Customer Privacy Policy — The Managers Marketplace

The Market — Customer Privacy Policy

Effective Date: June 12, 2026

This Privacy Policy explains how The Managers Marketplace, a Canadian company (The Market, we, us, or our) collects, uses, discloses, and protects information in connection with The Market, including our website, applications, consultant marketplace, booking tools, payment flows, session hosting, administrative tools, artificial intelligence-enabled preparation and summary features, and related services (collectively, the Platform).

The Platform allows customers to discover and book consultants, schedule and host sessions, process payments, and use AI-enabled tools to support pre-session preparation and post-session summaries.

This Privacy Policy applies to Customers, website visitors, and other individuals who access the Platform to discover, book, or engage with consultant services. If you are a Consultant, please refer to our Consultant Privacy Policy.

1. Important Context

The Market is a Canadian marketplace and technology platform. Customers and Consultants may be located in Canada, the United States, or other jurisdictions where we make the Platform available. Customers and Consultants may share information with each other before, during, and after sessions. When you share personal information with a Consultant through the Platform — including during intake, messaging, or sessions — that Consultant receives your information in their capacity as an independent operator. The Market facilitates that connection but does not govern what the Consultant does with your information outside the Platform. Consultants are independently responsible for their own privacy compliance. We encourage you to review any privacy practices a Consultant makes available before sharing sensitive information with them. For more information about how Consultants are required to handle your data, see our Consultant Privacy Policy. This Privacy Policy describes our practices. It does not control the privacy practices of Consultants, Customers, payment processors, video providers, calendar providers, AI providers, or other third-party services.

Where required by applicable law, we rely on one or more of the following legal bases to process personal information: your consent; the performance of a contract to which you are a party or steps taken at your request before entering a contract; compliance with a legal obligation; our legitimate interests or those of a third party, provided those interests are not overridden by your interests or fundamental rights; and the protection of vital interests. Where we rely on consent as a legal basis, you may withdraw it at any time as described in this Policy, subject to legal or contractual restrictions.

2. Information We Collect

2.1. Information You Provide

We may collect information you provide directly, including:

name, email address, phone number, company, job title, account credentials, and contact details;
profile information, biographies, photos, credentials, expertise, categories, location, work history, links, portfolio materials, and social or professional handles;
booking requests, intake forms, project descriptions, goals, preferences, availability, scheduling information, session agendas, and notes;
messages, comments, reviews, ratings, feedback, support requests, and other communications;
payment, billing, payout, tax, GST/HST, PST/QST, withholding, identity verification, and fraud-prevention information;
session content, recordings, transcripts, summaries, action items, uploaded materials, prompts, and AI-assisted outputs;
administrator or team settings, permissions, and account configuration, if applicable to your account type; and
any other information you choose to submit through the Platform.

2.2. Information Collected Automatically

We may automatically collect information when you use the Platform, including:

device information, browser type, operating system, IP address, device identifiers, and approximate location;
log data, pages viewed, clicks, referring URLs, search activity, session activity, booking activity, feature usage, timestamps, and error reports;
cookies, pixels, SDKs, local storage, and similar technologies;
communications metadata, such as sender, recipient, time, and delivery status;
payment, fraud, risk, and security signals; and
analytics and performance information.

2.3. Information From Other Users and Third Parties

We may receive information about you from Customers, Consultants, administrators, teammates, payment processors, identity verification providers, tax providers, calendar providers, video providers, analytics vendors, AI providers, marketing partners, public sources, professional directories, referral sources, and other third parties.

For example, a Customer may provide a Consultant's name in a booking request, a Consultant may upload materials about a Customer engagement, an administrator may invite team members, or a payment processor may provide transaction status and risk information.

3. Sensitive Information

The Platform is not designed for unrestricted collection of sensitive information. Unless we expressly approve it in writing or provide a feature specifically intended for that data, you should not submit government identifiers, financial account credentials, health information, biometric information, precise geolocation, information about children, privileged information, trade secrets, or other highly sensitive information.

If you submit sensitive information, you represent that you have the right to do so and that you have provided all required notices and obtained all required consents.

4. Session Recordings, Transcripts, and AI Summaries

The Platform may allow or require sessions to be recorded, translated, transcribed, analyzed, or summarized. We may process session content to provide call hosting, troubleshooting, quality review, summaries, action items, translation-related features, analytics, dispute resolution, compliance, safety, and Platform improvement.

AI-assisted features may use session information, intake materials, profile information, prompts, notes, transcripts, recordings, and other Platform data to generate preparation materials, suggested questions, summaries, action items, tags, recommendations, and administrative insights.

We may use third-party AI, machine learning, transcription, speech-to-text, summarization, and automation providers to deliver AI Features. Information submitted to AI Features may be processed by such providers to generate summaries, action items, recommendations, classifications, preparation materials, and related outputs. The Market implements contractual, technical, and organizational safeguards it considers appropriate for the nature of the services, but no AI, machine learning, cloud, or third-party processing service can be guaranteed to be completely secure, confidential, accurate, or error-free. AI-generated outputs may be inaccurate or incomplete — users should review them before relying on or sharing them. You should not submit highly sensitive, regulated, privileged, confidential, or third-party information to AI Features unless expressly permitted by the Platform and authorized under all applicable legal, contractual, and confidentiality obligations.

5. How We Use Information

We may use information to:

provide, operate, maintain, secure, and improve the Platform;
create and manage accounts, profiles, bookings, sessions, payments, payouts, and support;
match Customers with Consultants and help users discover relevant services;
process payments, legally required refunds, credits, rescheduling fees, chargebacks, taxes, and payouts;
provide AI-enabled preparation, transcription, summarization, classification, search, recommendation, and administrative tools;
communicate about bookings, sessions, reminders, updates, policies, security, support, and account activity;
send transactional SMS, email, in-product, calendar, and similar notifications;
personalize content, search results, recommendations, and user experience;
analyze usage, revenue, marketplace performance, feature adoption, quality, and operational metrics;
detect, investigate, and prevent fraud, abuse, security incidents, policy violations, illegal activity, and circumvention;
enforce our Terms of Service, Booking Policy, and other agreements;
comply with law, legal process, tax obligations, accounting obligations, and regulatory requirements;
protect the rights, safety, property, and interests of The Market, users, vendors, and third parties; and
market our services, measure marketing performance, and develop new features, subject to applicable law and, where required, your consent.

6. How We Disclose Information

We may disclose information as described below.

6.1. Other Users

We disclose information between Customers, Consultants, administrators, and team members as needed to operate the marketplace. For example, we may show Consultant profiles to Customers, share Customer booking information with Consultants, display session status to administrators, or make session materials available to participants.

6.2. Service Providers and Vendors

We disclose information to vendors that help us provide the Platform, including hosting, data storage, payment processing, billing, identity verification, tax, video, calendar, email, SMS, messaging, real-time notification, analytics, customer support, security, fraud prevention, AI processing, automation, transcription, translation, domain, and marketing vendors. We enter into data processing agreements or equivalent contractual arrangements with service providers that process personal information on our behalf, requiring them to maintain appropriate security measures and process information only as directed.

Our current vendor stack may include Twilio for SMS notifications and transactional messaging; SendGrid for email notifications and transactional messaging; Pusher for real-time broadcasts and notifications; Daily.co for video chat, recording, transcription, or translation-related functionality; Google Cloud and Google Workspace tools for company email, calendar, storage, meeting recordings, and infrastructure; OpenAI API services for AI summaries, marketplace intelligence, and related AI Features; n8n for automation and workflow orchestration; Stripe and Stripe Connect for payments and Consultant payouts; DigitalOcean for backend hosting and databases; and Namecheap for domain services. We may add, remove, replace, or change vendors over time.

The Platform relies on third-party communications, cloud infrastructure, hosting, storage, collaboration, calendar, video, transcription, automation, payment processing, analytics, messaging, artificial intelligence, and related technology providers. Information may be disclosed to such providers as reasonably necessary to operate, maintain, secure, support, improve, and provide Platform functionality.

6.3. Payment Processors and Financial Partners

Payment and payout information may be collected or processed by third-party payment processors. These processors may use information under their own terms and privacy policies, including for compliance, fraud prevention, chargebacks, account underwriting, and legal obligations. To the extent payment processors independently determine the purposes and means of processing personal information in connection with their own legal, regulatory, fraud prevention, risk management, or compliance obligations, they do so under their own privacy policies and legal obligations.

6.4. AI and Automation Providers

We may disclose information to AI, machine learning, transcription, speech-to-text, summarization, search, classification, or automation providers to provide AI Features and related functionality. For a complete list of current vendors, see Section 6.2 above. We will update that list from time to time without rewriting this policy.

6.5. Business Customers and Account Administrators

If your account is associated with an organization, we may disclose information to that organization's account owner, administrators, billing contacts, or authorized personnel. This may include account activity, bookings, session information, usage, charges, team member information, and support information.

6.6. Legal, Safety, and Compliance

We may disclose information if we believe it is necessary or appropriate to comply with law, legal process, court orders, subpoenas, tax obligations, regulatory requests, law enforcement requests, or government inquiries; to enforce agreements; to protect rights, safety, property, and security; to investigate fraud, abuse, or violations; or to establish, exercise, or defend legal claims.

6.7. Business Transfers

We may disclose or transfer information in connection with a merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets, change of control, diligence process, or similar transaction.

6.8. Aggregated or De-Identified Information

We may use and disclose aggregated, de-identified, or anonymized information for analytics, benchmarking, research, product development, marketing, and other business purposes, provided it does not reasonably identify you.

7. Cookies and Similar Technologies

We and our vendors may use cookies, pixels, SDKs, local storage, and similar technologies to operate the Platform, remember preferences, authenticate users, measure performance, analyze usage, prevent fraud, improve features, and support marketing.

You can adjust browser settings to block or delete cookies, but some Platform features may not work properly. Where required by law, we will provide additional choices regarding certain cookies or targeted advertising technologies. Where required by applicable law, we display a cookie consent banner or preference centre that allows you to accept, reject, or customize non-essential cookies. You may update your cookie preferences at any time through the cookie settings link in the footer of our website or through your account settings.

8. Communications, Analytics, Advertising, and Marketing

We may use analytics and marketing tools to understand Platform usage, measure campaigns, improve the marketplace, and communicate with current or prospective users. We may send transactional messages (including SMS booking confirmations, reminders, and intake notices), email service updates, booking reminders, calendar notices, and policy notices. Marketing emails may be sent only where permitted by law and with required consent. Our SMS program is transactional only (see the SMS section below).

You may opt out of marketing emails by using the unsubscribe link in the email or contacting us at support@themanagersplaybook.com. Even if you opt out of marketing, we may still send transactional, legal, security, booking, payment, and account-related messages where permitted by law.

8.1 Canada's Anti-Spam Legislation (CASL)

We send commercial electronic messages in compliance with Canada's Anti-Spam Legislation. Where required, we obtain express or implied consent before sending commercial electronic messages and include our business name, mailing address, and an unsubscribe mechanism in each such message. Implied consent may arise from an existing business relationship, such as a recent booking, purchase, or inquiry. You may withdraw consent at any time using the unsubscribe link in any marketing email or by contacting us at support@themanagersplaybook.com. Withdrawal of consent from marketing messages does not affect transactional, legal, security, booking, payment, or account-related messages.

9. Data Retention

We retain information for as long as reasonably necessary to provide the Platform, manage accounts, complete transactions, comply with law, resolve disputes, enforce agreements, prevent fraud, maintain business records, support safety and security, and pursue legitimate business purposes.

To request deletion of your personal information, see Section 14 (Your Choices). We may retain certain information as required by law or for legitimate business purposes even after a deletion request.

As a general guide, we apply the following retention periods, subject to legal, tax, regulatory, or operational requirements that may require longer or shorter periods:

Account and profile information: We generally retain this information for the duration of your account and for up to two years after account closure.
Booking and transaction records: We generally retain booking, payment, refund, tax, and transaction records for seven years to support tax, accounting, legal, and audit obligations.
Session recordings and transcripts: We generally retain session recordings and transcripts for 90 days, unless a user elects to retain them for longer, they are needed for an active dispute, or a longer retention period is required by law.
AI-generated summaries and outputs: We generally retain AI-generated summaries, action items, and related outputs for 90 days, unless a user elects to retain them for longer or a longer period is required for legal, security, dispute-resolution, or operational purposes.
Payment and payout records: We generally retain payment and payout information for seven years, including where necessary for tax, accounting, fraud prevention, chargeback handling, and legal compliance.
Communications and support records: We generally retain customer communications, messages, and support records for three years.
Log data and analytics: We generally retain log data, analytics data, and similar technical usage information for up to 13 months.
Identity verification records: We retain identity verification information for the period required by applicable law, the relevant identity verification provider, and our fraud-prevention, compliance, and recordkeeping obligations.

Retention periods may vary depending on the type of information, user role, account status, legal obligations, payment or tax requirements, dispute history, backup cycles, and operational needs. We may retain recordings, transcripts, summaries, messages, transaction records, and logs for different periods.

We may delete, aggregate, or de-identify information when it is no longer needed.

The Market may retain certain categories of information for longer periods where required to comply with legal, accounting, tax, regulatory, dispute resolution, fraud prevention, security, or recordkeeping obligations.

10. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect information. No system, network, transmission, or storage method is completely secure. The Platform relies on third-party cloud, hosting, storage, communications, artificial intelligence, automation, payment processing, messaging, and infrastructure providers. While we take measures designed to protect information, we cannot guarantee that any third-party provider, network, platform, system, transmission, storage environment, or security control will be uninterrupted, error-free, immune from attack, or completely secure. We cannot guarantee absolute security, and users are responsible for protecting account credentials, devices, and access permissions.

10.1 Security Incidents and Breach Notification

In the event of a breach of security safeguards involving personal information under our control, we will assess the risk of harm and take appropriate steps in accordance with applicable law. Where a breach creates a real risk of significant harm to individuals, we will notify affected individuals and, where required, the applicable privacy regulator (including the Office of the Privacy Commissioner of Canada and, for Quebec residents, the Commission d'accès à l'information) within legally required timeframes. Notifications will include a description of what happened, the type of information involved, steps we have taken or plan to take, and what individuals can do to protect themselves. We maintain records of all breaches as required by law, regardless of whether notification is required.

11. Cross-Border Processing

We are a Canadian company, but we may process and store information in Canada, the United States, and other countries where we, our users, or our service providers operate. This means personal information may be transferred outside your province, state, or country of residence and may be accessible to courts, law enforcement, regulators, or government authorities in those jurisdictions according to local law.

We use contractual, technical, organizational, and vendor-management measures we consider appropriate for the nature of the information and services involved. Where Canadian privacy laws apply, we seek to provide meaningful information about our practices so users can understand the nature, purposes, and reasonably foreseeable consequences of collection, use, disclosure, and cross-border processing.

If you access the Platform from outside Canada, you acknowledge that your information may be transferred to, processed in, and stored in countries whose privacy laws may differ from those in your jurisdiction. Where applicable law requires additional safeguards for international transfers — such as standard contractual clauses or equivalent mechanisms — we will implement them. If we offer the Platform in jurisdictions with specific privacy requirements, we may provide supplemental notices at the point of collection.

12. Canadian Privacy Rights

The Market is responsible for personal information under its control and has designated a Privacy Officer responsible for overseeing compliance with applicable privacy laws. The Market determines the purposes and means by which personal information is collected, used, disclosed, retained, and otherwise processed in connection with the Platform. Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act and substantially similar provincial private-sector privacy laws where applicable, give individuals rights to access and correct their personal information, withdraw consent subject to legal or contractual restrictions, ask questions about our privacy practices, and challenge our compliance. If you reside within Canada, you may exercise these rights at any time by contacting our office, though we may need to verify your identity and authority before responding to or processing your inquiry. We may decline or limit a request where permitted or required by law, including situations where information is subject to legal privilege, confidential commercial information, another person's privacy rights, security needs, fraud prevention, legal compliance, dispute resolution, payment or tax records, or other lawful restrictions. If you choose to withdraw your consent for data processing that is strictly necessary to provide the Platform, certain features, services, or marketplace functionalities may no longer be available to you.

For individuals residing in the Province of Quebec, your privacy rights are additionally protected under the Act respecting the protection of personal information in the private sector (Law 25). In addition to the standard access and correction frameworks outlined in this clause, Quebec residents have a right to data portability, which permits you to request that any computerized personal information we have actively collected from you be provided in a structured, commonly used technological format. If our automated systems or underlying algorithms are used to make decisions that significantly impact your account profile, marketplace ranking, or transactional access, you have the right to be informed at the time of the processing, understand the core operational logic of the decision, and submit observations or challenges directly to our team. Quebec residents may also request the deletion of personal information where permitted by applicable law and subject to legal, regulatory, accounting, tax, security, fraud prevention, dispute resolution, and recordkeeping requirements.

The Market conducts privacy impact assessments before implementing new information systems, acquiring technology, or communicating personal information outside Quebec, where required by Law 25. These assessments evaluate the privacy risks of proposed activities and the measures implemented to mitigate them.

The Market maintains a register of confidentiality incidents as required by Law 25. If a confidentiality incident presents a risk of serious injury to a person, we will notify the Commission d'accès à l'information and affected individuals in accordance with the timeframes and requirements of Law 25. You may contact our Privacy Officer at privacy@themanagersplaybook.com to inquire about incidents that may have affected your personal information.

In accordance with Law 25, The Market has designated its Privacy Officer as the person responsible for the protection of personal information. The Privacy Officer is responsible for overseeing compliance with applicable privacy laws, responding to privacy-related inquiries, and administering privacy rights requests.

Where our automated systems make decisions that significantly affect your account profile, marketplace ranking, or access to the Platform, we will notify you at the time such a decision is made, explain the principal parameters used, and give you the opportunity to submit observations or request human review. This notice will be delivered through your account dashboard or by email at the time the decision is made.

13. Children's Privacy

The Platform is intended for adults and business users. We do not knowingly collect personal information from children under 13, and the Platform is not directed to children. If you believe a child has provided us personal information, contact us at support@themanagersplaybook.com.

14. Your Choices

Depending on your location and relationship with us, you may have rights to access, correct, delete, port, restrict, or object to certain processing of your personal information; opt out of certain disclosures, sales, sharing, targeted advertising, profiling, or marketing; withdraw consent; or appeal a privacy rights decision.

To make a request, contact us at support@themanagersplaybook.com. We may need to verify your identity and authority before processing a request. We may deny or limit requests where permitted by law, including where retention is necessary for security, legal compliance, transactions, tax, dispute resolution, fraud prevention, or other legitimate purposes.

If your information is controlled by a Customer, Consultant, or organization that uses the Platform, we may direct you to that party or process your request on its behalf, depending on our role and applicable law.

15. U.S. State Privacy Notice

Certain U.S. state privacy laws may provide residents with specific rights and require specific disclosures. This section applies where such laws apply to The Market.

16. Categories of Personal Information

We may collect the following categories of personal information:

identifiers, such as name, email, phone number, account ID, IP address, and device identifiers;
customer records information, such as billing, payment, payout, tax, and contact information;
commercial information, such as bookings, purchases, session history, refunds, payouts, and transaction records;
internet or electronic activity, such as usage data, logs, clicks, pages viewed, and interactions;
geolocation information, such as approximate location inferred from IP address;
audio, electronic, visual, or similar information, such as recordings, transcripts, messages, and session materials;
professional or employment-related information, such as title, company, expertise, work history, credentials, and Consultant profile details;
inferences, such as preferences, marketplace fit, likely interests, quality signals, and recommendations; and
sensitive personal information, if you choose to provide it or if needed for payment, tax, identity, security, or compliance purposes.

16.1. Sources

We collect information from you, other users, your organization, service providers, payment processors, identity verification providers, analytics tools, AI providers, public sources, referral sources, and automated technologies.

16.2. Purposes

We use information for the purposes described in Section 5, including providing the Platform, managing bookings and payments, supporting AI Features, security, fraud prevention, compliance, analytics, support, marketing, and business operations.

16.3. Disclosures

We disclose information to the categories of recipients described in Section 6, including other users, vendors, payment processors, AI providers, administrators, legal recipients, and transaction counterparties in business transfers.

16.4. Sale, Sharing, and Targeted Advertising

We do not sell personal information for money. Some state laws define sale, sharing, or targeted advertising broadly to include certain disclosures involving advertising or analytics technologies. If we use technologies that qualify, we will provide legally required opt-out mechanisms.

You may contact us at support@themanagersplaybook.com. to opt out of sales, sharing, targeted advertising, or certain profiling where applicable. If required by law, we will honor recognized opt-out preference signals in the manner required.

16.5. Sensitive Personal Information

We do not use sensitive personal information to infer characteristics except as permitted by law. We use sensitive personal information for purposes such as payment processing, tax, identity verification, security, fraud prevention, legal compliance, and providing requested services.

16.6. Non-Discrimination

We will not unlawfully discriminate against you for exercising privacy rights. We may offer different features, pricing, or service levels where permitted by law and reasonably related to the value or nature of the data or service.

17. California Privacy Rights

If the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the CCPA), applies to The Market and to your information, California residents may have rights to know, access, correct, delete, opt out of sale or sharing, limit certain uses of sensitive personal information, and not be discriminated against for exercising rights.

To exercise California rights, contact us at support@themanagersplaybook.com.

California's Shine the Light law may allow California residents to request certain information about disclosures of personal information to third parties for their direct marketing purposes. To make such a request, contact us at support@themanagersplaybook.com.

18. Authorized Agents

Where applicable law allows you to use an authorized agent, we may require proof that you authorized the agent and may also require you to verify your identity directly with us, unless prohibited by law.

19. Do Not Track

Some browsers transmit Do Not Track signals. Because there is no uniform industry standard for responding to those signals, we do not currently respond to them. We may respond to legally required universal opt-out mechanisms where applicable.

20. Third-Party Links and Services

The Platform may contain links to, or allow you to navigate to, third-party websites, tools, or services that are not operated or controlled by The Market — for example, a Consultant's external website, a linked resource, or a third-party scheduling tool you choose to use independently. If you follow a link to a third-party service or choose to use a third-party tool outside the Platform, that service operates under its own privacy policy and terms of service, and The Market is not responsible for its privacy or data handling practices. We encourage you to review the privacy policies of any third-party services you choose to use.

For information about the vendors and service providers The Market works with directly to operate the Platform, see Section 6.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the Platform, by email, or by other reasonable means. The updated Privacy Policy will be effective when posted unless a later effective date is stated.

Mobile / SMS information

The Managers Marketplace operates at https://themanagersplaybook.com. We use phone numbers you provide on our public booking forms to send transactional SMS related to bookings and account activity (confirmations, reminders, intake notices, and updates). Message frequency varies based on your booking activity. Message and data rates may apply.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. We do not share, sell, or provide your mobile phone number or messaging consent / opt-in data to third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties. All other categories of data sharing described elsewhere in this Privacy Policy exclude text messaging originator opt-in data and consent.

For help with SMS, reply HELP or email support@themanagersplaybook.com. To opt out, reply STOP. Public SMS opt-in example (unchecked checkbox + disclosures): https://themanagersplaybook.com/sms-opt-in.