Pure Forward MarketingHome

Privacy Policy

Effective date: October 20, 2026
Last updated: October 31, 2026

1. Who we are

This Privacy Policy explains how 28 Corp., a corporation headquartered in Calgary, Alberta, Canada, operating as "Pure Forward" ("Pure Forward," "we," "us," "our"), collects, uses, discloses and protects personal information. It applies to our website at pureforward.com (the "Site") and to our advertising, lead-generation, coaching, training, podcast and related services (the "Services").

We are subject to Alberta's Personal Information Protection Act (PIPA) and, where personal information crosses provincial or national borders, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). We also aim to meet the privacy expectations of our clients and visitors in the United States.

Contact / Privacy Officer: Cameron O'Brien, Founder, 28 Corp., 1122 3 St SE, Ste 1906-498, Calgary, Alberta T2G 1H7, Canada. Email: privacy@pureforward.com

2. Whose information this policy covers

3. Information we collect

Information you give us:
- Contact details: name, email, phone number, business name, brokerage, market area, and licence status.
- Booking and inquiry details, including answers to intake questions.
- Billing information. We use Stripe and Venn Bank to process payments. We do not store full card numbers.
- Account and program information: login details, course progress, call recordings (with notice), submitted assignments, and community posts.
- Communications with us, including email, SMS, calls and messages.
- Testimonials or reviews you choose to provide (published only with your permission).

Information collected automatically:
- Device and usage data: IP address, browser type, pages viewed, referring URLs, time on page, and approximate location derived from your IP address.
- Cookies, pixels and similar technologies (see Section 5).

Information from third parties:
- Advertising and social platforms such as Meta (Facebook/Instagram), including lead form submissions and ad performance data.
- Clients' CRMs or ad accounts we are given access to in order to deliver the Services.
- Scheduling, payment and analytics providers.

We do not knowingly collect sensitive information such as health, financial account, or government ID numbers through lead forms or our Site, and we ask that you not submit it.

4. Why we use personal information

We use personal information to:
1. Respond to inquiries, book consultations, and provide proposals.
2. Deliver the Services, including setting up and managing ad campaigns, building lead forms, routing leads to clients, reporting, and providing coaching and training.
3. Process payments, invoicing and taxes, and keep business records.
4. Communicate with you about your account, programs and service updates.
5. Send marketing communications where permitted by law (for example, with your consent under Canada's Anti-Spam Legislation). You can unsubscribe at any time.
6. Measure and improve our Site, ads and Services, including through analytics and advertising measurement.
7. Protect our business, prevent fraud and abuse, enforce our agreements, and comply with legal obligations.

We will not use your personal information for a new purpose without telling you and, where required, getting your consent.

5. Cookies, the Meta Pixel and similar technologies

We and third parties, including Meta Platforms, Inc., use cookies, pixels (including the Meta Pixel), web beacons, the Meta Conversions API and similar technologies on our Site. These collect or receive information from our Site and elsewhere on the internet, and the third parties use it to provide measurement services and to target and deliver ads. We use tools from Meta and Google for analytics and advertising.

6. Lead data we handle for our clients

When we run ads for a client (for example, a real estate agent) and you submit a lead form on Facebook, Instagram, or a landing page, your information is collected for that client. The client decides how to follow up with you, for example by calling, texting or emailing about buying or selling a home. The client's own privacy policy, linked on the form, governs their use of your information. We process lead data only on the client's behalf and under their instructions, to deliver and measure the campaign and route your information to them. We do not sell lead data, and we do not combine one client's leads with another client's data. To exercise your rights over lead data, contact the agent or brokerage named on the form. If you contact us, we will forward your request to them.

7. How we share personal information

We do not sell personal information. We share it only:
- With service providers who help us operate, under contracts that limit their use of your information. Our service providers include Google Cloud for website hosting; GoHighLevel for CRM, marketing automation, scheduling and course hosting; GoHighLevel and Google for email delivery; Stripe and Venn Bank for payments; Zoom and Zencastr for video conferencing; and GoHighLevel, Google Workspace and Google Cloud for cloud storage.
- With advertising platforms, chiefly Meta, as described in Section 5.
- With our clients, in the case of lead data (Section 6).
- With professional advisers such as lawyers, accountants and insurers, under confidentiality obligations.
- For legal reasons: to comply with law or legal process, to protect rights and safety, or in connection with a merger, financing or sale of all or part of our business (subject to confidentiality and continued protection).

Service providers outside Canada (Alberta PIPA notice). Several of our service providers, including Meta, Google, GoHighLevel, Zoom, Zencastr and Stripe, are located in or store data in the United States. They are authorized to collect, use, store and disclose personal information only to host our systems, deliver and measure advertising, manage client relationships and communications, process payments, and provide related support to us. While your information is outside Canada, it may be accessible to courts, law enforcement and national security authorities in those countries. For written information about our policies and practices for service providers outside Canada, or for questions about how they collect, use, disclose or store personal information, contact Cameron O'Brien, Founder, at privacy@pureforward.com.

YouTube API Services. Our internal publishing tool uses YouTube API Services to upload our own podcast episodes to our own YouTube channel. It does not access, collect or store any information about other users. Use of YouTube API Services is subject to the YouTube Terms of Service (https://www.youtube.com/t/terms) and the Google Privacy Policy (https://policies.google.com/privacy).

8. How long we keep information

We keep personal information only as long as needed for the purposes in this policy, or as required by law. Typical periods:
- Client and billing records: 7 years, for tax purposes.
- Prospect information: 24 months after last contact.
- Client lead data: leads generated for a client belong to that client. Pure Forward may retain client lead data for up to 24 hours to address an automated lead-transfer failure. We delete the retained lead data within that period.

At the end of the applicable retention period, we securely delete or anonymize client, billing and prospect information.

9. How we protect information

We use reasonable administrative, technical and physical safeguards, including:
- access controls and multi-factor authentication;
- encryption in transit;
- least-privilege access to client ad accounts and CRMs;
- vetted service providers;
- staff confidentiality obligations.

No system is perfectly secure. If a privacy breach creates a real risk of significant harm, we will notify the appropriate regulators and affected individuals as the law requires.

10. Children

Our Site and Services are intended for adults and business professionals. They are not directed to children under 13 (or under 16 where local law sets a higher age). We do not knowingly collect their personal information. If you believe a child has given us information, contact us and we will delete it.

11. Your rights and choices

Subject to legal limits, you may:
- ask what personal information we hold about you and how it has been used and disclosed;
- request a copy;
- ask us to correct inaccurate information;
- withdraw consent to certain uses, on reasonable notice, unless a legal or contractual restriction applies;
- ask us to delete information we no longer need;
- unsubscribe from marketing emails or texts at any time, using the unsubscribe link or by replying STOP.

To make a request, email privacy@pureforward.com. We may need to verify your identity. We will respond within 30 days (or the period required by law). If you are not satisfied, you may contact the Office of the Information and Privacy Commissioner of Alberta (oipc.ab.ca) or the Office of the Privacy Commissioner of Canada (priv.gc.ca).

12. US State Privacy Rights

Depending on where you live, US state privacy laws (such as those of California, Colorado, Connecticut, Virginia, Texas and others) may give you rights to:
- know or access, correct and delete personal information;
- obtain a portable copy;
- opt out of targeted advertising, "sale" or "sharing";
- appeal a decision on a request.

We may not be legally required to comply with all of these laws. Even so, we will honour reasonable requests from US residents in the same way as Section 11. We do not sell personal information for money. Some use of advertising cookies may be considered "sharing" or "targeted advertising" under certain state laws. You can manage cookies through your browser settings or contact us by email about your privacy choices. We will not discriminate against you for exercising your rights.

California (CalOPPA): This policy describes the categories of personally identifiable information we collect (Section 3), the third parties we share it with (Sections 5–7), how you can review and request changes (Section 11), our Do Not Track response (Section 5), how we notify you of changes (Section 14), and the effective date (top).

13. Marketing communications

We send commercial emails and texts only as permitted by Canada's Anti-Spam Legislation (CASL), the US CAN-SPAM Act, and applicable telemarketing laws. Every marketing email identifies us, includes our mailing address, and has a working unsubscribe link. We process opt-outs within 10 business days.

14. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new "Last updated" date. If changes are material, we will notify you by email or by a prominent notice on the Site before they take effect. Where required, we will seek your consent.

15. Contact us

Cameron O'Brien, Founder, 28 Corp. (operating as Pure Forward), 1122 3 St SE, Ste 1906-498, Calgary, Alberta T2G 1H7, Canada. Email: privacy@pureforward.com