Privacy Policy

Last Updated: Feb 18, 2026

2043350 Ontario Ltd. (Legal Business Name), DBA: Alive Holistic Health Clinic ( “we,” “us,” or “our”) is deeply committed to protecting the privacy and confidentiality of the personal information and personal health information of our clients, website visitors, and all individuals who interact with our services. This Privacy Policy outlines our practices for the collection, use, disclosure, and protection of your information, in strict adherence to applicable Canadian and Ontario privacy legislation, including:

● The Personal Information Protection and Electronic Documents Act (PIPEDA): Canada’s federal private sector privacy law.

● The Personal Health Information Protection Act, 2004 (PHIPA): Ontario’s provincial health-specific privacy law, governing personal health information.

● The Regulated Health Professions Act, 1991 (RHPA): Ontario’s legislation governing the practice of regulated health professions.

● The standards of respective regulatory colleges: Including The College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario, The Canadian College of Naturopathic Medicine, The National Guild of Hypnotists, The College of Nurses of Ontario and, The Ontario College of Social Workers and Social Service Workers).

1. Accountability and Our Role as Health Information Custodians

2043350 Ontario Ltd. (Legal Business Name), DBA: Alive Holistic Health Clinic, takes full accountability for the personal information and personal health information (PHI) under our control. Our director serves as the designated Health Information Custodian (HIC) under PHIPA with respect to the personal health information we collect, use, and disclose in the course of providing healthcare services at our clinic. This means we are primarily responsible for safeguarding your PHI and ensuring compliance with PHIPA.

In instances where individual practitioners may operate as independent contractors, they are also recognized as Health Information Custodians regarding the PHI they collect and manage. In such cases, 2043350 Ontario Ltd. DBA: Alive Holistic Health Clinic may also act as their Agent under a contractual agreement, facilitating administrative and operational functions under strict adherence to PHIPA.

We have a designated Privacy Officer (details in Section 12) who is responsible for overseeing our compliance with this policy and applicable privacy legislation.

2. Collection of Personal Information and Personal Health Information (PHI)

We collect personal information and PHI that is necessary for the purposes identified in this policy. This information may be collected through various means:

● Directly from you: When you book an appointment (online or by phone), complete intake forms, consent forms, client history forms, communicate with us via email, phone, or in person, sign up for our newsletter, or participate in surveys.

● Through our website: Via cookies and other tracking technologies (see Section 6).

● From third-party service providers, Such as our online booking system (Jane App) or secure payment processors, who securely transmit necessary information to us to facilitate services.

The types of personal information and PHI we may collect include:

● Contact Information: Name, home address, telephone number, email address.

● Demographic Information: Date of birth, gender (optional), and emergency contact information.

● Personal Health Information (PHI – as defined by PHIPA): This is a critical category for our services. It includes your medical history, current health conditions, symptoms, allergies, medications, treatment notes (including SOAP notes), assessment findings, treatment plans, progress updates, referrals, and any other health-related details relevant to your care. This information is collected solely for the purpose of providing safe, effective, and tailored healthcare services.

● Billing & Payment Information: Credit card details (processed securely by third-party payment processors; we do not store full credit card numbers on our local systems), insurance policy details required for direct billing or issuing receipts for reimbursement.

● Communication Preferences: How you prefer to receive communications from us.

● Website Usage Data: IP address, browser type, operating system, pages visited, time spent on site, and referral sources (collected via cookies and analytics). This data is typically aggregated and anonymized.

2.1. Children’s Information Handling

For clients under 16 years of age, we require explicit parental or legal guardian consent to collect, use, and disclose their personal health information, in accordance with PHIPA s.23(1). Parents or legal guardians will be asked to complete and sign specific consent forms for minors.

3. Purposes for Collecting Personal Information and Personal Health Information (PHI)

We collect and use your personal information and PHI strictly for the following purposes, as permitted by PIPEDA, PHIPA, RHPA, and professional regulations:

● To Provide Healthcare Services (Primary Purpose): To assess your health, establish a comprehensive understanding of your needs, develop and deliver appropriate treatment plans (massage therapy, osteopathy, acupuncture, naturopathy), provide effective and safe care, and accurately track your progress and outcomes. This includes maintaining accurate and complete clinical records as required by our professional colleges.

● To Manage Appointments and Client Relationships: To schedule, confirm, and send reminders for appointments; to manage your client account; and to provide you with a smooth and efficient service experience.

● For Communication: To respond to your inquiries, provide information about our services, or send essential updates and instructions directly related to your healthcare (e.g., pre/post-treatment advice).

● For Billing, Payments, and Insurance: To process payments for services, manage direct billing to your insurance provider (with your consent), and issue official receipts required for your personal insurance reimbursement.

● For Internal Clinic Operations: For quality assurance, professional development, anonymized statistical analysis, record-keeping as required by law and professional colleges, and staff training under strict confidentiality protocols.

● For Marketing and Client Engagement (with Explicit Consent): To send newsletters, promotional offers, or information about new services, but only if you have provided explicit, informed consent for such communications. You have the right to withdraw this consent at any time.

● For Legal, Regulatory, and Professional Compliance: To meet our obligations as regulated health professionals under PHIPA, PIPEDA, the RHPA, the standards of our respective professional colleges (The College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario, The Canadian College of Naturopathic Medicine, The National Guild of Hypnotists, The College of Nurses of Ontario and, The Ontario College of Social Workers and Social Service Workers), tax laws, and other applicable federal and provincial legislation.

● To Improve Our Services: To understand client needs, analyze general website usage patterns (using aggregated, non-identifiable data), and continuously enhance our service offerings and website experience.

4. Consent to Collection, Use, and Disclosure

Your informed consent is fundamental to our handling of your personal information and especially your PHI.

● Express Consent: For the collection, use, and disclosure of your PHI for treatment purposes, and for any marketing communications, we will seek your clear, explicit, and informed consent, typically obtained in writing (e.g., through our detailed intake and consent forms) or verbally where appropriate. You will be informed of the purposes for which your information is being collected, used, and disclosed.

● Withdrawal of Consent: You have the right to withdraw your consent for the collection, use, or disclosure of your personal information or PHI at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide you with certain services. For health records, withdrawal of consent for treatment purposes may require further discussion with your practitioner regarding the implications for your ongoing care. Please contact us to discuss or withdraw consent.

5. Disclosure of Personal Information and Personal Health Information (PHI)

We will not disclose your personal information or PHI to third parties without your express consent, except as required or explicitly permitted by PIPEDA, PHIPA, and other applicable laws. Circumstances where disclosure may occur, often with your explicit consent, include:

Within Our Healthcare Team: Relevant PHI may be shared among our practitioners (RMTs, Osteopaths, Acupuncturists, Naturopaths) involved in your direct care to ensure integrated, coordinated, and holistic treatment, but only with your consent and when clinically relevant.

Third-Party Service Providers (including Cross-Border Data Flow): We engage reputable third-party service providers to facilitate our operations (e.g., secure online booking platforms like Jane App, secure payment processors, cloud-based record systems, IT support). These providers are contractually obligated to protect your information, adhere to strict privacy and security standards (including PHIPA compliance where applicable), and use it solely for the purposes for which we provide it to them. Please be aware that some of these third-party service providers, notably Jane App, may store or process personal information and PHI outside of Ontario or Canada (e.g., in the United States). In such cases, your information may be subject to the laws of that foreign jurisdiction, including access by law enforcement or national security authorities in that country. By receiving services from us, you are notified of and consent to this possibility.

Insurance Companies: For direct billing purposes or to provide necessary documentation for your personal reimbursement, always with your specific consent.

Referrals: When referring you to other healthcare professionals (e.g., physiotherapists, doctors), with your express consent.

Legal and Regulatory Requirements: When required by law (e.g., a court order, subpoena), or by our professional regulatory colleges for oversight or disciplinary purposes.

Emergency Situations: In situations where it is necessary to protect the life, health, or safety of an individual, and obtaining consent is not feasible.

De-identified or Aggregated Data: We may use and disclose de-identified or aggregated data for research, analysis, or public health purposes, provided that individual identities cannot be determined.

We do not sell, rent, or trade your personal information or PHI to third parties for any marketing or commercial purposes.

6. Cookies, Tracking and Website Usage Data

Our website utilizes cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand how you interact with our content.

Cookies: Small text files stored on your device that help our website remember your preferences and provide a more personalized experience. These are generally not linked to your PHI.

Analytics: We use tools like Google Analytics to collect non-identifiable information about website usage, such as pages visited, time spent on site, and referral sources. This data is collected in an aggregated and anonymized form and is used to improve our website’s functionality and content.

IP Addresses: We may collect IP addresses, which can be considered personal information. These are used for security, analytics, and to manage website traffic.

Cookie Consent: Our website aims to provide appropriate control over non-essential cookies. You can manage your cookie preferences through your browser settings. For certain non-essential cookies, we may also employ a cookie consent banner or pop-up to obtain your explicit consent before placing them on your device. Please note that disabling cookies may affect the functionality of some parts of our website.

7. Security of Personal Information and PHI

We implement robust administrative, technical, and physical safeguards to protect your personal information and PHI against unauthorized access, use, disclosure, alteration, or destruction, in compliance with PIPEDA, PHIPA, and industry best practices. These measures include:

Confidentiality Obligations: All staff, contractors, and agents are legally and contractually bound to maintain the confidentiality of your information.

Secure Electronic Records: Use of secure, password-protected, and encrypted electronic health record systems (e.g., Jane App).

Physical Security: Securing physical client records (if any) in locked filing cabinets within a secure clinical environment.

Access Controls: Restricting access to personal information and PHI to authorized personnel on a “need-to-know” basis.

Data Encryption: Implementing encryption technologies for data at rest and in transit where appropriate, especially for sensitive PHI.

Regular Security Audits and Training: Periodically reviewing our security practices and providing ongoing privacy and security training to our staff to ensure compliance and vigilance.

Privacy Impact Assessments (PIAs): We regularly conduct Privacy Impact Assessments for key systems and processes (such as our use of Jane App for EHR and booking) to proactively identify and mitigate privacy risks, aligning with best practices encouraged under PHIPA.

While we are dedicated to protecting your information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

7.1. Breach Reporting Protocol

In the event of a material breach of personal health information, we have a strict protocol in place. We will promptly notify the Information and Privacy Commissioner of Ontario (IPC) and all affected individuals, consistent with our obligations under PHIPA regulations (O. Reg. 329/04 s. 6.3.1 to 6.3.10). For other types of personal information, we will notify the Office of the Privacy Commissioner of Canada (OPC) and affected individuals as required by PIPEDA.

8. Retention of Personal Information and PHI

We retain your personal information and PHI for as long as necessary to fulfill the purposes for which it was collected, to provide ongoing services, and to comply with legal and professional obligations. Specifically for PHI, we adhere to the retention periods mandated by our respective professional colleges and PHIPA (e.g., typically 10 years from the last date of service for adults, or 10 years after the client would have turned 18 for minors). Once your personal information or PHI is no longer required, we securely dispose of it in a manner that prevents unauthorized access or reconstruction.

9. Your Rights Under PIPEDA and PHIPA

As an individual in Ontario, you have significant rights regarding your personal information and PHI:

Right to Access: You have the right to request access to your personal information and PHI held by us. We will provide you with access within the timeframes specified by PHIPA (typically 30 days) and may charge a reasonable fee for providing copies of records, as permitted by law.

Right to Correction: You have the right to request correction of any inaccurate or incomplete personal information or PHI we hold about you. We will make the correction or, if we do not agree to the correction, we will append a statement of disagreement to the record.

Right to Data Portability: You have the right to request a secure transfer of your personal health information to another healthcare provider, as a component of your right of access under PHIPA.

Right to be Informed: You have the right to be informed about our privacy practices, including the purposes for which your information is collected, used, and disclosed.

Right to Withdraw Consent: As outlined in Section 4, you can withdraw your consent at any time, subject to legal or contractual restrictions.

Right to Complain: If you believe your privacy rights under PHIPA or PIPEDA have been violated by our practices, you have the right to:

● Contact us directly to discuss and resolve the issue with our Privacy Officer.

● If your concern relates to Personal Health Information (PHI) under PHIPA, you may file a complaint with the Information and Privacy Commissioner of Ontario (IPC).

● If your concern relates to other personal information not covered by PHIPA (e.g., website data, marketing preferences), you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC).

To exercise any of these rights, please contact our Privacy Officer (details below).

10. Text Messaging – Collection, Use, and Disclosure of Personal Information

10.1 Data & Disclosure of Personal Information

2043350 Ontario Ltd., DBA: Alive Holistic Health Clinic(“we,” “us,” or “our”) DOES NOT share customer opt-in information, including phone numbers and consent records, with any affiliates or third parties for marketing, promotional, or any other purposes unrelated to providing our direct services. All text messaging originator opt-in data is kept strictly confidential. Direct service providers include Third-party SMS platform providers who facilitate message delivery and manage our messaging program.

Telecommunications companies that assist us in delivering text messages to your device

These subcontractors and service providers are contractually obligated to protect your information and use it only for the purposes we specify.

10.2 Information We Collect

When you provide express consent to receive text messages from us, we collect and use the following personal information in accordance with PIPEDA, CASL and applicable provincial privacy legislation:

Personal Information

  • Name, email address, mobile phone number, work phone number, and physical home address.

  • The date, time, and method of your consent (SMS, Email etc.)

  • Your consent opt-in preferences and the purpose(s) for which consent was provided

  • Message delivery status and engagement data (e.g., delivery confirmations, read receipts if available)

  • Any personal information you provide in response to our messages

  • Device and technical information related to message delivery

Non-Personal Information:

  • IP address, browser type, device information

  • Website usage patterns and analytics

  • Cookies and similar technologies

Customer Communication:

  • Records of inquiries and service requests

  • Appointment details and preferences

  • Service history and feedback

10.3 How We Use Your Information

We collect and use your personal information for the following purposes, for which we have obtained your express consent:

We use collected data for:

  • Providing and improving our services

  • Processing transactions and payments

  • Communicating with you about your inquiries, appointments, and promotions, new offers

  • Enhancing website functionality and user experience

  • To maintain records of consent as required by CASL

  • To analyze program effectiveness and improve our services

  • To comply with legal and regulatory obligations

  • To prevent fraud, ensure security and protect our legitimate business interests where permitted by law.

10.4 SMS Messaging & Compliance

Text Message Program Terms & Conditions

By opting into our SMS messaging services, you agree to receive text messages related to our services, including appointment reminders, customer support, and important updates.

Opt-In & Consent:

By providing your mobile phone number and explicitly opting in to receive text messages from 2043350 Ontario Ltd, DBA: Alive Holistic Health Clinic, you provided explicit consent to non-marketing and/or marketing messages via SMS (text messaging) to the mobile number you have provided. We maintain timestamped records of all opt-in actions, and comply with CASL and all other applicable laws.

Opt-Out Instructions:

You can cancel the SMS service at any time. Simply text “STOP” to the same number that sent you messages. Upon sending “STOP,” we will confirm your unsubscribe status via SMS. All opt-out requests will be process immediately. Following this confirmation, you will no longer receive SMS messages from us. To rejoin, sign up as you did initially, and we will resume sending SMS messages to you.

All unsubscribe mechanisms will remain functional for at least 60 days after a message is sent, as required by CASL.

Please note that if you withdraw your consent, we may not be able to provide certain services that require text messaging.

Retention of Personal Information

We retain your mobile phone number and consent records for the following periods:

  • Active Subscribers: While you remain subscribed to our text messaging program

  • Unsubscribed Users: We retain your phone number on our suppression list indefinitely to honor your unsubscribe request and comply with CASL record-keeping requirements

  • Consent Records: We retain records of consent for a minimum of three (3) years from the date consent was obtained, as required by CASL

After the required retention period, we securely delete or anonymize your personal information in accordance with our data retention policies and legal requirements.

Help and Support Information

If you experience issues with the messaging program, reply with the keyword “HELP” for more assistance, or reach out directly to our clinic at (416) 591-1535 or clinic@aliveholistichealth.ca during business hours.

Message Frequency & Data Rates

Message and data rates may apply for messages sent to you from us and to us from you. Message frequency varies based on your service usage and appointment schedule. For questions about your text plan or data plan, contact your wireless provider.

Carrier Information:

Standard message and data rates may apply.Carriers are not liable for delayed or undelivered messages. Our SMS program works with all major Canadian wireless carriers, including Rogers Wireless, Bell Mobility, Telus Mobility, and Freedom Mobile, and regional carriers.

SMS Data Protection Statement

No mobile information or consent records will be shared with third parties/affiliates for marketing/promotional purposes or any other purposes unrelated to providing our direct services. Information sharing with carriers and subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Subcontractors include Third-party SMS platform providers who facilitate message delivery and manage our messaging program.

Compliance

Our text messaging program complies with:

  • Canada’s Anti-Spam Legislation (CASL)

  • Personal Information Protection and Electronic Documents Act (PIPEDA) [or applicable provincial privacy legislation]

  • Canadian Radio-television and Telecommunications Commission (CRTC) regulations

  • Other applicable federal and provincial laws

Contact Information for Text Messaging Program

For questions about our text messaging program or to withdraw consent, please refer to the Privacy Officer contact information provided in the “Contact Information” section of this Privacy Policy below

Children’s Privacy

Our text messaging service is not directed to individuals under the age of majority in their province or territory of residence. We do not knowingly collect personal information from minors without parental or guardian consent. If you believe we have collected information from a minor, please contact us immediately.

Changes to Text Messaging Privacy Practices

We may update our text messaging practices and this section of our Privacy Policy from time to time. We will notify you of material changes by sending a text message, posting a notice on our website, or by other means as required by law. Where required, we will obtain your renewed consent.

12. Third-Party Website Links and Services

Our website may contain links to third-party websites and services (e.g., Jane App for booking, and social media platforms). This Privacy Policy applies solely to 2043350 Ontario Ltd. DBA: Alive Holistic Health Clinic practices. We encourage you to review the privacy policies and terms of service of any third-party sites or services you interact with, as we are not responsible for their privacy practices.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements (including amendments to PIPEDA or PHIPA), or service offerings. The “Last Updated” date at the top of this page will indicate when the policy was last revised. We encourage you to review this policy periodically to stay informed about how we are protecting your information.

14. Your Rights & Choices

You have the right to:

• Access, update, or delete your personal information
• Opt out of marketing emails by clicking “unsubscribe” in our emails
• Opt out of SMS messages by replying “STOP”
• Request information on how we process your data
• Withdraw consent at any time for future communications
• Lodge a complaint with a supervisory authority if you believe your rights have been violated

To exercise these rights, please contact us using the information in Section 14 below.

15. Contact Information / Privacy Officer

For any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, or to exercise your rights, please contact us at: 2043350 Ontario Ltd. (Legal Business Name), DBA: Alive Holistic Health Clinic:

Your designated Privacy Officer:

Privacy Officer: Mary Wong, R.TCMP, R.Ac, FABORM, CHPC

Email:clinic@aliveholistichealth.ca

Phone Number(416) 591-1535

Address: 708-2 Carlton Street,Toronto, ON M5B 1J3, Canada