FLO 100 INC.
PRIVACY POLICY
Effective date: March 26, 2026
1. INTRODUCTION
Flo100 Inc. (“Flo100,” “we,” “us,” or “our”) is a Canadian corporation that produces curated executive roundtables, dinners, and experiences for senior business leaders. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, and the rights you have over it.
This policy applies to information we collect through our website, our membership platform (Flo100 Circle), our digital membership passes, our events, and our communications with members and prospective members.
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector ("Law 25"), and equivalent privacy laws in jurisdictions where our members reside.
2. WHO WE ARE
The data controller for personal information collected through Flo100 services is:
Flo100 Inc.
36 Lisgar Street, Toronto, Ontario M6J 0C7, Canada
For all privacy-related inquiries — including access requests, corrections, complaints, or questions — contact our Privacy Officer at info@flo100.com.
3. PERSONAL INFORMATION WE COLLECT
3.1 Information you provide directly
When you register for a Flo100 event, request membership, or correspond with us, we collect:
Full name
Personal email address
Work email address
Phone number
Company name
Job title
Region or city
Information you choose to share about your professional interests and goals
3.2 Sensitive personal information (optional)
We give you the option to share information about your gender, race, or ethnicity. Providing this information is entirely voluntary.
We use this information algorithmically, as a weighting signal. When we plan an event designed for a specific community (for example, women in technology or Black founders), our system gives positive weight to members who have indicated alignment with that community. Our team uses that signal, alongside other factors, to decide who to invite. The system does not make the decision; we do. By design, no member of the Flo100 team can search, filter, or view the member database by gender, race, or ethnicity in the course of normal operations — the data is processed by the system but is not surfaced to staff.
We do not share this information with third parties, we do not use it for advertising, and we do not use it to exclude anyone from any event for which they are otherwise eligible. You can decline to provide this information without affecting your eligibility for any other Flo100 event or membership benefit. You may update or withdraw this information at any time through your member profile or by contacting us at info@flo100.com. You also have the right to ask us to confirm what information we hold about you, and we will provide that to you on request — see Section 12 (Your Rights).
3.3 Information from third-party sources (identity verification)
To protect the integrity of our rooms and confirm that members and applicants are who they say they are, we verify professional details against third-party data sources. Specifically:
We use People Data Labs (PDL) to retrieve professional information (such as work history, current role, and company affiliation) from publicly available and licensed business data sources.
We use Google Gemini to compare the information you have provided against the information returned from those sources and to flag any inconsistencies.
A member of the Flo100 team manually reviews every verification. The role of the automated system is to speed up the process and surface potential red flags — it does not make decisions about your membership on its own. You may request a fresh human review of any verification outcome at any time by contacting us at info@flo100.com.
3.4 Information collected automatically
When you use our website or our membership platform, we and our service providers may collect technical information including IP address, browser type, device identifiers, referring URL, pages visited, and the date and time of your visit. We use cookies and similar technologies to operate the site and to understand how it is used. See Section 9 (Cookies and Tracking Technologies).
4. HOW WE USE YOUR PERSONAL INFORMATION
We use the personal information we collect to:
Verify your identity and confirm you meet the criteria for the events and communities you wish to join
Operate our membership program (Flo100 Circle), including issuing digital membership passes
Plan, host, and follow up on events
Communicate with you about events, membership, and Flo100 updates you have asked to receive
Improve our services, understand engagement, and develop new programming
Comply with legal and regulatory obligations
Detect and prevent fraud, misuse, or harm
We rely on your consent for most processing, on legitimate interests (such as identity verification and event safety) where applicable under PIPEDA, and on legal obligation where required by law.
5. DIGITAL MEMBERSHIP PASSES
Flo100 Circle members receive a digital membership pass that can be saved to a mobile wallet. We currently issue passes through the Google Wallet API and intend to add Apple Wallet support.
A Flo100 membership pass typically contains:
Member name
Membership tier
Member ID
Issue date and expiry date
Flo100 branding and design elements
When you save a Flo100 pass to Google Wallet, the pass data is provided to Google so that the pass can be displayed and updated on your device. Google's handling of pass data is governed by Google's Privacy Policy. The same will apply to Apple Wallet once supported. You can delete a Flo100 pass from your wallet at any time directly within the wallet application.
6. HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell your personal information.
We share personal information only with the following categories of recipients:
6.1 Service providers and sub-processors
We use third-party service providers to operate our business — for example, identity verification (People Data Labs, Google Gemini), digital pass issuance (Google Wallet, Apple Wallet), email and messaging tools, customer relationship management, payment processing, calendar and scheduling, analytics, and cloud hosting. These providers may only use your information to perform services for Flo100, and they are bound by contractual confidentiality and data protection obligations.
6.2 Event co-organizers, sponsors, and venues
Flo100 events are often co-hosted with partner organizations or sponsors. When you apply to attend one of our events, we ask for your consent to share basic professional information — typically your name, company, and title — with the co-organizers and sponsors of that specific event, so they may follow up with you directly. Your consent is captured as a checkbox in the application form. Sharing only proceeds if your application is accepted and you attend the event, and is limited to the specific event for which you provided consent. We do not share the information of applicants who were not accepted, or of accepted applicants who did not attend.
Separately, we share guest lists with venue staff (such as restaurants, hotels, or private clubs) to manage entry, seating, and any dietary or accessibility needs you have provided. This is operational and limited to what the venue requires to host the event.
6.3 Partner introductions
From time to time, a Flo100 partner or fellow member may ask us to facilitate an introduction to another member. When that happens, we contact the member being requested first — typically by email — describe who is asking and why, and proceed only if that member agrees in writing. With consent, we facilitate the introduction by connecting the two parties directly, so the member can decide what to share. Without consent, we do nothing. We keep a record of all such requests and responses.
6.4 Other members at events
Flo100 events bring people into the same room. Your name, company, and title are visible to other attendees by virtue of being present. We do not publish member rosters publicly.
6.5 Legal disclosures
We will disclose personal information when required by law, court order, or regulatory authority, or to protect the rights, safety, or property of Flo100, our members, or others.
6.6 Business transfers
If Flo100 is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to the protections in this policy.
7. INTERNATIONAL DATA TRANSFERS
Flo100 is based in Canada. Some of our service providers — including People Data Labs (United States) and Google (global infrastructure) — process personal information in the United States and other countries. By using Flo100 services, you understand that your personal information may be transferred to and processed in jurisdictions outside Canada that may have different privacy laws.
We require our service providers to maintain a level of protection comparable to what your personal information receives in Canada, and we use contractual safeguards (such as standard contractual clauses or equivalent terms in our data processing agreements) where appropriate.
8. AUTOMATED PROCESSING
We use automated systems in two places in our operations:
Identity verification. The People Data Labs and Google Gemini pipeline described in Section 3.3 supports identity verification by accelerating the work and flagging potential inconsistencies. A member of the Flo100 team manually reviews every verification; the system does not make decisions about your membership on its own.
Themed-event prioritization. As described in Section 3.2, when we plan an event designed for a specific community, our system applies a positive weighting based on the optional gender, race, or ethnicity information you have provided. This weighting is one input our team considers when deciding who to invite. The decision is made by a person at Flo100, not by the system. You can decline to provide this information at any time, and doing so will not affect your eligibility for any other Flo100 event or membership benefit.
If you live in Quebec or another jurisdiction that gives you specific rights regarding automated decision-making, you have the right to be informed when an automated system has been used to render a decision about you, to know the principal factors and parameters involved, and to request a review of that decision by a person at Flo100. Contact us at info@flo100.com to make such a request.
9. COOKIES AND TRACKING TECHNOLOGIES
Our website uses cookies and similar technologies. Some are strictly necessary for the site to function (for example, to remember your login session). Others help us understand how the site is used and improve it (analytics).
Where required by law, we ask for your consent before placing non-essential cookies. You can manage your cookie preferences through the cookie banner on our website and through your browser settings. Disabling certain cookies may affect site functionality.
10. DATA RETENTION
We keep personal information for as long as necessary to provide our services to you and to fulfill the purposes described in this policy. When you cease to be a member or otherwise terminate your relationship with us, we will retain your information only as long as needed to:
Comply with our legal, accounting, and regulatory obligations
Resolve disputes
Enforce our agreements
Maintain a record of past event attendees for our own historical and operational reference
You may request deletion of your personal information at any time, subject to the exceptions above. See Section 12 (Your Rights).
11. SECURITY
We use reasonable physical, technical, and administrative safeguards to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These safeguards include access controls, encryption in transit, vetted service providers, and incident response procedures. No system is perfectly secure, and we cannot guarantee absolute security.
If we become aware of a security incident that compromises your personal information and creates a real risk of significant harm, we will notify you and applicable regulators as required by law.
12. YOUR RIGHTS
Subject to applicable law, you have the right to:
Access the personal information we hold about you
Correct information that is inaccurate or incomplete
Delete your personal information, subject to legal retention obligations
Withdraw consent to processing that relies on consent (without affecting prior lawful processing)
Port your information to another service in a structured, commonly used electronic format
Object to or restrict certain processing
Request human review of any decision made through automated processing
File a complaint with a privacy regulator
To exercise any of these rights, contact us at info@flo100.com. We will respond within the timelines required by applicable law (30 days under PIPEDA and Law 25, with extensions where permitted).
If you are not satisfied with our response, you may also file a complaint with:
Canada (federal): Office of the Privacy Commissioner of Canada — priv.gc.ca
Quebec: Commission d'accès à l'information du Québec — cai.gouv.qc.ca
Other jurisdictions: Your local data protection authority
13. CHILDREN
Flo100 services are intended for senior professionals and are not directed at children under the age of majority. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us and we will delete it.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy to reflect changes in our practices, our services, or applicable law. When we make material changes, we will post the updated policy on our website with a new effective date and, where appropriate, notify members directly.
15. HOW TO CONTACT US
For privacy questions, requests, or complaints, contact:
Flo100 Inc.
Attention: Privacy Officer
36 Lisgar Street
Toronto, Ontario M6J 0C7, Canada
16. QUEBEC-SPECIFIC PROVISIONS (LAW 25)
If you reside in Quebec, the following provisions apply in addition to the rest of this policy.
Person responsible for the protection of personal information. The Privacy Officer identified in Section 15 is the person responsible for the protection of personal information at Flo100, as required by section 3.1 of Law 25.
Data localization and transfer outside Quebec. Some of your personal information will be processed outside Quebec, including in the United States, by service providers such as People Data Labs and Google. Before transferring personal information outside Quebec, we conduct privacy impact assessments where required, and we use contractual protections to ensure the information receives a level of protection equivalent to what is provided under Quebec law.
Automated decision-making. Where an automated system is used to make a decision based exclusively on automated processing of personal information about you, you have the right to be informed, to know the principal factors and parameters involved, to make submissions to a person at Flo100 who can review the decision, and to have any inaccurate personal information corrected. As described in Section 8, identity verification at Flo100 always includes human review before any consequential decision.
Right to data portability. You may request that we communicate your personal information to you, or to a third party of your choosing, in a structured, commonly used technological format.
Complaint to the regulator. You may file a complaint with the Commission d'accès à l'information du Québec (cai.gouv.qc.ca) at any time.
Effective date: March 26, 2026