Privacy Policy

1. Introduction

ES+ SRL ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and engage with our personal finance educational services. Please read this policy carefully. If you have any questions, contact us at the address provided at the end of this document.

2. What Data We Collect

We collect the following categories of data:

• Full name
• Email address
• Phone number
• IP address and device information
• Browser type and version
• Device type and operating system
• Cookies and tracking identifiers
• Usage data (pages visited, time on site, click paths)
• Form submission content (course inquiries, contact requests, messages)
• Conversion events (form submissions, course registrations, contact clicks)

3. Cookie Categories and Consent Management

Essential Cookies

Essential cookies are necessary for the website to function properly. These cookies enable core functionality including session management, security, and user preferences.

• Purpose: Core site functionality, security, session management
• Examples: session_id, csrf_token, cookie_consent_status
• Consent Required: No – these cookies are activated automatically
• Retention: Session duration or up to 12 months for preference storage

Analytics Cookies

Analytics cookies help us understand how visitors use our website, including pages visited, time spent, and user behavior patterns. This information allows us to improve the user experience and course content delivery.

• Purpose: Measuring traffic, user behavior, site performance
• Primary Tool: Google Analytics 4
• Examples: _ga, _ga_XXXXXXX, _gid, _gat
• Consent Required: Yes – activated only after user accepts
• Retention: Up to 14 months

Marketing and Advertising Cookies

Marketing cookies enable personalized advertising and remarketing campaigns. They track your interactions across websites to deliver relevant educational course advertisements and measure campaign effectiveness.

• Purpose: Remarketing, personalized ad delivery, conversion tracking
• Consent Required: Yes – activated only after user accepts
• Retention: Up to 540 days (Google Ads standard)
• Platforms: Google Ads, Meta (Facebook/Instagram), Google Display Network

4. Marketing Cookies – Detailed Disclosures

Third-Party Ad Serving

Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet. This allows us to reach you with relevant educational content when you browse other websites.

Advertising Partners

We work with advertising partners such as Google and Meta to deliver advertisements tailored to your interests across various websites and platforms. These partnerships help us reach learners interested in personal finance education throughout Canada.

Remarketing Services

We use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit. This helps us remind you about our educational courses and stay connected with prospective learners.

YouTube and Display Network

Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network. These placements help us reach Canadian learners interested in financial education through trusted platforms.

Tracking Technologies Used

We use the following tracking technologies on this website:

• Cookies (first-party and third-party)
• Tracking pixels (Google Ads tag / gtag.js, Meta Pixel)
• Device identifiers (browser fingerprint, IP address)
• Conversion event tags

Advertising Measurement

We use conversion tracking to understand which advertisements lead to actions on our website such as form submissions, calls, or course registrations. This allows us to measure campaign effectiveness and allocate budget appropriately. Conversion data may be shared with Google Ads and Meta to improve campaign performance and reach qualified learners.

Advertising Technologies in Use

Advertising and analytics technologies active on this site include:

• Google Ads (gtag.js / Google Tag Manager)
• Google Analytics 4
• Google Remarketing Tag
• Meta Pixel (Facebook / Instagram)

Opt-Out from Personalized Advertising

You may opt out of personalized advertising at any time using the tools below. Please note that opting out does not remove ads from your browsing experience entirely – you will continue to see non-personalized advertisements based on general content and context rather than your personal interests.

• Google Ads Settings
• Your Online Choices (EU)
• Network Advertising Initiative
• Digital Advertising Alliance

Cookie Preference Management

You can manage your cookie preferences at any time by clicking the "Manage cookie preferences" link in the footer of this website. This will open a panel where you can accept or reject each cookie category independently. Essential cookies cannot be disabled as they are necessary for website functionality.

5. Consent Requirements and Consent Banner

When you first visit our website, a consent banner appears offering three options:

• Accept All: Activates all cookies including analytics and marketing
• Reject Non-Essential: Activates only essential cookies
• Manage Preferences: Opens a detailed panel for per-category control

Analytics and marketing cookies are activated ONLY after you click "Accept All" or explicitly enable them in Manage Preferences. Your consent choice is stored in your browser for 12 months.

GDPR and UK GDPR Compliance (EEA and UK Users)

Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Your consent is recorded with a timestamp and may be audited upon request.

Withdrawal of Consent

You may withdraw consent at any time by clicking "Manage cookie preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect the lawfulness of processing that occurred while consent was valid. You will not be penalized for withdrawing consent.

6. Data Sharing with Advertising Partners

We share certain data with advertising partners for campaign delivery and measurement. These recipients and the data categories shared include:

Google LLC

We share the following data with Google for advertising and analytics purposes:

• Cookie identifiers and device identifiers
• Conversion events (form submissions, course registrations)
• Anonymized behavioral data and usage patterns
• Remarketing lists for reaching previous visitors

Google's processing is governed by Google's Privacy Policy. Data transfers to Google operate under Standard Contractual Clauses where applicable.

Meta Platforms, Inc.

We share the following data with Meta for advertising purposes on Facebook and Instagram:

• Pixel events (page views, user interactions)
• Conversion data (form submissions, registrations)
• Custom audience membership for retargeting

Meta's processing is governed by Meta's Data Policy. Data transfers to Meta operate under Standard Contractual Clauses where applicable.

Data Not Sold

We do not sell personal data to third parties. All transfers to Google and Meta are for the specific purposes of ad targeting, campaign measurement, and analytics only. Data is not resold to unaffiliated third parties.

7. Lead Forms and Contact Requests

When you submit a contact form, request course information, or register interest in our services, we collect the information you provide. This typically includes:

• Full name
• Email address
• Phone number
• Message or inquiry content
• Course selection (if applicable)

Legal Basis for Processing

We process form submission data under two legal bases:

• Consent (GDPR Art. 6.1.a): You explicitly consent by submitting the form
• Performance of a Contract (GDPR Art. 6.1.b): Where a service relationship or course registration exists

Data Retention

Form submission data is retained for up to 2 years from the date of submission, unless a longer period is required by applicable law or you request deletion earlier.

Data Deletion

You may request deletion of your form submission data at any time by contacting us at the email address provided in this policy. We will process deletion requests within 30 days.

Privacy Policy Link on Forms

A link to this Privacy Policy appears adjacent to every submission button on this site. Submitting a form constitutes acknowledgment of this policy and your consent to data processing as described.

8. Google Services and Advertising

This website uses the following Google services for analytics and advertising purposes:

Google Analytics 4

Google Analytics 4 collects anonymized usage data including device information, behavioral signals, and traffic patterns. IP anonymization is enabled to protect your privacy. Data retention is set to 14 months. You may opt out using the Google Analytics Opt-out Browser Add-on.

Google Ads Conversion Tracking

We implement Google Ads conversion tracking to record when a user completes a defined action after clicking one of our ads. Tracked actions include form submissions, contact requests, and course registrations. This data is used solely for measuring ad campaign performance and return on investment.

Google Remarketing

We use Google Remarketing to show ads to previous visitors across Google's network. Remarketing lists are created based on page visits and user behavior only. We do not create remarketing lists from sensitive data categories including health information, financial situation, religion, sexual orientation, or political views.

Google Tag Manager

Google Tag Manager acts as a container that deploys tracking tags on our behalf. No personal data is collected by GTM itself; it serves as the deployment mechanism for the analytics and conversion tracking tags listed above.

Google's Privacy Governance

Google's advertising products and services are governed by Google's Advertising Policies and Google's Privacy Policy. We encourage you to review these policies to understand how Google processes your data.

9. Meta Advertising Services

This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record:

• Page views and time spent on the website
• Specific conversion events (form submissions, course registrations)
• Custom audience membership for retargeting purposes

Sensitive Data Restrictions

We do not use the Meta Pixel to collect or transmit sensitive personal data. We do not target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies. All use of the Meta Pixel complies with Meta's terms and policies.

Meta's Role and Policies

Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Meta's processing is governed by Meta's Data Policy. We encourage users to review Meta's policy to understand their rights.

Managing Your Ad Preferences

To manage your ad preferences on Meta platforms, visit Facebook Ad Preferences. You can control which categories of ads you see and manage your advertising interests.

10. Prohibited Content Self-Declaration

This website does not promote, sell, or facilitate access to prohibited product or service categories. We explicitly do not engage with:

• Weapons or dangerous goods
• Controlled substances or illegal drugs
• Counterfeit goods or intellectual property theft
• Gambling services without appropriate licensing
• Adult content or sexually explicit materials
• Services making misleading health or financial claims
• Get-rich-quick schemes or guaranteed wealth promises

All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full. Our educational courses focus exclusively on legitimate financial literacy instruction without making guaranteed outcome claims.

11. Landing Page Integrity Statement

The content of this website accurately represents the personal finance educational products and services we offer. We do not employ bait-and-switch practices or deceptive landing page tactics. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website. All content is consistent, transparent, and matches the promises made in our advertising campaigns.

12. Children's Privacy

This website is not directed at individuals under the age of 16 and is designed for adult learners. We do not knowingly collect personal data from minors under 16 years of age. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly upon notification. If you believe we have received data from a minor, please contact us immediately at the address provided in this policy.

13. International Data Transfers

Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. maintain their primary operations and data centers.

Standard Contractual Clauses

These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data during international transfer. SCCs are contractual commitments that ensure adequate data protection standards are maintained even in countries without equivalent privacy legislation. A copy of the applicable SCCs can be requested by contacting us directly at the email address provided in this policy.

14. User Rights Under GDPR (Articles 15-22)

If you are located in the European Economic Area or the United Kingdom, you have the following rights regarding your personal data:

Right of Access (Article 15)

You have the right to request a copy of all personal data we hold about you. We will provide this information in a clear, understandable format within 30 days of your request.

Right to Rectification (Article 16)

You have the right to correct inaccurate or incomplete data we hold about you. We will update your information promptly upon verification.

Right to Erasure (Article 17)

You have the right to request deletion of your personal data (the "right to be forgotten") in certain circumstances, such as when data is no longer necessary or consent is withdrawn.

Right to Restrict Processing (Article 18)

You have the right to limit how we process your data in certain situations, such as while we verify the accuracy of disputed information.

Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, machine-readable format and to transmit that data to another controller without hindrance.

Right to Object (Article 21)

You have the right to object to processing of your data based on legitimate interest, including for direct marketing purposes.

Right to Withdraw Consent (Article 7.3)

You have the right to revoke your consent at any time without penalty. Withdrawal does not affect the lawfulness of processing that occurred while consent was valid.

How to Exercise Your Rights

To exercise any of these rights, email us at [email protected] with your request. Please include your name, email address, and a description of the action you are requesting. We will respond within 30 days. You also have the right to lodge a complaint with your local supervisory authority:

• European Data Protection Board (EU users)
• Information Commissioner's Office (UK users)

15. Legal Basis for Processing (GDPR Article 6)

We process personal data under the following legal bases:

Consent (Article 6.1.a)

We process analytics data, marketing data, and conversion tracking data based on your explicit consent through the cookie consent banner. You control this consent and may withdraw it at any time.

Contract Performance (Article 6.1.b)

We process contact form data and course enrollment information to perform our educational services and respond to your inquiries.

Legitimate Interest (Article 6.1.f)

We process security logs and fraud prevention data based on our legitimate interest in protecting our website, users, and services from unauthorized access and malicious activity.

16. Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Here are our specific retention periods:

Contact Form Submissions

Up to 2 years from the date of submission, unless you request deletion earlier or applicable law requires a longer retention period.

Analytics Data (Google Analytics 4)

Up to 14 months, as configured in Google Analytics settings.

Marketing and Advertising Cookies

Up to 540 days (approximately 18 months), following Google Ads and Meta standard cookie retention periods.

Email Communications

Duration of the learning relationship plus 1 additional year for record-keeping purposes.

Server Logs

90 days from the date of access.

Cookie Consent Records

3 years (required for audit and regulatory compliance purposes).

17. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our data practices, legal requirements, or other operational needs. Changes will be posted on this page with an updated "Last Updated" date. Material changes will be notified to users via a homepage banner at least 14 days before taking effect. Your continued use of the website following the posting of changes constitutes your acceptance of the updated Privacy Policy.

18. Contact Information

If you have questions about this Privacy Policy, wish to exercise your rights, or have privacy concerns, please contact us:

19. Policy Version Information