1. Introduction
Welcome to True North Health, a trade name of 10211070 Manitoba Corp. (“we,” “us,” or “our”). We understand that your privacy, especially in the context of health services, is of utmost importance. This Privacy Policy explains how we collect, use, disclose, and protect your personal information (including personal health information) when you interact with our services—whether by visiting our website at https://truenorthhealth.co/ (the “Site”), calling us at (204) 500-0076, or engaging with us in person, by email, or through other means.
By using our Site or otherwise providing us with your personal information, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use our services or provide any personal information to us.
2. Who We Are
- Legal Business Name: 10211070 Manitoba Corp.
- Operating Name: True North Health
- Business Number (BN): 746174622
- Registered Address: 208–1460 Chevrier Blvd, Winnipeg, Manitoba R3T 1Y6, Canada
- Telephone Number: (204) 500-0076
- Website: https://truenorthhealth.co/
As a provider of health-related services, we may act as a “trustee” of personal health information under the Personal Health Information Act (PHIA) in Manitoba. We also adhere to the Personal Information Protection and Electronic Documents Act (PIPEDA) at the federal level, and any other relevant federal/provincial privacy legislation.
3. Scope of This Privacy Policy
This Privacy Policy applies to the personal information (including personal health information) we collect, use, or disclose in the course of providing health-related and other services. It covers information collected via:
- Our Site and related platforms;
- Email, text, or other electronic messages between you and us;
- Phone calls or in-person interactions; and
- Other offline or online interactions with True North Health.
4. Definitions
Personal Information
Information that can identify you or could be combined with other information to identify you. Examples include your name, address, phone number, or email address.Personal Health Information (PHI)
Under Manitoba’s PHIA, personal health information generally refers to recorded information about an identifiable individual that relates to the individual’s health, health care history, the provision of health care, or payment for health care. This may include medical records, treatment notes, diagnostic test results, or other health-related information.
5. Information We Collect
Personal Information You Provide
- Contact Details: Name, address, email, and phone number.
- Health Information: Information you provide during consultations or when booking health-related services, such as medical history, treatment plans, or any other data needed to provide you with the requested health services.
- Payment Information: For any fees or purchases you make, we may collect billing and payment details (noting that credit card information is typically processed and stored by our payment processors, not on our servers).
- Communication Records: If you contact us by email, phone, text, or through the Site’s contact forms, we may keep a record of that correspondence.
Information Collected Automatically
- Log Data: IP address, browser type, operating system, referring URLs, pages viewed, date/time of visits.
- Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking tools to enhance your experience on our Site. You can adjust your browser settings to refuse cookies; however, some features of the Site may not function properly without them.
Information from Third Parties
- We may receive information from third-party service providers or partners—such as referral sources, payment processors, or data analytics services—helping us operate or improve our services.
6. Legal Basis for Collection, Use, and Disclosure
We collect, use, and disclose personal information (including PHI) as permitted or required by applicable laws, including:
- Your Consent: We rely on your express or implied consent to collect or process your personal information for most health- or service-related purposes.
- Provision of Health Services: We collect, use, and disclose personal health information to provide medical or health-related services, to consult with other health professionals (with your consent or as permitted by law), and to manage the operations of our practice.
- Legal or Regulatory Obligations: We may also collect, use, or disclose information without consent where authorized or required by law (e.g., reporting certain diseases or abuse, responding to a court order).
7. How We Use Your Information
Your personal information (including PHI) may be used for purposes such as:
- Providing Health and Wellness Services
- Scheduling appointments, diagnosing and treating medical or health conditions, maintaining health records, and coordinating care with other health professionals.
- Administration and Communication
- Sending administrative messages such as appointment reminders (including text messages with your consent) or notifications about changes to our services.
- Billing and Payment
- Processing service fees or product payments, submitting insurance claims (where applicable), and maintaining financial records.
- Improving Our Services
- Analyzing usage trends, tracking website performance, and refining our clinical or service delivery.
- Marketing (With Consent)
- Sending newsletters, special offers, or updates if you have opted in to receive them. You may unsubscribe any time.
- Regulatory and Legal Compliance
- Meeting professional, legal, or regulatory requirements, including responding to lawful requests from regulatory bodies or government entities.
8. Disclosure of Your Information
We do not sell or rent personal information (including phone numbers) to third parties for marketing purposes. We only disclose personal information as authorized or required by law, or with your consent. Typical disclosures may include:
- Service Providers and Partners
- We may share information with third-party vendors who help us in delivering services, such as cloud hosting, electronic health record systems, payment processors, or marketing support. These vendors are contractually bound to protect your information and may only use it for the purposes we specify.
- Other Health Professionals
- With your consent or as permitted by law, we may share relevant PHI with other practitioners (e.g., specialists, labs, pharmacies) to ensure continuity of care.
- Legal and Regulatory Obligations
- We may disclose information in response to a court order, subpoena, or other lawful request. We may also share information when necessary to protect our rights, your safety, or the safety of others.
- Business Transactions
- If we are involved in a merger, acquisition, or sale of assets, personal information (including PHI) may be transferred, subject to appropriate confidentiality protections.
9. Consent and Your Choices
Consent to Collection and Use
- By providing personal information or PHI to us, you consent to our collection, use, and disclosure of that information in accordance with this Privacy Policy and applicable law.
Withdrawing Consent
- You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, withdrawing consent for certain uses may limit our ability to provide certain services to you (e.g., health services that rely on access to PHI).
Text Message (SMS) Consent
- If you opt in, we may send you text messages about your appointments or promotional content. You can opt out at any time by replying “STOP” or following instructions in the message. Standard messaging rates may apply.
Email Marketing
- You can unsubscribe from marketing emails at any time by clicking the “unsubscribe” link in the message or by contacting us directly.
10. Security and Retention
Security Measures
- We take reasonable administrative, technical, and physical safeguards to protect personal information (including PHI) against loss, theft, or unauthorized access, use, or disclosure. This includes secure servers, encryption where appropriate, and limiting internal access to those who need it.
Retention Period
- We retain personal information and PHI only for as long as necessary to fulfill the identified purposes or as required by law. Medical records, for instance, may be retained for a specific period in compliance with professional and legal requirements.
11. Access and Correction
You have the right to request access to your personal information (including PHI) and to request corrections if you believe it is inaccurate or incomplete. To exercise these rights, please contact us (see Section 15). In certain circumstances, we may not be able to fulfill your request (e.g., if it would disclose someone else’s personal information or if prohibited by law), but we will always provide you with an explanation.
12. Children’s Privacy
Our services are generally aimed at adults, but we may collect PHI for minors under the care of a parent or legal guardian. In such cases, we will obtain consent from the appropriate parent or guardian as required by law.
13. Website Cookies and Tracking
We use cookies and other tracking technologies to understand how you use our Site, improve site performance, and customize your experience. You can manage cookie settings in your browser; however, disabling cookies may limit certain functionalities of the Site.
14. International Transfers
If you are visiting our Site from outside Canada, please be aware that your information may be stored or processed in Canada or other jurisdictions where our service providers are located. By using our Site or services, you consent to any such transfer.
15. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:
Privacy Officer (True North Health)
10211070 Manitoba Corp.
208–1460 Chevrier Blvd
Winnipeg, Manitoba R3T 1Y6
Phone: (204) 500-0076
Email: info@truenorthhealth.co
16. Changes to This Privacy Policy
We may periodically update this Privacy Policy to reflect changes in our information practices or legal obligations. When we do, we will revise the “Last Updated” date at the top. Your continued use of our services following any updates indicates your acceptance of the revised Policy.
