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PRIVACY POLICY

My Fyrst

myfyrst.com Effective Date: October 2026

myfyrst.com (the “Site”) is owned and operated by My Fyrst. My Fyrst is the data controller and can be contacted at hello@myfyrst.com.

This Privacy Policy has been prepared in accordance with Alberta’s Personal Information Protection Act (PIPA) and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). For users located in the European Union or United Kingdom, My Fyrst also adheres to the General Data Protection Regulation (EU) 2016/679 (GDPR) and the UK Data Protection Act 2018, to the extent applicable.

Purpose
The purpose of this Privacy Policy is to inform users of the Site of the following:

  1. the personal data we collect;
  2. how we use collected data;
  3. who has access to the data collected;
  4. the rights of Site users; and
  5. the Site’s cookie policy.

This Privacy Policy applies in addition to the Terms and Conditions of the Site.

Consent
By using the Site, subscribing to any service, or providing your personal information in any form, you consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

You may withdraw your consent at any time by contacting us at hello@myfyrst.com. Please note that withdrawing consent will not affect the lawfulness of any processing carried out before the withdrawal, and may affect our ability to provide certain services to you.

Personal Data We Collect
We only collect personal data that is necessary to provide the Services described on the Site. We will not collect additional data beyond what is listed below without notifying you first. The following personal data may be collected when you use the Site or subscribe to our Services:

  • First and last name;
  • Email address;
  • Phone number;
  • Mailing address (for journal delivery); and
  • Payment information.

This data is collected through the following methods:

  • subscribing to the My Fyrst program or services;
  • signing up for the My Fyrst newsletter or community;
  • completing any form on the Site;
  • signing up at a My Fyrst workshop, event, or in-person session (data collected at events is handled with the same care and under the same policy as data collected online); and
  • providing a phone number and email address when you create an App account, or separately opting in to any SMS program that My Fyrst may offer outside the App.

How We Use Personal Data
Data collected through the Site will only be used for the purposes specified in this Privacy Policy. We will not use your data beyond what is disclosed here. Personal data collected may be used for the following purposes:

  • to communicate with you regarding your subscription, program updates, and community information;
  • to deliver the Active Minds Journal and any other physical materials to your mailing address;
  • to send App sign-in verification codes by SMS;
  • to send how-to guides, updates and offers by email, if you have chosen to receive them (see “Email Communications”); and
  • to process payments for subscriptions, App purchases and services.

SMS Text Message Communications
For the My Fyrst App, your mobile number is used to send a one-time verification code when you sign in. App SMS messages are for account security and verification only; the App does not send daily activity prompts or marketing messages by SMS. Standard message and data rates may apply depending on your mobile carrier and plan. A payment provider such as Stripe may separately send transaction-related messages under its own policies and settings. If My Fyrst offers a separate SMS program outside the App in the future, its purpose and opt-in instructions will be provided separately before messages are sent.

Email Communications
An email address is required to create a My Fyrst App account. When you create your account, your email address and first name are added to our email list, which is stored separately from your emotional practice record. Providing an email address to create an account does not, by itself, mean that you have agreed to receive marketing emails.

You will receive how-to guides, updates, practice tips, community news, webinar invitations or other promotional emails only if you agree to them, for example by ticking the box at sign-up (“Yes, email me how-to guides, updates and offers”) or by joining a My Fyrst list on the Site or in the App. Every marketing email identifies My Fyrst as the sender and includes an unsubscribe link. Unsubscribe requests are processed within 10 business days. Unsubscribing from marketing emails does not stop essential account, security, order or subscription messages.

Who We Share Personal Data With
Your mobile number is shared with our authentication/SMS provider solely to send App sign-in verification codes and confirm your sign-in. This provider processes information under its own service terms and applicable privacy obligations.

Payment information is processed by our third-party payment processor. This processor receives your payment details solely for the purpose of completing your purchase (a journal subscription or an App reflection). My Fyrst does not store your full payment card details. Payment processing is governed by the processor’s own privacy policy, a link to which is available on our Billing page.

We may disclose your personal data to members of our organisation who reasonably need access to it in order to fulfil the purposes set out in this Privacy Policy.

We will not sell your personal data to any third party. We may share personal data with service providers that process it on our behalf as needed to operate the Site, App and Services, including hosting, authentication, email, analytics, security and payment providers. We may also share personal data in the following circumstances:

  • if required by law or a regulatory authority;
  • if required for any legal proceeding or to protect our legal rights; and
  • to buyers or potential buyers of this company in the event that we seek to sell the company, in which case you will be notified in advance.

If you follow hyperlinks from the Site to any third party website, including our workshop registration and billing platforms, please note that we are not responsible for and have no control over the privacy policies or practices of those third party sites. We encourage you to review the privacy policies of any third party sites you visit.

How Long We Store Personal Data
We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal obligations. For website orders and subscriptions, My Fyrst may retain order details for the duration of the subscription and for one (1) year after it ends to address billing inquiries, disputes and possible reactivation, unless the law requires or permits a different period. App account and practice-record retention and deletion are described in the App Privacy Addendum below. Stripe and other independent providers may retain transaction records under their own policies and legal obligations.

You may request early deletion of your personal data at any time by contacting us at hello@myfyrst.com. We will comply with such requests except where retention is required by law.

How We Protect Your Personal Data
We take the security of your personal data seriously. The following measures are in place to protect your information:

  • all data transmitted through the Site is protected using SSL (Secure Sockets Layer) encryption;
  • access to personal data is restricted to authorised employees only; and
  • all employees with access to personal data are bound by strict confidentiality obligations.

While we take all reasonable precautions to protect your personal data, no method of transmission over the internet is entirely secure. We are unable to guarantee the absolute security of your data beyond what is reasonably practicable.

In the event of a data breach that poses a real risk of significant harm to individuals, My Fyrst will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by applicable law.

Children and Minors
My Fyrst’s Site, App, programs, workshops and other Services are intended for adults aged 18 and over. We do not knowingly collect personal data through the Services from anyone under 18. If we become aware that a person under 18 has provided personal data, we will take reasonable steps to delete it, subject to applicable legal obligations. Please contact us at hello@myfyrst.com if you believe a person under 18 has provided personal data.

Your Rights as a User
Under applicable Canadian privacy legislation (PIPA and PIPEDA), and where applicable the GDPR, you have the following rights with respect to your personal data:

  • the right to be informed about how your data is collected and used;
  • the right to access your personal data held by us;
  • the right to request correction of inaccurate or incomplete data;
  • the right to request deletion of your personal data, subject to legal retention requirements;
  • the right to withdraw consent to processing at any time;
  • the right to data portability (where applicable under GDPR); and
  • the right to object to certain types of processing (where applicable under GDPR).

To exercise any of these rights, please contact us at hello@myfyrst.com. We will respond to all requests within a reasonable timeframe and in accordance with applicable law.

Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not respond to browser-initiated DNT signals. Because we use advertising measurement tools (see the Cookie Policy), you should use your browser settings, an ad blocker, or the controls offered by those providers to limit that measurement.

Cookie Policy
A cookie is a small file stored on a user’s device by a website. Its purpose is to collect data relating to the user’s browsing habits and preferences. You can choose to be notified each time a cookie is transmitted, or disable cookies entirely in your browser settings, though this may affect the quality of your experience on the Site.

We use the following types of cookies and similar technologies on the Site and in the App:

  • Functional cookies and similar storage: used to keep the App working, to remember your selections and preferences, and to save them for your next visit.
  • Analytics cookies: used to collect information about how visitors interact with the Site and the App, including pages visited and time spent. This data helps us improve the experience and is processed by third party analytics tools governed by their own privacy policies.
  • Advertising measurement cookies: set by Meta (such as _fbp and _fbc) through the Meta Pixel, to measure whether our advertising works. See “Advertising and Measurement” in the App Privacy Addendum.

Complaints
If you have any complaints about how we collect, use, or handle your personal data, please contact us first at hello@myfyrst.com so that we can attempt to resolve the issue.

If you are not satisfied with our response, you have the right to contact the relevant supervisory authority:

  • In Alberta: Office of the Information and Privacy Commissioner of Alberta (OIPC) – www.oipc.ab.ca
  • Federally (Canada): Office of the Privacy Commissioner of Canada – www.priv.gc.ca
  • EU users: your relevant national data protection authority under the GDPR.

Modifications
This Privacy Policy may be amended from time to time to maintain compliance with applicable law and to reflect any changes to our data collection and processing practices. When we amend this Privacy Policy, we will update the Effective Date at the top of this document and post a notice on the Site. We recommend that users periodically review this Privacy Policy to ensure they are aware of any updates.

Contact Information
If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal data, please contact us at:
hello@myfyrst.com
myfyrst.com

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APP PRIVACY ADDENDUM

This App Privacy Addendum supplements the Privacy Policy above and applies to the My Fyrst App at myfyrst.com/mytracker. This Addendum explains App-specific practices and should be read together with the main Privacy Policy. If a general section describes a different practice for the App, this Addendum governs the App-specific practice.

TWO WAYS TO USE MY FYRST

You can use My Fyrst in one of two ways:

  1. The App on its own. You practise in the App and choose emotion colours and write notes in it. Your practice record, as described below, is saved to your account.
  2. The physical journal together with the App. You write in your Active Minds Journal on paper. In this version, the App provides the activities only; you do not journal in the App. What you write in your paper journal stays with you and is not stored by the App. The App records which activities you have done and when.

Information about notes, colours and answers applies only when you use the App on its own, or where that information is otherwise collected. Information about your account, sign-in, reminders, practising with someone, technical information and your privacy rights may apply to both ways of using My Fyrst.

THE APP

  • My Fyrst is a personal emotional self-awareness practice. It is not therapy or medical care.
  • What you choose and write in the App is personal to you. My Fyrst does not sell your practice record or use it for advertising, and does not send your emotional notes or answers to advertising companies.
  • Your phone number is used for sign-in verification and is held by the sign-in service, not copied into your practice record. Your email address is required for an App account and is held in our email list, separately from your emotional practice record.
  • If you practise with someone, the App shares the activity order and connection status needed for the feature. It does not show the other participant your phone number, answers, colours or private notes.
  • You can delete your App data with the “Delete my data” feature in the App. Your email address stays on our email list until you unsubscribe or ask us to remove it (see “How long App information is retained”).
  • The App is designed to lock your notes, colours and answers on your own device before they are saved. You are asked to save a Notes unlock code to unlock them on another device or browser. My Fyrst cannot recover your notes if you lose the code and the key held on your device.
  • The App is intended for adults aged 18 and over.

PERSONAL INFORMATION COLLECTED IN THE APP
We collect and process the following information, depending on the features you use.

  1. Phone number

We use your phone number to send a verification code by text message when you sign in. Your phone number is processed by our authentication service provider and is not copied into your emotional practice record. See “Who We Share Personal Data With” in the main Privacy Policy for information about service providers.

  1. First name

We collect the first name you enter when creating your account. It is associated with your account and used to identify your account within the App.

  1. Email address

You must provide an email address to create an App account. Your email address and first name are added to our email list, which is separate from your emotional practice record and is not linked to what you write in the App. Providing an email address to create your account does not automatically mean you have agreed to marketing emails.

At sign-up there is a separate box, unticked, that says “Yes, email me how-to guides, updates and offers.” If you tick it, we may email you how-to guides, updates, practice tips and offers. If you do not tick it, we use your email only for essential account, security, order and subscription messages. You can unsubscribe from marketing emails at any time with the unsubscribe link in any email or by writing to hello@myfyrst.com. Essential account, security, order and subscription emails may still be sent.

  1. Emotional practice record

When you use the App on its own after creating an account, we may store the information you create or record as part of your practice, including:

  • the emotion colours you select;
  • notes you write about the circumstances, experiences or triggers associated with those selections;
  • your indications of whether an experience or trigger feels “nourishing” or “draining”;
  • your answers to short self-awareness questions;
  • sessions and activities you have completed, including relevant dates and times;
  • milestone selections and other practice-related choices;
  • your time zone; and
  • information about activities already presented to you.

This information supports your practice, progress and the App’s features. Your written reflections and emotional notes are intended to remain private and are not used to decide which advertisements you see.

  1. Feedback answers

If you choose to answer feedback questions in the App, your responses are stored with your account identifier so we can understand user experiences and improve the App. These responses are not shown to other users through the App.

  1. Notification token

If you enable notifications, the App may store a device notification token or similar technical identifier so that reminders can be sent to your device. You can disable notifications through your browser or device settings. The token is removed when it stops working or when you delete your data.

  1. Practising with someone

If you choose to practise with another person, the App may collect and store information needed to establish and maintain the connection, including:

  • a one-time invitation code, stored as a keyed cryptographic fingerprint rather than in readable form;
  • a record linking the participating accounts;
  • a private connection-status note for each participant, indicating whether the connection is pending or established; and
  • the shared order of activities for the joint practice.

The invitation code is designed to work once and expire after 24 hours. The original readable code is not intended to be retained after use or expiry. The connection record is used to operate the feature. Each participant’s emotional practice record remains associated with their own account. A connection does not, by itself, give either participant access to the other participant’s private notes, answers, colours or progress. Either participant can stop the joint practice. If one participant stops or deletes their data, the connection ends, and the other participant is notified that the shared practice has stopped.

  1. Payments and orders

The first emotional reflection in the App is free. Each later reflection requires a purchase, and the applicable price is shown, in the currency for your phone number’s country, before you choose to pay. Tax may be added at checkout. The physical journal with the App is offered as a recurring subscription, with its price, billing interval and included items shown at checkout. Payment processing is handled by Stripe or the payment provider identified at checkout.

The payment provider may collect information required to process your transaction, which may include your name, email address, phone number, billing or delivery address and payment card details. The provider may send transaction confirmations or receipts by email or text message. My Fyrst does not see or store your full payment card number. For each App purchase, My Fyrst keeps a record of how many reflections you have unlocked and the reference needed to match a payment to your account. Stripe and other independent providers may retain transaction records under their own policies and legal obligations.

Where a subscription is offered, its renewal, charges and cancellation terms will be disclosed at checkout. You may cancel in accordance with the terms provided at purchase.

  1. Technical and security information

Our hosting, authentication and security service providers may process technical information needed to operate and protect the App. Depending on the provider and configuration, this may include your IP address, browser and device type, operating system, App version, access timestamps and security-related logs. This information may be used to deliver the service, troubleshoot problems, protect accounts, prevent misuse and maintain security.

  1. Try-out before account creation

If you try the App before creating an account, the information you enter or select during the try-out is designed to remain on your own device and is not intentionally saved to our application database before account creation. This does not exclude technical information that may be processed by your browser, device, hosting provider or other service providers when you access the try-out experience. Information from the try-out is not automatically transferred to your account unless the App specifically provides that functionality.

HOW THE APP USES THIS INFORMATION
App information may be used to:

  • create, maintain and secure your account and sign you in;
  • provide activities and maintain your practice record and progress;
  • operate the “Practising with Someone” feature when you choose to use it;
  • send reminders if you enable notifications;
  • send essential account-related messages and, if you have ticked the box at sign-up or joined a list, how-to guides, updates, practice tips and offers;
  • process and fulfil orders and subscriptions;
  • respond to support requests and feedback;
  • measure use of the App and improve its features; and
  • protect the App, troubleshoot errors and prevent misuse.

My Fyrst does not use your written emotional reflections, trigger notes, colours or self-awareness answers to select advertisements for you, and does not provide those contents to advertisers.

YOUR NOTES AND DEVICE-BASED ENCRYPTION
The App is designed so that notes, colours, answers and journal entries are encrypted on your device before being saved to the database. My Fyrst and the hosting provider are not intended to be able to read that encrypted content. A limited summary may remain readable where needed for the App to function, such as your first name, time zone, session-completion dates and activity labels from the App’s library, rather than your own written words.

After your first session, the App asks you to save a Notes unlock code that allows you to unlock your notes on another phone or browser, or after your device is reset. My Fyrst does not have your code and cannot recover it for you. If you lose both the code and the key held on your device, your notes cannot be recovered. You can replace your Notes unlock code at any time in My Guide.

Some information is not encrypted in this way because it is needed to run the service, including your phone number held by the authentication provider, your email address held in our email list, feedback responses, and payment and order records. The security of device-based encryption depends on the App page and code running on your device being genuine. We take reasonable steps to protect the service, but no system is entirely secure.

USAGE COUNTS AND AGGREGATED STATISTICS
We may calculate basic counts about how the App is used, such as the number of accounts, completed sessions and reflections, weekly active users, shares of the App and sign-ups for a waiting list. We may share these counts and aggregated statistics with funders, partners and advisers.

After reflections and milestones, the App may generate numerical statistics, such as how often emotion colours are selected, how often activities are marked nourishing or draining, and how self-awareness answers change between the first day and a milestone. These statistics are designed not to include written reflections or trigger notes. The numbers are calculated on your device and sent to My Fyrst without your written notes. They are intended to be used collectively to understand usage patterns and improve the App.

Groups with fewer than 20 contributions are not reported. A coded reference may be retained to apply a small daily limit and prevent misuse. Because such a reference may allow contributions to be distinguished without revealing a person’s identity, these statistics are more accurately described as pseudonymous rather than fully anonymous. Once statistics have been incorporated into aggregated reporting, they may not be capable of being traced back to or removed for a particular person.

TEXT MESSAGES AND APP NOTIFICATIONS
The App sends a one-time text message verification code when you sign in. This is a security message, not a marketing message. Standard message and data rates may apply. Stripe or another payment provider may also send receipts or order updates by text message or email when you make a purchase; those messages are governed by the provider’s policies and your transaction preferences.

The App may send practice reminders if you enable browser or device notifications. You can turn notifications off at any time through your browser or device settings.

ADVERTISING AND MEASUREMENT
My Fyrst uses the Meta Pixel through Google Tag Manager, and Google Analytics, to measure advertising performance and understand how the Site and App are used. Information shared with these providers may include visits to landing pages, use of the try-out, account creation, completion of a reflection or milestone (as a number only), which advertisement or campaign brought you to us, your IP address, browser and device information, and advertising or analytics cookies.

My Fyrst does not send to Meta or other advertisers the emotional colours, written reflections, trigger notes, self-awareness answers, or other private practice content you enter in the App. My Fyrst also does not send your name, phone number or email address to advertisers through these measurement features. These tools are provided by third parties and are subject to their own privacy policies and settings. You can limit this measurement with your browser settings, an ad blocker, or the controls offered by Meta in your Meta account.

WHO PROVIDES APP SERVICES AND WHERE INFORMATION IS STORED
The App uses service providers to deliver its features. These include:

  • Google Firebase for phone sign-in, the database, server functions, and notification delivery;
  • Google Tag Manager and Google Analytics for tag management and analytics;
  • Meta Platforms for advertising measurement;
  • Stripe for payment processing;
  • GoDaddy for website hosting;
  • Cloudflare for content delivery and security; and
  • WordPress and our email-list provider, which hold your email address, first name and where you signed up.

Your App account, practice record and server functions are hosted by Google Firebase on servers in the United States. Other providers may store or process information in Canada, the United States or other countries. Information processed in another country may be subject to that country’s laws and lawful access by its courts, law enforcement or national security authorities. We rely on service-provider safeguards and appropriate transfer mechanisms where required.

HOW LONG APP INFORMATION IS RETAINED
We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, subject to legal obligations.

  • Paper journal entries remain with you and are not held by My Fyrst.
  • The App account and practice record are retained while your account exists. The App also keeps a limited number of recent safety copies of your progress to restore work if something goes wrong.
  • When you use “Delete my data”, we delete from the App’s systems, at once and permanently: your practice record, your safety copies, your feedback answers, your Notes unlock code key record, your record of unlocked reflections and payment references, any “Practising with Someone” connection, and your App account and sign-in information, including your phone number. This cannot be undone, and you will need to create a new account to use the App again. The usage statistics described above are not linked to you and cannot be removed.
  • “Delete my data” does not remove your email address from our email list. Your email address stays on the list until you unsubscribe using the link in any email or ask us to remove it at hello@myfyrst.com. Stripe and other providers that hold records independently under their own systems, policies or legal obligations are also not affected by “Delete my data”. They may retain transaction, delivery, security or other records, and My Fyrst may retain limited records where legally required or permitted, such as accounting or transaction records.
  • Journal subscription and order details held by My Fyrst may be retained while a subscription is active and for one year after it ends for billing questions, disputes and possible reactivation, unless the law requires longer.
  • Advertising and analytics information held by Meta and Google is retained under their own policies.

You may also request deletion by contacting hello@myfyrst.com. We will comply with deletion requests except where retention is required or permitted by law.

AGE REQUIREMENT FOR THE APP
My Fyrst’s Site, App and Services are intended for adults aged 18 and over. We do not knowingly collect personal information through the Site or App from anyone under 18. If we become aware that an App account belongs to someone under 18, we will take steps to delete the account and associated information, subject to applicable legal obligations. Please contact hello@myfyrst.com if you believe a person under 18 has provided information through the App.

YOUR APP PRIVACY RIGHTS
Subject to applicable law, you may request access to personal information held about you, ask for inaccurate information to be corrected, request deletion, or withdraw consent where processing is based on consent. Some rights, including data portability and the right to object to certain processing, may apply depending on your location and the law that applies. You can use “Delete my data” in the App or contact hello@myfyrst.com.

If you have concerns about the handling of your personal information, contact hello@myfyrst.com. You may also contact the relevant privacy regulator, including the Office of the Information and Privacy Commissioner of Alberta or the Office of the Privacy Commissioner of Canada, as applicable.