Privacy Policy

Effective date: August 17, 2026

This Privacy Policy explains how Wray Consulting Group Inc., a corporation incorporated in British Columbia, Canada, operating as MINDSHIFT, with its registered office at 5363 Westhaven Wynd, West Vancouver, BC, Canada V7W 3E8 (“MINDSHIFT,” “we,” “us,” or “our”), collects, uses, and shares personal information when you visit https://www.mindshiftjourney.com (the “Site”), register for our events, apply for or participate in our programs, or otherwise interact with us.

By using the Site, registering for our events, or applying for or participating in our programs, you agree to the practices described in this policy.

Our Privacy Officer

We have designated a Privacy Officer who is accountable for our compliance with applicable privacy laws, including Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and, for Quebec residents, Quebec’s Act respecting the protection of personal information in the private sector (as amended by Law 25):

Privacy Officer: Adam Wray — adam@wraygroup.com — Wray Consulting Group Inc., 5363 Westhaven Wynd, West Vancouver, BC, Canada V7W 3E8.

Please direct any privacy question, request, or complaint to the Privacy Officer, who will respond within the timeframe required by applicable law (and in any event within 30 days).

Information We Collect

Information you provide through the Site and our events. When you fill out a form on our Site, register for a webinar or event (including through registration forms hosted on third-party platforms such as LinkedIn), subscribe to our emails, or contact us, we collect the information you submit. This may include your name, email address, job title, company or organization, country, and any other details you choose to provide.

Program applications and interviews. When you apply for one of our programs, we collect the information in your application: your name and email address; the program option you are applying for; your written responses to the application’s reflection questions; and, if you choose to provide them, your phone number, how you heard about MINDSHIFT, what influenced you to apply, who referred you, and whether you are applying together with others (which we use to apply referral or group discounts). If you proceed to an application interview, the interview is recorded for internal use only — the interviewer uses the recording in place of notes to inform follow-up with you. Interview recordings are not published or used in marketing.

Program participation. If you enroll in a program, we collect the information generated through your participation, including: your enrollment and billing details (name, billing address, country, payment records); your exercise submissions, reflections, and other program work; your attendance; and communications between you and us. Program work is stored on our online course platform (Thinkific) and on the devices of the MINDSHIFT team members and cohort Mentors who review it, as described under “How We Share Your Information.”

Session recordings. Live program sessions (including workshops, labs, huddles, and onboarding and coaching sessions held via Zoom) are recorded, and your image, voice, name, and contributions may appear in those recordings. The uses of these recordings — program delivery (including access by cohort members who miss a session), internal purposes, and marketing subject to your right to opt out of identifying marketing uses — are described in the Program Terms & Conditions you accept when enrolling. Recordings are stored in our Zoom cloud account, may be transcribed through our transcription provider (Rev.com), and may be held on the devices of MINDSHIFT team members.

Testimonials and marketing content. Where you give a testimonial, appear in a case study, or agree to be featured on our website, we collect and use the content, name, likeness, and details you provide, on the basis of your consent or a signed release. If you appear in our marketing materials and would like your testimonial or appearance updated or removed — or if you are the representative or family member of a featured person who is deceased or cannot be reached — contact our Privacy Officer and we will address the request promptly.

Information collected automatically. When you visit the Site, we and our service providers may automatically collect technical information such as your IP address, browser type, device information, pages viewed, and the dates and times of your visits. We collect this through cookies and similar technologies. The Site uses Squarespace’s built-in analytics only; we do not run third-party analytics or advertising trackers. See “Cookies” below.

How We Use Your Information

We use the information we collect to:

  • deliver the events, programs, and services you request, including sending event details, access links, and reminders, processing applications and enrollment, delivering program sessions and materials, reviewing program work, and issuing certificates and continuing education credits;

  • make session recordings available for program delivery (including to cohort members, Mentors, and program staff, for example so a participant who misses a session can watch it afterward), use them internally, and — subject to the opt-out described in the Program Terms & Conditions — in our marketing;

  • respond to your inquiries and provide support;

  • process payments and maintain billing records;

  • send you marketing communications about our programs, services, and related coaching resources and opportunities. Where the law requires your consent for such communications, we rely on that consent; where it does not, we rely on your relationship with us and our legitimate interest in telling registrants and contacts about relevant offerings. You can unsubscribe at any time using the link in any marketing email, and we honor opt-outs promptly;

  • use testimonials and case-study content, with your consent or under a signed release;

  • operate, maintain, analyze, and improve the Site, our programs, and our services; and

  • comply with legal obligations and protect our rights.

Event registrations specifically. When you register for one of our events — including through a registration form hosted on a third-party platform such as LinkedIn — we receive the information you submit and use it to deliver the event and send related communications and reminders. We may also send you marketing communications about MINDSHIFT programs and services on the lawful bases described above, with a clear way to opt out in every marketing email.

Legal Bases for Processing (Where GDPR Applies)

Where the EU/UK General Data Protection Regulation applies, we process personal data on the basis of: the performance of a contract or steps taken at your request (for example, processing your application, delivering a program you enrolled in, or an event you registered for); your consent (for example, where consent is required for marketing emails, non-essential cookies, or identifying marketing uses of your image or recordings — which you may withdraw at any time); our legitimate interests (for example, operating and improving our services, recording sessions for program delivery and internal purposes, and informing people who have engaged with us about relevant offerings), balanced against your rights and freedoms; and compliance with legal obligations. You may object to processing based on legitimate interests at any time.

How We Share Your Information

We do not sell your personal information. We share it only as described here:

Service providers that process personal information on our behalf to help us operate, under their own privacy and security terms:

  • Squarespace — website hosting and forms;

  • Mailchimp / Intuit — email marketing and automation;

  • Zapier — data transfer between our systems;

  • LinkedIn — event hosting and registration;

  • Zoom — delivery and cloud recording of webinars, program sessions, and interviews;

  • Thinkific — our online course platform, including storage of program materials and your exercise submissions;

  • Stripe and PayPal — payment processing (we do not store your full card details ourselves);

  • Calendly — scheduling of sessions and interviews;

  • Adobe (Acrobat Sign) — electronic signature of agreements; and

  • Rev.com — transcription of recordings.

Cohort Mentors. If you participate in the MINDSHIFT Program for Coaches, your program work, reflections, and information you share in sessions may be shared with the Mentors supporting your cohort — graduates of the program participating in our Mentorship Program — who are bound by confidentiality obligations and may use that information only for program purposes.

Within our team. Access to personal information within Wray Consulting Group Inc. is limited to team members who need it for the purposes above; billing information is handled by our in-house accounting.

Legal and safety reasons, where required by law or to protect our rights, users, or the public; and business transfers, in connection with a merger, acquisition, or sale of assets.

International Data Transfers

We are based in Canada, and our service providers may process your information in the United States and other countries. Where required, we rely on appropriate safeguards for such transfers (such as standard contractual clauses offered by our providers). By using the Site or participating in our events and programs, you understand your information may be processed outside your country of residence.

Data Retention

We retain personal information for as long as needed to fulfill the purposes described in this policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. In particular:

  • Applications from people who do not enroll are deleted within 12 months after the application deadline for the cohort applied to, unless you ask us to keep your application on file for a future cohort or ask us to delete it sooner;

  • Program records and session recordings are retained while they remain relevant to program delivery, alumni support, and our legitimate business records, and are reviewed at least annually by our Privacy Officer, who deletes recordings and records no longer needed;

  • Billing records are retained as required by tax and accounting law; and

  • Marketing suppression records (such as unsubscribe requests) are retained so we can honor them.

You may request deletion at any time (see “Your Rights”).

Your Rights

Depending on where you live, you may have the right to access, correct, update, or delete your personal information; to withdraw consent; to object to or restrict certain processing; and to request a copy of your data. Residents of the EU/UK (GDPR) and Canada (PIPEDA and provincial laws, including Quebec’s Law 25), among others, have these or similar rights.

To exercise any of these rights, contact our Privacy Officer at adam@wraygroup.com. You can unsubscribe from marketing emails at any time using the link in any such email. We will respond within the timeframe required by applicable law.

Complaints. If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory or regulatory authority, including: for the EU/UK, the data protection supervisory authority in your country of residence, place of work, or the place of the alleged infringement; for Canada, the Office of the Privacy Commissioner of Canada; and for Quebec residents, the Commission d’accès à l’information du Québec. We would, however, welcome the chance to address your concern directly first.

Cookies

The Site uses cookies and similar technologies set by our website platform, Squarespace: strictly necessary cookies that make the Site function (such as security and load-balancing cookies), functional cookies that remember your preferences, and Squarespace's built-in analytics, which give us aggregate information about how the Site is used. We do not run third-party advertising, social-media, or cross-site tracking cookies on the Site.

Embedded video. Some pages include videos hosted by Vimeo and embedded in our pages. When a page containing a Vimeo video loads, Vimeo may set its own cookies on your device and receive technical information such as your IP address, in accordance with Vimeo's own privacy policy, over which we have no control. These cookies are set by Vimeo rather than by us, and our cookie banner does not control them; you can manage or block them through your browser settings, and Vimeo's privacy policy is available at vimeo.com/privacy.

Your consent. When you first visit the Site, a cookie banner lets you accept or decline non-essential cookies. Strictly necessary cookies are always active; Squarespace's analytics cookies are set only after you accept. You can change your choice at any time using the cookie preferences control on our site, or by clearing your cookies, and you can also control cookies through your browser settings; disabling them may affect how the Site works.

Children’s Privacy

The Site and our services are intended for professionals and are not directed to children. We do not knowingly collect personal information from children. If you believe a child has provided us information, please contact us and we will delete it.

Security

We take reasonable technical and organizational measures to protect personal information, and we require the same of our service providers. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Effective date” above and, where appropriate, provide additional notice. Your continued use of the Site after changes take effect constitutes acceptance of the updated policy.

Contact Us

If you have questions about this policy or how we handle your information, contact our Privacy Officer:

Adam Wray, Privacy Officer — adam@wraygroup.com

Wray Consulting Group Inc. (MINDSHIFT), 5363 Westhaven Wynd, West Vancouver, BC, Canada V7W 3E8

Governing Law

This Privacy Policy is governed by the laws of the Province of British Columbia and the applicable laws of Canada, without regard to conflict-of-laws principles.

Wray Consulting Group Inc. (MINDSHIFT) · 5363 Westhaven Wynd, West Vancouver, BC, Canada V7W 3E8