PRIVACY POLICY

Form Products Group Ltd., operating as Form Insoles

Last Updated: March 30, 2026

1. Introduction

Form Products Group Ltd., an Alberta corporation operating as Form Insoles (“we,” “us,” or “our”), is committed to protecting the privacy and personal information of our customers, website visitors, and other individuals who interact with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at forminsoles.com, place an order, or otherwise interact with us.

We manage your personal information in accordance with Alberta’s Personal Information Protection Act (“PIPA”) and, where applicable, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) of Canada. This policy also addresses our obligations under Canada’s Anti-Spam Legislation (“CASL”).

By using our website or providing us with your personal information, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use our website or provide us with your personal information.

2. Definitions

Personal Information means information about an identifiable individual, as defined under PIPA and PIPEDA. This includes, but is not limited to, your name, address, email address, telephone number, payment information, and purchase history. It does not include the name, title, business address, or telephone number of an employee of an organization that is used for business purposes.

Privacy Officer means the individual designated by Form Insoles as responsible for our compliance with this Privacy Policy and applicable privacy legislation. Questions, concerns, or complaints regarding our privacy practices should be directed to our Privacy Officer using the contact information in Section 14 of this policy.

3. Accountability

Form Insoles is responsible for personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Privacy Policy and applicable privacy legislation. Our Privacy Officer can be reached using the contact information provided in Section 14.

We are responsible for personal information in our possession or custody, including information that has been transferred to a third party for processing. When we transfer personal information to third parties for processing, we use contractual or other means to ensure that the information is protected to a comparable level.

4. Information We Collect

4.1 Information You Provide Directly

When you interact with us, we may collect the following personal information that you voluntarily provide: your name and contact information (email address, mailing address, telephone number); billing and shipping addresses; payment information (credit card number, expiration date, and security code), which is processed securely through our payment processor and is not stored on our servers; account credentials if you create an account on our website; order history and product preferences; and any correspondence or communications you send to us, including customer service inquiries, product reviews, and feedback.

4.2 Information Collected Automatically

When you visit our website, we automatically collect certain information through cookies and similar technologies, including: your IP address and approximate geographic location; browser type and version, operating system, and device information; pages you visit on our site, time spent on each page, and navigation patterns; referring website or search terms that brought you to our site; and information about your interactions with our emails, such as whether you opened them or clicked on links.

4.3 Information from Third Parties

We may receive information about you from third-party sources, including: our e-commerce platform provider (Shopify Inc.); payment processors; shipping and logistics providers; marketing and advertising partners; and analytics services.

5. Purposes for Collection, Use, and Disclosure

We collect, use, and disclose your personal information only for purposes that a reasonable person would consider appropriate in the circumstances. These purposes include:

Processing and Fulfilling Orders. To process your purchases, arrange shipping and delivery, process payments, and communicate with you about the status of your order.

Customer Service. To respond to your inquiries, provide product support, process returns or exchanges, and resolve complaints.

Account Management. To create and manage your customer account, maintain your order history, and facilitate future purchases.

Marketing and Communications. With your consent, to send you information about our products, promotions, and events. You may withdraw your consent to receive marketing communications at any time (see Section 7).

Website Improvement and Analytics. To analyse how visitors use our website, improve site functionality and user experience, and develop new products and services.

Fraud Prevention and Security. To detect and prevent fraudulent transactions, protect against unauthorized access to our systems, and ensure the security of our website and your personal information.

Legal Compliance. To comply with applicable laws, regulations, court orders, or governmental requests, and to establish, exercise, or defend legal claims.

6. Consent

We obtain your consent before or at the time we collect your personal information. The form of consent we seek, including whether it is express or implied, will depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.

You may provide consent in the following ways: expressly, by actively agreeing to the collection, use, or disclosure of your personal information (for example, by checking a consent box or providing information on an order form); or impliedly, where the purpose of the collection, use, or disclosure would be considered obvious to a reasonable person and you voluntarily provide your information (for example, by providing your shipping address to complete an order).

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we will inform you of the likely consequences of doing so, which may include our inability to provide you with certain products or services. To withdraw consent, please contact us using the information in Section 14.

7. Commercial Electronic Messages (CASL Compliance)

In accordance with Canada’s Anti-Spam Legislation (CASL), we will not send you commercial electronic messages (including promotional emails, SMS messages, or other electronic communications) without your consent.

We may send you commercial electronic messages based on: express consent that you have provided, such as by subscribing to our newsletter, checking a consent box at checkout, or otherwise explicitly opting in; or implied consent arising from an existing business relationship, such as a purchase you have made within the preceding two years.

Every commercial electronic message we send will: identify Form Insoles as the sender; include our contact information (mailing address, email address, or telephone number); and contain a clear and prominently displayed unsubscribe mechanism that allows you to opt out of future messages.

If you unsubscribe, we will process your request within ten (10) business days. Please note that even if you opt out of marketing communications, we may still send you transactional or service-related messages, such as order confirmations, shipping notifications, and responses to your inquiries.

8. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and to collect information about how you use our site.

8.1 Types of Cookies We Use

Essential Cookies. These are necessary for the website to function properly. They enable core features such as shopping cart functionality, account access, and secure checkout. These cookies do not require your consent.

Analytics Cookies. These cookies help us understand how visitors interact with our website by collecting information about pages visited, time spent on the site, and errors encountered. We use services such as Google Analytics for this purpose.

Marketing Cookies. These cookies are used to deliver advertising that is relevant to you and to measure the effectiveness of our advertising campaigns. These may be set by third-party advertising partners.

8.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling cookies may affect the functionality of our website and your ability to complete purchases.

9. Disclosure of Personal Information

We do not sell, trade, or rent your personal information to third parties. We may share your personal information with the following categories of recipients, and only to the extent necessary for the purposes identified in this policy:

Service Providers. We share information with trusted third-party service providers who assist us in operating our business, including Shopify Inc. (e-commerce platform), payment processors, shipping and logistics companies, email marketing platforms, and customer service tools. These providers are contractually required to protect your information and use it only for the purposes we specify.

Business Partners. We may share information with wholesale and retail partners to the extent necessary to fulfill orders placed through those channels.

Legal Requirements. We may disclose your personal information if required to do so by law, regulation, court order, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.

Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

10. Data Security

We implement reasonable security arrangements to protect your personal information against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. Our security measures include: encryption of payment transactions using SSL/TLS technology; secure storage of personal information with access restricted to authorized personnel; regular review of our information collection, storage, and processing practices; and physical, electronic, and procedural safeguards in compliance with applicable regulations.

While we take reasonable steps to protect your personal information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security of your information.

11. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specific retention periods include: order and transaction records, which are retained for a minimum of seven (7) years to comply with tax and accounting requirements under Canadian law; customer account information, which is retained for as long as your account is active, plus a reasonable period thereafter to address any follow-up inquiries; marketing consent records, which are retained for as long as your consent is valid, plus a reasonable period to demonstrate compliance with CASL; and website analytics data, which is generally retained in anonymized form.

When personal information is no longer required, we will securely destroy, erase, or anonymize it.

12. Your Rights Under PIPA and PIPEDA

Under Alberta’s Personal Information Protection Act and, where applicable, PIPEDA, you have the following rights regarding your personal information:

Right to Access. You have the right to request access to the personal information we hold about you. We will respond to your request within a reasonable time and no later than forty-five (45) days, as required by PIPA. There may be a minimal fee to process your request, which we will advise you of in advance.

Right to Correction. You have the right to request correction of any personal information we hold about you that is inaccurate or incomplete. If we agree that a correction is warranted, we will make the correction and, where reasonable, notify any third parties to whom we have disclosed the information.

Right to Withdraw Consent. You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions. We will inform you of the implications of withdrawing consent.

Right to Complain. If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Information and Privacy Commissioner of Alberta (see Section 14 for contact details).

To exercise any of these rights, please contact our Privacy Officer using the information provided in Section 14.

13. Data Breach Notification

In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm to you, we will: notify you of the breach as soon as feasible, providing details about the nature of the breach, the personal information involved, and the steps we are taking to reduce the risk of harm; report the breach to the Office of the Information and Privacy Commissioner of Alberta as required under PIPA; and notify any other organizations or government institutions if doing so may reduce the risk of harm.

“Significant harm” includes bodily harm, humiliation, damage to reputation or relationships, loss of employment or business opportunities, financial loss, identity theft, negative effects on a credit record, and damage to or loss of property.

14. Contact Information

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact:

Privacy Officer

Form Products Group Ltd., operating as Form Insoles

Email: sales@forminsoles.com

Phone: 855-274-8046

Website: forminsoles.com

We will investigate all complaints and respond within a reasonable time. If you are not satisfied with our response, you may contact:

Office of the Information and Privacy Commissioner of Alberta

Suite 2460, 801 – 6 Avenue SW

Calgary, Alberta T2P 3W2

Phone: 403-297-2728

Toll Free: 1-888-878-4044

Email: generalinfo@oipc.ab.ca

Website: www.oipc.ab.ca

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will post the updated policy on our website with a revised “Last Updated” date. We encourage you to review this Privacy Policy periodically.

Your continued use of our website or services following the posting of changes constitutes your acceptance of those changes.

16. Shopify

Our store is hosted on Shopify Inc. Shopify provides us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases, and the general Shopify application. Shopify stores your data on a secure server behind a firewall.

For more information, you may wish to review Shopify’s Terms of Service at shopify.com/legal/terms and their Privacy Policy at shopify.com/legal/privacy.