Privacy Policy

Last Updated June 17, 2024.

10432423 Canada Limited (“Bright Breaks”, “we”, “us”, “our”) respects the privacy of our users and is committed to protecting it by complying with this policy. This privacy policy (the “Privacy Policy”) describes:

  • the types of information we may collect from you, the user of the Services, or that you may provide when you, download, install, register with, access or use the Bright Breaks mobile application (the “App”), or interact with our website (the “Site”) (together, the “Services”); and
  • our practices for collecting, using, maintaining, protecting and disclosing that information.

By accessing or using our Services, you agree that you have read, understood, and agreed to be bound by this Privacy Policy. If you do not accept the terms of this Privacy Policy, you may not access or use the Services. We may change this Privacy Policy from time to time without notice to you. The date on which this Privacy Policy was last updated will appear at the top of this page. You should periodically review this Privacy Policy so that you are aware of any changes which might affect you. Your continued use of the Services after we make changes indicates that you accept and consent to those changes. Please also carefully read our Terms of Service found at prior to using our Services.

Collection of your Information

For the purposes of this Privacy Policy, personal information (“Personal Information”) means any information about an identifiable individual, as may be defined or limited under applicable privacy legislation. Personal Information excludes anonymous or de-identified data that is not associated with a particular individual (herein referred to as “Non-identifiable Information”). Personal Information and Non-identifiable Information are collectively referred to in this Privacy Policy as “Information”.

What Information do we collect?

When you use our Services, we collect and use several types of Information from and about you, including:

  • Personal Information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, IP address, credit card and billing information, and other information that may be required to open an account (such as login credentials). We may also collect descriptive information from you about your general state of well-being (you are asked to rate, on a scale of 1-10, how true certain statements are for you, such as “I feel good about myself”, or “I eat a healthy, balanced diet”, or “I am comfortable with my current financial situation”). If you use the App and enable/opt-in to certain fitness tracking features, we may collect Personal Information you decide to share regarding your physical activity and fitness, such as your daily step count or other, similar activity/fitness information, for the purpose of providing the Services to you.
  • Non-identifiable Information, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Site or App feature.
  • Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.
  • Information about your Site and App interactions, including the full URLs, clickstream to, through and from our Site and/or App (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How do we collect Information?

We only collect Information that is reasonably necessary to provide the Services to you, and as otherwise described in this Policy. We use different methods to collect your Information, including through:

  • Direct interactions with you when you provide it to us, such as when you book services offered through the Site or App, ask to receive emails and/or text messages, or when you correspond with us through the Site or App, by email, phone, or otherwise. We also collect Personal Information directly from you when you enable and opt-in to certain App features, such as step-tracking or similar fitness tracking functions on the App.
  • Automated technologies or interactions as you navigate our Site and/or App. Information collected automatically may include usage details, IP addresses, and information collected through cookies or other tracking technologies. For more information on our use of Cookies and related technologies, please see below.
  • Third parties or publicly available sources, such as other users of the Site or App, our business partners and service providers, and unaffiliated third parties (such as advertising networks).

We may collect Information that you, or another, provides directly to us by filling in forms, and Non-identifiable Information that we collect from cookies or tracking software we utilize. In addition to Information collected through your use of our Services, we may also collect Information in other ways such as over the phone, via email and through location tracking devices as further described below.

The choice to provide us with Personal Information is yours, and you can withdraw your consent with respect to our collection and use of your Personal Information at any time. In certain cases, your decision to withhold Information may limit the services that we can provide to you through the Site or App.


A cookie is a small file placed on your computer or smartphone. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting, you may not be access all parts of our Services. We use cookies as means of providing personalization features to our users, to assist in completing an incomplete purchase for items left in a shopping cart, and for marketing purposes.

Some of the cookies used by us are essential for the functioning and performance of our Site and App, such as by making our Site and App work more efficiently and facilitating your use of the functionalities and services provided; these functionality and/or performance cookies will be deleted from your device once your browser-session has ended (session cookies). We will not use the information stored in essential cookies for any other purpose than as strictly necessary to provide you with the services and functionalities requested.

We also use cookies that are not essential for the functioning and performance of our Site and App, but that help us to customize your experience, improve Site and App functionality, and have marketing functions.

Our Site or App may contain links to other websites operated by third parties such as media sites and app stores and may include social media features such as Facebook and Twitter buttons (such as “Like,” “Tweet” or “Pin”). These third-party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our Privacy Policy. We do not control what information these third parties collect. Please review your privacy settings on your social media sites and think carefully before clicking on links which may take you to a third-party website.

In addition, we may permit third-party partners to use cookies and other technology to collect information about your browsing activities over time and across different websites when you use our Site or App. This cookie information may be used to generate custom and lookalike audiences and similar marketing outreaches.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. To opt-out of interest-based advertising, and to find information about how to block or limit cookies, visit AdChoices, the Canadian self-regulatory program for online interest-based advertising, administered by the Digital Advertising Alliance of Canada (“DAAC”).If you are in US, visit, administered by the Digital Advertising Alliance (“DAA”)”.

We use a third party, Google Analytics, to understand how visitors find and use our Site and App. Google Analytics uses cookies to help us analyze how users use our Site and App, including the number of visitors, the websites our visitors have come from, and the pages they visit. Any information generated by the cookie about your use of our Site and/or App will be transmitted to and stored by Google. You may prevent the collection of data generated by the cookie about your use of the Site and App (including your IP address) and opt-out of being tracked by Google Analytics across all websites by downloading and installing a browser-plugin which is available here.

Use of your Information

We will only use your Information for purposes identified in this Privacy Policy, or as required by law. The Information that we collect and store is primarily used for the following purposes:

i. to provide you with access to the Services;

ii. to provide you with information relating to our Services;

iii. to provide you with information, Services that you request from us;

iv. to follow up on your comments and suggestions;

v. to fulfill the purposes for which you provided the Information or that were described when it was collected, or any other purpose for which you provide it (note that if you opt-in to enable certain App features, such as a step-counter or other fitness tracking feature, collected Information will be used only for the reasonable purposes identified to you at or before the time the Information is collected, such as to enable your participation in group activity/fitness challenges and/or rewards, or other group incentives, included as part of the Services);vi. to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;

vii. to notify you about changes to our Services we offer or provide through our Site or App;

viii. to improve our Site or App, Services, marketing, or customer relationships and experiences;

ix. to manage and develop our business systems and operations;

x. to monitor and conduct an analysis of our Site and App traffic and usage patterns;

xi. to post customer testimonials, comments or reviews;

xii. to protect our rights and property; or

xiii. to lessen a serious threat to personal safety, health or security.

Recordings of our sessions (via Zoom or otherwise), which may include Personal Information such as your image or voice, may also be distributed published, displayed, performed, transmitted, streamed, broadcasted, or made available to our service providers, other customers, third parties, or the public in order to provide such persons with access to the content of the recordings in connection with our business.

Disclosure of your Information

We will not sell, share, trade or otherwise distribute your Personal Information to third parties, except in accordance with this Privacy Policy. However, we reserve the right to use Non-identifiable Information for any purpose, including commercial purposes, in our sole discretion. Such commercial purpose may include, but is not limited to, sale to third parties to allow them to send targeted advertising messages.

We reserve the right to share any Information collected from you with our affiliates, or to transfer such Information to a successor entity or to an entity which purchases substantially all of the assets of Bright Breaks.

We sometimes contract with outside organizations to perform specialized services such as hosting the Site and App. Our suppliers may at times receive, process or handle some of your Information. Only the Information necessary to perform the services under the contract is given to the supplier. Under their contracts with us, our suppliers may use such Information only to carry out the contracted service and must not store or use the Information for any other purpose. Our contracts with suppliers require that they provide a level of protection for your Information that is comparable to our own.

We may also disclose your Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bright Breaks, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Transfers

Note that Personal Information may be stored, accessed, used and otherwise processed inside and outside of Quebec and/or Canada. When Personal Information is located outside Quebec and/or Canada, it may be subject to laws that have different standards of protection and may allow for foreign law enforcement and governmental access.

Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.


The security of your Personal Information is important to us. To ensure that your Personal Information is secure, we have put in place commercially suitable procedures to safeguard the Information we collect against unauthorized use, disclosure, or modification, including but not limited to:

  • the data stored by Bright Breaks is encrypted at rest and in transit;
  • Bright Breaks does not store user passwords; and
  • access to Bright Breaks’ API endpoints requires the requester to be authenticated and authorized (except for some endpoints that do not give access to any sensitive data).

    Nonetheless, transmission of information on the internet is not completely secure. Therefore, we cannot guarantee the security of data sent to us electronically on our Site, through our App, by email or otherwise and transmission of such data is therefore entirely at your own risk. Likewise, the storage of information is not completely secure and we cannot guarantee the security of data stored on our system and storage of such data is therefore entirely at your own risk.

We comply with all applicable laws related to the security standards we must apply to our services, including data collection, transmission and storage, to be and remain compliant with those laws when we collect, use, handle or store your Personal Information.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize or aggregate your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Canada’s Anti Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.


Our Services are not intended for persons under the age of majority, and we do not knowingly collect Personal Information from minors. If you believe we might have any information from or about a minor, please contact us at the address provided below.

Updating your Information and Correcting Errors

It is important that your Personal Information be accurate and up-to-date. We will take reasonable steps to ensure the Personal Information we hold is accurate, complete and up-to-date. If any of your Personal Information changes, is inaccurate, or is incomplete, please inform us by contacting us at the address provided below so that we can make any necessary changes. You can also log into your account and update your Personal Information at any time. Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal information and give you access to that information..

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are a resident of Quebec, we will inform you if we exclusively use automated processing to render a decision about you. You also have the right to request information about the Personal Information used to make that decision, and to request that the information be corrected.

Withdrawing your Consent

You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your Personal Information time by contacting us at . If you withdraw your consent (or if you decide not to provide certain Personal Information), you acknowledge that we may not be able to provide you, or continue to provide you, with certain products, services, or information that may be of value to you. We will explain the impact to you at the time to help you with your decision.

Contact Us

If you have any questions, concerns or suggestions regarding this Privacy Policy, please contact our privacy officer at

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