Privacy Policy

Last Updated: March 10, 2026

Frozen Fly International Inc. ("we", "us", "our") is committed to maintaining the confidentiality, accuracy, and security of the personal information of our matrix ecosystem members. This Privacy Policy describes how we collect, use, store, and disclose your personal data in compliance with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).

1. Accountability and Scope

We are responsible for all personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with PIPEDA principles. If you have any inquiries regarding the management of your personal data, you may reach our privacy office via email at privacy@frozenfly.org or at our registered address: 9528 25 Hwy, Halton Hills, Ontario, L9T 2X7, Canada.

2. Information We Collect

To manage member registrations, establish referral networks (sponsorships), and process matrix commissions, we collect the following personal information:

Identity Data: Full Name and desired Username.
Contact Data: Email Address, Phone Number, and Country of residence.
Referral Relations: Sponsor referral codes and network matrix structures linking you to other members.
Transaction Logs: E-Pin activation details, payout requests, audit logs, and account activities.

3. Identifying Purpose

We collect and process your personal information only for the following specified purposes:

To provision and maintain your member account and verify level upgrades.
To calculate network commissions, direct referral bonuses, and global turnover pool distributions.
To notify sponsors when a new referral has registered under their network.
To secure the database against multiple fake registration attempts, bots, or stacked accounts.
To communicate transactional messages (password recovery, system updates, billing notifications) as required to administer your membership.

4. Consent and CASL Compliance

By checking the agreement box during registration and submitting your profile, you provide explicit, meaningful consent for us to collect and process your personal data for the purposes outlined in Section 3.

CASL Marketing Consent: In compliance with Canada's Anti-Spam Legislation, we will not send you commercial promotional electronic messages (emails or newsletters) unless you have provided explicit opt-in consent. Transactional emails (e.g. password resets, matrix activation confirmations, or notifications of pending approvals) do not require marketing consent and are sent to administer the contract. You may update your notification preferences or opt-out of marketing communications at any time.

5. Limiting Collection, Retention, and Disclosure

Limiting Collection: We collect only the data necessary to provide structural matrix services and maintain platform security.
No Sale of Data: We do not sell, trade, or rent member lists, phone numbers, or email addresses to third-party advertising companies.
Third-Party Sharing: We only disclose personal information to service providers (such as hosting servers, database backups, or email dispatchers) who are contractually bound to safeguard the data. Information is never disclosed to external bodies except when required by Canadian courts or law enforcement.
Data Retention: Personal information is retained as long as your account remains active. Upon request, inactive or closed accounts will have identifying details scrubbed or anonymized, subject to regulatory bookkeeping audit rules under Canadian tax law.

6. Safeguards and Database Security

We employ rigorous administrative, technical, and physical security measures to protect your personal information:

Passwords are protected and encrypted using industry-standard secure hashing algorithms.
Database activity is tracked with automated internal audit logs that trace changes to payments, E-Pins, and structural ranks.
Data transfers are secured through standard SSL/TLS encryption.

7. Your Rights (Individual Access and Accuracy)

Under PIPEDA, you have the right to request access to the personal information we hold about you. You can update or correct your profile settings (such as full name, phone number, and country) at any time from your dashboard profile settings page.

To request a copy of your stored data, submit an inquiry to privacy@frozenfly.org. You may also permanently delete your account directly at any time from your dashboard profile settings page, which instantly removes your personal details and releases your username/email for potential future registrations.

8. Updates to this Policy

We may update this Privacy Policy from time to time to adapt to changes in software structure or Canadian legal guidelines. Significant changes will be broadcasted to members via dashboard notifications or email updates.