1Health Information Custodian & Contact Person
Our clinic is the Health Information Custodian under PHIPA s. 3(1). As required by
PHIPA s. 15(3), we have designated a Contact Person who is responsible for facilitating
compliance with the Act, responding to access and correction requests, and receiving
privacy inquiries and complaints. You may reach our Contact Person at:
2Information We Collect
- Personal information: name, email, phone, address, date of birth, and billing details.
- Personal health information (PHI): medical history, allergies, medications, photographs taken as part of clinical assessment, treatment records, consent forms, and post-treatment notes.
- Technical information: IP address, browser type, device identifiers, pages visited, referring URLs, and cookie identifiers. Session recordings are collected only if you consent.
3Purposes of Collection
We collect, use, and disclose information, as permitted under PHIPA s. 29, for the following purposes:
- To provide direct health care.
- To bill for services through Stripe and JaneApp.
- To send appointment confirmations, reminders, and post-treatment care.
- To send commercial electronic messages, only where you have provided express CASL consent.
- To improve our services and website, with your consent.
- To comply with legal, regulatory, and professional obligations.
4Consent
We collect PHI only with your express written consent, except in circumstances permitted
by PHIPA (for example, emergency care or court orders). You may withdraw consent at any
time, subject to legal and contractual restrictions, by contacting our Contact Person.
5Disclosure
We do not sell your personal information. We disclose PHI only:
- to agents who perform services on our behalf (JaneApp Mobility Inc., Stripe Payments Canada Ltd., our Medical Director, [Medical Director name — to confirm], our accounting firm, and IT support);
- to other custodians for the purpose of providing health care, with your consent;
- as required or authorized by law.
All agents are contractually required to comply with PHIPA.
6Safeguards
We use industry-standard administrative, physical, and technical safeguards: TLS 1.2+
encryption in transit, AES-256 encryption at rest, role-based access, multi-factor
authentication on systems holding PHI, locked physical files, staff confidentiality
training, and incident response procedures.
7Cross-Border Data Transfer
JaneApp data is hosted on AWS Canada (ca-central-1). Stripe processing may involve transfer
to the United States; Stripe is bound by Standard Contractual Clauses. Cloudflare may route
traffic through global edge nodes; no PHI is stored at the edge.
8Retention
Clinical records are retained for ten years from the date of last entry, in accordance with
professional guidance. Marketing data is retained while consent is valid and is deleted
within 30 days of consent withdrawal. Photographs used for marketing are removed from active
distribution within 30 days of withdrawal.
9Your Rights
Under PHIPA and PIPEDA you have the right to:
- access your records;
- request correction;
- withdraw consent for non-mandatory uses;
- file a complaint with our Contact Person, or with the Information and Privacy Commissioner of Ontario (1-800-387-0073, info@ipc.on.ca) or the Office of the Privacy Commissioner of Canada (1-800-282-1376).
We respond to access and correction requests within 30 days (extendable to 60 days in
defined circumstances under PHIPA), generally at no charge. Visitors in the EU and UK
additionally have rights to portability, erasure, and restriction of processing under
GDPR Articles 15–22.
10Cookies & Tracking
We use essential cookies (required for the site to function) and, with your consent,
analytics cookies (Google Analytics 4) and advertising cookies (Meta Pixel, TikTok Pixel).
When you first visit, a cookie consent banner lets you accept all or reject all non-essential
cookies. You can change your choice at any time using the “Cookie settings” link in our
footer. For more detail, see our Cookie Policy.
11Children
Our services are intended for adults aged 18 and over. We do not knowingly collect
information from minors.
12Changes
We will post material changes to this policy on this page and notify existing clients by
email at least 30 days before the changes take effect.
Bracketed items marked [to confirm] are placeholders to be
finalized before publication. For privacy inquiries, contact our Contact Person at
privacy@activatebeauty.ca.