies. 
  • Advertising & Marketing to send advertisements and marketing material via physical and electronic mail relating to product specials and other promotional events or offers, perform marketing research and data analytics, and perform similar activities.
  • Contextual and Behavioral Targeting to provide contextual customization of ads shown as part of an interaction with our website or application, using tracking technologies like cookies and pixels.
  • Counting Ad Impressions & Website Interactions to audit interactions with our websites, applications, or advertisements, count ad impressions to unique visitors, verify the position and quality of ad impressions, and perform similar activities.
  • Customer Service to provide customer service, maintain and service products and accounts, provide training for quality assurance purposes, and perform similar activities.
  • Fraud Prevention to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
  • Processing Transactions to process or fulfill orders and transactions, verify customer information, process payments, confirm eligibility promotional benefits, and perform similar activities.
  • Public Health and Safety to conduct screening or temperature checks for COVID-19 symptoms or similar screening activities related to public health and safety.
  • Defending Against Claims & Litigation to defend against or respond to potential or actual claims and litigation.
  • Determining Employment Eligibility to determine eligibility for employment, verify references and employment history, and conduct background checks.
  • Claims & Benefits Administration to process claims, administer benefits, and conduct employee drug tests in accordance with applicable laws.
  • Employee & Emergency Contact Communications to communicate with our employees or individuals listed as an employee’s emergency contact.

Our Sharing of Your Personal Information

We may share your personal information with the following:

Heroes and other Content Providers. We collect personal information about Hero’s end users and provide information to them. We process this personal information in order to provide our Platform, maintain the security of our Platform, enforce our policies, and otherwise maintain a safe and secure Flex U. platform.  

Business Services Providers. These are those persons or entities with whom we have a relationship to provide business operations services and support to Flex U.. These providers may include the following:

  • IT Operations Providers. These include cloud computing service providers, internet service providers, data backup and security providers, functionality and infrastructure providers, and similar service providers. 
  • Operations Providers. These include service providers with whom we partner to provide day-to-day business operations, including payment processors, security vendors, business software service providers, hospitality service providers, banks, and facilities management providers. 
  • Professional Advisors. These include lawyers, accountants, consultants, security professionals, and other similar parties when disclosure is reasonably necessary to comply with our legal and contractual obligations, prevent or respond to fraud or abuse, defend ourselves against attacks, or protect the rights, property, and safety of us, our customers, and the public.

Marketing and Advertising Providers. These include advertising, direct marketing, and lead generation providers, affiliate marketing program providers, retargeting platforms, data brokers, ad networks, marketing consultants, and similar service providers. 

Affiliates. Our affiliates include Flex U. Financial, LLC, a Delaware limited liability company, and any subsidiaries, joint venturers, or other companies that we control or that are under common control with us. 

Legally Required Parties/Governmental Entities. Persons to whom we are required by law to provide information, such as pursuant to a subpoena or a court order.

Reorganization. Persons involved in the consideration, negotiation, and completion of a business transaction, including the sale, merger, consolidation, acquisition, change in control, transfer of substantial assets, bankruptcy, or reorganization, and any subsequent integration.

Authorized Disclosures: To any party when authorized by the individual to whom it pertains to share it. 

Publicly Posted Content

 Flex U users may have the ability to post content to one or more Flex U forums, such as chat rooms and bulletin boards. You should be aware that when you voluntarily disclose personal information in any forum, that information can be collected and used by others and may result in unsolicited messages from other people. You are responsible for the personal information you choose to submit in these instances. Please take care when using these features. You may request and obtain the removal of such posted content by contacting us at [email protected] and specifically identifying the content to be removed.  Please be advised that any such removal does not ensure the complete or comprehensive removal of all traces of the content posted on the Flex U. forums.

Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; and the applicable legal requirements. In some circumstances, you may ask us to delete your information. Additionally, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Data Security

We have implemented and maintain reasonable security procedures and practices, appropriate to the nature of the information, to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. However, no security measure is perfect, so we cannot guarantee the security of your personal information. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply common protections described in this policy. These protections align with well-known standards such as ISO 27001:2017 and others.

International Data Transfers

We are located and operate in the United States. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you, including the United States, for processing. The laws that apply to the use and protection of personal information in the United States, or other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. These transfers may include transfers to our service providers located in foreign jurisdictions. Whenever we engage a service provider, we require that its privacy and security standards adhere to our requirements and applicable privacy laws.

Your Privacy Preferences

You can control the collection and use of personal information for some of our processing activities. This includes: 

  • Adjusting Communication Preferences

Emails From Flex U. During the registration for Flex U, you were presented with an opt-in to receive email communications. If you wish to no longer receive email communications, you can click on the “unsubscribe” link located at the bottom of the email, email Flex U at [email protected] to let us know, and we will remove you as soon as possible. Opting out of marketing or newsletter emails will not opt you out of all emails—we may need to send you transactional or similar emails related to your Flex U account, purchases, legal or contractual updates, or similar topics. You are not able to opt out of these emails. 

Emails from Third Parties. During registration for a Flex U virtual event or webinar, you may be asked to opt-in to receive emails from third parties. If you choose to opt-in to receive email communication from a third party, you can opt out or unsubscribe at any time by clicking on the “unsubscribe” or similar opt-out link in the third party’s’ email communication. Opting out of marketing or similar communications from third parties may not prevent all emails from third parties.  Third parties have their own privacy policies regarding the personal information they collect and process about you. We urge you to review their privacy policies regarding their processing of your personal information. 

Text Messages. You may opt out of automated text notifications any time by replying “STOP,” or any alternative keyword we have shared with you. You may still receive communications from Flex U regarding safety issues, such as messages related to your account, even if you have opted out.

  • Blocking Cookies

Most web browsers automatically accept cookies by default, but you can alter how your browser responds to cookies by adjusting the settings. Information about managing cookies for popular web browsers can be found in the links below:

Many websites, including ours, employ Google Analytics. To opt out of Google Analytics data collection, follow these instructions from Google.

Your Privacy Rights

Some jurisdictions provide covered individuals with specific privacy rights which can be exercised against covered entities. Depending on the jurisdiction, these rights may include the following: 

  • Access and Portability. The right to know (or confirm) what personal information a business has collected about you, and to receive a copy of it. 
  • Deletion/Restriction. The right to request that a business delete personal information it has collected from you or restrict how it is used, subject to certain exceptions.
  • Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business. 
  • Opt-Out of the Sale/Sharing of Your Personal Information. The right to opt out of the sale of your personal information to third parties. The term “sale” varies by jurisdiction, but sometimes includes the right to opt out of the use of personal information for targeted advertising purposes.
  • Revoke Consent. Where consent is required for processing under applicable law, you may withdraw your consent to the processing of your information at any time.
  • Object to Processing. Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
  • Limitation/Restriction. The right to limit or restrict a business’s use or disclosure of certain personal information.
  • Opt-out of Profiling/Automated Decision-Making: The right to opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. 
  • Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.
  • Complaints. The right to lodge a complaint with the appropriate governmental authority. 

 Flex U will honor the privacy rights afforded to individuals in accordance with applicable law and will not discriminate against individuals for exercising their privacy choices under the law.

Exercising Your Privacy Rights

You may make a request at any time to exercise your access, deletion, correction, and restriction rights listed above by using our “Do Not Sell or Share” or “Data Rights Request” at the bottom of, or emailing us at [email protected].  We will respond to your request within a reasonable period (if properly submitted) and in accordance with applicable law. If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. If we decline to act regarding your request, we will inform you of our decision and the reason for it, and, if applicable, with instructions on how you may appeal our decision. 

Children’s Privacy

Our Platform is not intended for persons under 16 years of age. We do not knowingly collect or process the personal information of individuals under the age of 16. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us their Personal Information, please contact us at [email protected]

Jurisdiction-Specific Privacy Disclosures

  1. Canada

If you are a Canadian resident, this section applies in addition to all other applicable rights and information contained in the Privacy Policy. 

We are committed to openness and accountability with respect to how we handle your personal information pursuant to Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including: 

  • The Personal Information Protection and Electronic Documents Act (PIPEDA)
  • Alberta’s Personal Information Protection Act (Alberta PIPA)
  • British Columbia’s Personal Information Protection Act (BC PIPA)
  • Québec's Act respecting the protection of personal information in the private sector (Québec Act).

Consent. Where you have provided your consent to the collection, use, and transfer of your personal information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by contacting us at [email protected]. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Use of Your Personal Information. We will not collect, use, or disclose personal information except for the identified purposes identified above (See What We Do with Your Personal Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the personal information we provide to them, we ensure that an agreement is place the ensure compliance with applicable Canadian Privacy Law.  

Exercising Your Canadian Privacy Rights. If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your personal information, you may submit a request using our  “Do Not Sell or Share” or “Data Rights Request” at the bottom of, or emailing us at [email protected]. When submitting a request, we may require that you take additional steps to validate your identity or legal authority. We will begin processing your request once you have completed the verification process. 

We have put procedures in place to receive and respond to inquiries about our policies and practices relating to the handling of personal information. We will provide a response to any personal information request within the timeframe required by law. If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation. 

Additional information about how to exercise your rights under Canadian Privacy Law can be found here: 

Office of the Privacy Commissioner of Canada


Toll-free: 1-800-282-1376

Office of the Information and Privacy Commissioner of Alberta


Toll-Free: 1-888-878-4044

Edmonton office: (780) 422-6860

Calgary office: (403) 297-2728

Office of the Information and Privacy Commissioner of British Columbia


Vancouver: (604) 660-2421

Elsewhere in BC: (800) 663-7867

Commission d’accès à l’information du Québec


Toll-free: 1-888-528-7741 

  1. Members of the European Economic Area and the United Kingdom

You may lodge a complaint with a supervisory authority at any time if you are of the opinion that the processing of personal data relating to you violates applicable law. If the complaint relates to provisions of the EU and UK GDPR, you can lodge such complaint with a supervisory authority in the Member State of your place of residence, your place of work or the place of the alleged infringement. You may identify the applicable supervisory authority based on your location on the European Data Protection Board website. If the complaint relates to provisions of the UK GDPR, you can lodge such complaint with the Information Commissioner’s Office. For contact details of your local Data Protection Authority, please see:

EU Representative

European Data Protection Office (EDPO)

Avenue Huart Hamoir 71, 1030 Brussels, Belgium

Email: [email protected]

Online request form: 

UK Representative


8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Online Request Form: 

  1. Australia

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You consent to us processing your personal information in accordance with this Privacy Policy.  You may access or request correction of the personal information that we maintain about you by using our Privacy Portal. There are some circumstances in which we are not required to give you access to your personal information. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete. 

If you have complaints about our privacy practices, please contact us using the contact methods provided. We will evaluate any complaints and determine if further action is necessary and keep you informed of our investigation and decisions.  If you remain dissatisfied with our handling of a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) ( for guidance on alternative courses of action which may be available.

  1. U.S. State-Specific Privacy Rights

Residents of certain U.S. States have the rights indicated below as of the date in which the applicable laws granting such rights are effective, which are as follows:

California: January 1, 2023

Virginia: January 1, 2023

Colorado: July 1, 2023

Connecticut: July 1, 2023

Utah: December 31, 2023

 Flex U does not engage in automated decision making/profiling so no action is required to exercise this right under state law. 

If you would like to opt-out of the sale or sharing of your personal information for cross-contextual behavioral or targeted advertising, please click the Do Not Sell or Share My Information link. 

You may make a request at any time to exercise your privacy rights under applicable law by using our “Data Rights Request” or “Do Not Sell or Share My Information” links at the bottom of  We will respond to your request within 45 days of receipt (if properly submitted). If we need more time to process and respond to your request, we will notify you of that fact along with the reason for the delay. In all cases we will complete your request within 90 days from the date of our receipt of your properly submitted request. If we decline to act regarding your request, we will inform you of our decision and the reason for it, along with instructions on how you may appeal our decision. 

  1. Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

Changes to this Notice

We may update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access our Platform or otherwise interact with us to stay informed about our information practices and the choices available to you.

Contact Us

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

Mail: Flex U., Inc., 83 Madison Ave,. Toronto, Ontario, Canada, Attn: Data Protection Officer

Email: [email protected]

Telephone: 1-647-680-8381