Privacy Policy 
The Crystal Factor ("TCF"), formerly known as Headway Coaching International ("HCI"), an Alberta company, is committed to protecting the privacy of users to this Website and for users of our on-line services in accordance with the requirements of Canadian federal and provincial privacy laws.

This privacy statement details how TCF collects and uses of personal information of users of this Website or our on-line services and outlines our privacy commitment to you, the user, as well as our privacy practices. TCF wants all users of its Website and on-line services to understand the purposes and uses for our collection of user personal information and we want to ensure that TCF has your consent to continue to collect, use and disclose your personal information for those purposes and uses as set out below.

At the same time, TCF wants its privacy statement to meet the highest commercial standards that establish trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the site (the “Web site”) including all sub-domains.

We want this Web site and our on-line services to demonstrate our commitment to its users’ privacy, and therefore we want to you to know what our information and privacy practices are with respect to the following matters: 

1. What personally identifiable information TCF collects.
2. What personally identifiable information third parties collect through the Web site.
3. What organization collects the personal information. 
4. How TCF uses the personal information.
5. With whom TCF may share user information. 
6. What choices are available to users regarding collection, use and distribution of the personal information. 
7. What types of security procedures are in place to protect the loss, misuse or alteration of personal information under TCF control. 
8. How users can correct any inaccuracies in the personal information. 

If users have questions or concerns regarding this statement, they should first contact Crystal Willms by the following email If a user does not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact TCF directly by the following contact number: 1.403.230.1464

Information Collection and Use

Information Collection

TCF is the sole owner of the information collected on including all sub-domains. TCF collects personally identifiable information from our users at several different points on our Web site. If you use our on-line services, we ask you for your name, firm or company affiliation, email address, mailing address, telephone number and fax number. This information allows us to ensure that you are able to access and use our on-line services and for us to contact you regarding these service offerings. 


For billing purpose, we request the following information, (m) refers to mandatory; (o) refers to optional information. The decision by users not to complete the optional information may affect their full usability of the TCF Website,

verification information
business name (m)
business phone number (m)
business contact person (m)
business e-mail address(m)
billing address (m)
public information
store/service outlet location (o)
hours of service (o)
photo/logo (o)
store description (o)
personal information
name (m)
date of birth (o)
course taken (o)
gender (o)
photo (o)
personal website (o)

We do not collect or request social insurance or social security numbers and do not retain credit card information on its database. Contact information, such as business address and email address from the user and financial information, such as credit card number and expiration date are used for is used for billing purposes and if we have trouble with billing, the information is used to contact the user.

We may disclose personal information if legally required to do so such as to protect our rights and property, take emergency action regarding personal safety or where required by operation of law.

Information Use

We collect and use the information to process and fill your orders, to facilitate the services requested by the user, to improve the services and features of the Web site, to customize our services or delivery of information to you on the Web site to make the users’ use of the Web site more effective and efficient, to resolve disputes, to troubleshoot problems and enforce this privacy statement. We automatically track certain information based on the user’s use of our Web site. We use this information to do internal research on our user’s demographics, interests, and behavior to better understand the users and our client base. We track information regarding the URL that the user came from (whether from our site or not), which URL the user may go to next (whether this URL is on our site or not), what browser is being used and the user’s IP address. 

We use information to improve our marketing and promotional efforts, to improve our content and product offerings, and to customize our site’s content, layout and services to better meet the needs of users. We collect information to generate statistics and aggregate reports for internal use only. These statistics and aggregate reports will not contain any personally identifiable information. Personal identity is kept anonymous.

We collect and use information from messages, users who chose to post information on our site. We also collect and use personal correspondence, such as emails or letters, or if other users or third parties send correspondence about your activities or postings on the Web site. 

We collect and use information if users register for or another web site or use a web site providing a service for that helps facilitate a user’s activity on and that web site may provide personal information about you and your transactions back to HCI does not sell or rent any information collected from users to other third parties.

Third Party Advertising

We do not do any external advertisement. We do not aggregate (gather up data across all user accounts) information and provide information in a non-personally identifiable manner to advertisers and other third party for promotional purposes. 

This privacy statement covers the use of cookies by only and does not cover the use of cookies by any advertisers. 

Clear Gifs (Web Beacons/Web Bugs)

We do not employ the use of Clear Gifs.

Communications from the Site

Service Announcements

On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature. 

Customer Service

We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the users wishes.


Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Web site.

Aggregate Information (non-personally identifiable)

We do not share aggregated demographic information with our partners and advertisers.

Third Party Advertisers

We do not share Web site usage information about users with third party advertisers. 

Sharing of Personal Information with Third Parties

We DO NOT share personal information with third parties.

Third Party Intermediaries

We use an outside credit card processing company – PayPal – to bill users for goods and services. PayPal processes payments for use, does not retain, store, share or use personally identifiable information including credit card information for any secondary purpose.

Service Providers

We partner with other third parties such as PayPal to provide specific services. The user may need to sign up to these particular services. These third parties are not allowed to use personally identifiable information except for the purpose of providing these services. 

Business Transitions

In the event TCF goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

We may disclose personal information of a user to an agent when in the reasonable judgment of TCF, the individual is seeking information as an agent of the user.

Subject to applicable regulatory requirements, we may disclose personal information of a user to a credit reporting agency.

We may disclose personal information of a user to a public agency when in the reasonable judgment of TCF, there is imminent danger to person or property to which such disclosure would avoid or minimize the danger.


We do not use our users’ information for other purposes other than related to our site. 
We would like to continue to have you, the user’s consent for the purposes and uses of personal information as set out in this privacy statement, however, you may choose to refuse or withdraw your consent by refusing to give us personal information or withdrawing such consent subject to any applicable contractual or notice provisions by emailing us.. 

Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by following instructions given in the footer of the email or email us at Or If user wishes to unsubscribe to our communications, the user can do so by sending an email to use at


This Web site contains links to other sites. Please be aware that we, TCF, are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site. 

Recommend Us

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. We will automatically send the friend a one-time email inviting them to visit the site. We store this information for the sole purpose of sending this one-time email and to track the success of our referral program. The friend may contact us at to request the removal of this information from our database. 

Supplementation of Information 

In order for this Web site to properly fulfill its obligation to users it is necessary for us to supplement the information we receive with information from 3rd party sources. 

Credit Card

We do not conduct credit card validation as all credit card processing for our products and services is undertaken by PayPal.

ID Verification

In order to ensure the integrity of our business clients, we conduct a reverse phone number lookup to verify a business user’s identity. 

Purchasing History

We do not combine information about the purchasing habits of our users with other third parties. 

Notification of Changes

If we decide to change our privacy statement and or practices, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We will use information in accordance with the privacy policy under which the information was collected. The posting of changes to the privacy statement shall be effective within 30 days. 

If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Web site notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices. 

Contact Information

If users have any questions, concerns or suggestions regarding our privacy practices, please contact us at:

Phone 1.403.230.1464

Otherwise, we assume that we have you, the user of our Website and or on-line services, consent to collect, use and disclose your personal information for the purposes and uses identified in this privacy statement.