Privacy Policy

ENHANCE ENTERPRISE INC. (d/b/a Finally)

Last Updated: April 29, 2026

1. Introduction

1.1 We are committed to safeguarding the privacy of our App and Services users.

1.2 This policy applies to all Finally Application, as defined in the Terms of Service, and services, including our applications, websites, features, and other services (collectively, the “App” and/or the “Services”) where we are acting as a data controller with respect to the personal data of our App and Services users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website and application. Insofar as those cookies are not strictly necessary for the provision of our App and Services, we will ask you to consent to our use of cookies when you first visit our App.

1.4 In this policy, “we”, “us” and “our” refer to Enhance Enterprise Inc., d/b/a Finally.

1.5 This Policy is incorporated as part of the Finally Terms of Service and your use of the App or of the Services indicates your consent to it.

2. How we use your personal data

2.1 In this Section 2 we have set out:

the general categories of personal data that we may process;
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
the purposes for which we may process personal data; and
the legal basis of the processing.

2.2 We may process data about your use of our App and Services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, length of visit, page views and App navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the App and Services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our App and Services.

2.3 We may process your account data (“account data”). The account data may include your name and email address, and any third-party authentication identifiers used at sign-up. The account data may be processed for the purposes of operating our App, providing our Services, ensuring the security of our App and Services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our App and business.

2.4 We may process your information included in your personal profile on our App (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, height, weight, your selected Weekly Cadence, your designated User Training Area (including a photograph of your training area), and other related information you choose to provide regarding your fitness and training. The profile data may be processed for the purposes of enabling and monitoring your use of our App and Services, including determining whether sessions are completed for the purposes of the Penalty and the Side Goal. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our App and business. [NTD: Salary/income information was previously collected to scale the Penalty. Because the Penalty is now a flat per-missed-session amount, salary information should no longer be collected unless used for another purpose. If income data is still collected for any reason, that purpose must be added here and consent obtained accordingly.]

2.5 We may process your personal data that are provided in the course of the use of our Services (“service data”). The service data may include your real-time location data while sessions are active (used to determine whether you are inside your User Training Area), your designated User Training Area, your session activation and completion records, your Penalty history, your Side Goal status and history, your Finally XP balance and transaction history (including any redemptions in the in-app marketplace and any entries to a Cash Prize Drawing), and any information you provide while participating in a contest, drawing or promotion. The service data may be processed for the purposes of operating our App, providing our Services, ensuring the security of our App and Services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and the performance of a contract between you and us, namely the Terms of Service.

2.6 We may process information that you post for publication on our App or through our Services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our App and Services. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our App and business.

2.7 We may process information contained in any enquiry you submit to us regarding subscriptions, goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant subscriptions, goods and/or services to you. The legal basis for this processing is consent.

2.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent or our legitimate interests, namely the proper management of our customer relationships.

2.9 We may process information relating to transactions, including the per-missed-session Penalty, any Premium Subscription fees, and purchases of goods and services made through our App (“transaction data”). The transaction data may include your contact details, the amount and date of each Penalty charged, the amount and date of any Premium Subscription fee charged, any purchase made with Finally XP on our App, your card details (or a tokenized reference to your payment method, as held by our payment processor), and the transaction details. The transaction data may be processed for the purposes of supplying the purchased subscriptions, goods and services, charging Penalties as authorised under the Terms of Service, processing refunds in connection with the Side Goal, and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and our legitimate interests, namely the proper administration of our App and business.

2.10 We may process information that you provide to us for the purpose of subscribing to our email and App notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications, push notifications, emails, information and/or newsletters pertaining to the Services, including reminders to complete training sessions and notifications regarding Penalties, Side Goal progress, and Cash Prize Drawings. The legal basis for this processing is consent or the performance of a contract between you and us.

2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our App and business and communications with users.

2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.15 Please do not supply us with any other person’s personal data, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your account data, your profile data, your service data, your publication data, your enquiry data, your correspondence data, your transaction data, and your customer relationship data to our suppliers or subcontractors insofar as reasonably necessary for the provision of the App and Services.

3.4 Payment processor. Financial transactions relating to our App and Services — including the per-missed-session Penalty, any Premium Subscription fees, and any refunds in connection with the Side Goal — are handled by our third-party payment processor [INSERT NAME OF PAYMENT PROCESSOR]. We will share transaction data with our payment processor only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment processor’s privacy policies and practices at: [INSERT URL OF PAYMENT PROCESSOR PRIVACY POLICY]. [NTD: This Privacy Policy must name the actual payment processor used at launch and link to its privacy policy. The previous version named Stripe; this should be replaced with the actual processor selected for the per-missed-session model. If different processors are used for the Penalty (recurring card-not-present charges) and the Premium Subscription (Google Play in-app billing or Apple in-app billing), each should be named here.]

3.5 Other service providers. Customer service relating to our App and Services, third party suppliers of goods and services identified on our App, and certain functionalities of our App are handled by our third party providers. These currently include: Google Authentication, Google Firebase, Google Cloud, Google AdMob, Twilio, and Amazon Web Services (AWS). We may share account data, profile data, service data, correspondence data, customer relationship data, and transaction data with these providers only to the extent necessary for the purposes set out in this policy. You can find information about these providers’ privacy policies and practices at:

Google services (including Authentication, Firebase, Cloud, AdMob): https://policies.google.com/privacy/
Amazon Web Services: https://aws.amazon.com/privacy/
Twilio: https://www.twilio.com/legal/privacy/

[NTD: Update this list as service providers are added or removed. Confirm whether Facebook Authentication is still in use; the previous version listed it but it can be removed if not.]

3.6 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our App for the purpose of enabling them to contact you so that they can offer, and sell to you, relevant goods and/or services. You can find information about third party service providers’ privacy policies and practices at: [LIST EACH SUCH THIRD PARTY AND LINK TO ITS PRIVACY POLICY]. Each such third party will act as a data controller in relation to the enquiry data that we supply to it, and each such third party has its own privacy policy, which will govern that third party’s use of your personal data. We advise you to read carefully those third parties’ privacy policies.

3.7 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. Retaining and deleting personal data

4.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes, including providing you our App and Services.

4.3 Finally provides ways for you to access and delete your personal data as well as exercise other data rights which give you a certain control over your personal information.

4.3.1 Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of the App and Services, including notifications of Penalties charged and Side Goal progress.

4.3.2 Push Notifications. You can opt out of receiving push notifications through your app settings. Please note that opting out of receiving push notifications may impact your use of the App and Services, including your ability to receive timely reminders about upcoming sessions.

4.3.3 Profile Information. You can review and edit certain account information you have chosen to add to your profile by logging into your account settings and profile.

4.3.4 Cookie Tracking. You can modify your cookie settings on your browser and, from time to time, if enabled, on your mobile device, but if you delete or choose not to accept our cookies, you may be missing out on certain features of the App.

4.3.5 Do Not Track. Your browser or mobile device may offer you a “Do Not Track” option, which allows you to signal to operators of websites and applications and services that you do not want them to track your online activities. The App does not currently support Do Not Track requests at this time.

4.3.6 Deleting Your Account. If you would like to delete your Account, please contact Finally through the email or the phone provided on the website, or use the in-App account-closure flow. In some cases, we will be unable to immediately delete your account, such as if there is an issue with your account related to trust, safety, or fraud, or if there are unpaid Penalties, unresolved disputes, or amounts otherwise owing under the Terms of Service. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations, including a record of any Penalties charged and Side Goal refund balances held under the 12-month return period described in the Terms of Service. When we retain such data, we do so in ways designed to prevent its use for other purposes.

4.4 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Amendments

5.1 We may update this policy from time to time by publishing a new version on our App.

5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

5.3 We may notify you of significant changes to this policy by email or through notification on our App.

6. Your rights

6.1 In this Section, we have summarized the rights that you have under data protection law, including the Personal Information Protection and Electronic Documents Act (Canada) and the Act respecting the protection of personal information in the private sector (Quebec), as applicable. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2 You have choices regarding our use and disclosure of your personal data:

6.2.1 Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

6.2.2 To see or change your account personal data. If you would like to review, correct, or update personal data that you have previously disclosed to us, you may do so by signing into your account or by contacting us.

6.2.3 Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to your personal data:

the right to request confirmation of whether Finally processes personal data relating to you, and if so, to request a copy of that personal data;
the right to request that Finally rectify or update your personal data that is inaccurate, incomplete or outdated;
the right to request that Finally erase your personal data in certain circumstances provided by law;
the right to request that Finally restrict the use of your personal data in certain circumstances, such as while Finally considers another request that you have submitted (including a request that Finally make an update to your personal data); and
the right to request that we export to another company, where technically feasible, your personal data that we hold in order to provide the App and Services to you.

6.2.4 Consent. Where the processing of your personal data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your personal data on grounds relating to your particular situation.

6.2.5 Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Finally as described in the “Our details” Section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your personal data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country. In Quebec, you may file a complaint with the Commission d’accès à l’information du Québec. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

6.2.6 For your protection, we may need to verify your identity before responding to your request, such as by verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process personal data about you in order to provide our App and Services, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

7. About cookies

7.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a server to a browser or your device and is stored by the browser or your device. The identifier is then sent back to the server each time the browser or device requests a page from the server.

7.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser or device and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

7.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

8. Cookies that we use

8.1 We use cookies for the following purposes:

authentication — we use cookies to identify you when you visit our website and as you navigate our website or App;
status — we use cookies to help us determine if you are logged into our website or App;
personalization — we use cookies to store information about your preferences and to personalize our website or App for you;
security — we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
analysis/tracking — we use cookies to help us recognise and count the number of visitors and analyse use of the services, as well as to verify transactions;
advertising — we use cookies to help us display advertisements that will be relevant to you; and
cookie consent — we use cookies to store your preferences in relation to the use of cookies more generally.

9. Cookies used by our service providers

9.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website or our App.

9.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy/.

9.3 The relevant Google Analytics cookies are: rc::c (used to distinguish humans from bots) and collect (used to send data to Google Analytics about the visitor’s device and behaviour, tracks the visitor across devices and marketing channels).

9.4 We use [INSERT NAME OF PAYMENT PROCESSOR] to allow Users to be charged for any Penalty owed under the Terms of Service and for any Premium Subscription fees, and to receive any refunds in connection with the Side Goal. Our payment processor uses cookies to enable the proper functioning of the payment flows and to allow reporting and analytics. Its privacy policy is available at: [INSERT URL].

[NTD: The previous version of this Privacy Policy named Stripe and listed Stripe-specific cookies. Update this section to reflect the actual payment processor selected and its specific cookies once finalized.]

10. Managing cookies

10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

10.2 Blocking all cookies will have a negative impact upon the usability of many websites.

10.3 If you block cookies, you will not be able to use all the features on our website and/or our Services.

11. Our details

11.1 This website is owned and operated by Enhance Enterprise Inc.

11.2 We have designated [INDIVIDUAL NAME] as the Privacy Officer of Finally. You may address any inquiries relating to your confidential information and data to [INDIVIDUAL NAME] by contacting [EMAIL].

11.3 We are registered in Québec, Canada, and our registered office is at [ADDRESS].

11.4 You can contact us:

by post, to the postal address given above;
using our website or App contact form;
by telephone, on the contact number published on our website from time to time; or
by email, using the email address published on our website from time to time.