Privacy
Policy.

01

Purpose and scope

This Privacy Policy applies to personal information handled by Preluma Health Inc. (“Preluma,” “we,” “our,” or “us”) through this website, consultations, program enrollment, communications, and service delivery.

“Personal information” means information about an identifiable individual. Personal health information may receive additional protection under Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”) and the professional obligations of the practitioner responsible for the record.

02

Information we may collect

Please do not send urgent medical information through the website or ordinary email. Contact emergency services or your responsible healthcare team when immediate assistance is required.

03

How we use information

• Respond to inquiries and schedule consultations or services.
• Assess program suitability, identify precautions, and personalize service delivery.
• Coordinate members of the Preluma team and, with appropriate authority, communicate with other people involved in your care.
• Maintain service, clinical, consent, billing, and business records.
• Process payments, cancellations, and refunds.
• Operate, secure, troubleshoot, and improve the website and our services.
• Meet legal, regulatory, insurance, accounting, and professional obligations.
• Send service messages and, only where permitted, communications you have requested or agreed to receive.

04

Consent and personal health information

We seek meaningful consent for the collection, use, and disclosure of personal information, except where applicable law authorizes or requires otherwise. The form of consent may depend on the sensitivity of the information and the circumstances.

When PHIPA applies, consent for personal health information must relate to the information and purpose, be knowledgeable, and be given voluntarily by the individual or an authorized substitute decision-maker. A separate clinical consent or notice may provide additional detail about records maintained by a regulated healthcare professional.

You may withdraw consent, subject to legal, contractual, safety, and record-retention restrictions. Withdrawing consent may limit our ability to provide a requested service.

05

When information may be shared

We may disclose information only as reasonably necessary for an identified purpose, with consent, or as permitted or required by law. Recipients may include:

• Preluma practitioners, staff, and authorized contractors who need the information to perform their role.
• Your healthcare providers, family member, caregiver, or substitute decision-maker when you authorize the disclosure or the law otherwise permits it.
• Service providers supporting hosting, secure records, scheduling, communications, payment processing, accounting, or professional advice.
• Regulators, insurers, courts, law enforcement, or other authorities where disclosure is legally required or permitted.
• A successor organization in a proposed or completed business transaction, subject to appropriate confidentiality and legal safeguards.

Some service providers may process information outside Ontario or Canada, where it may be subject to the laws of that jurisdiction. We require service providers to use information only for authorized purposes and to protect it appropriately.

06

Security, accuracy, and retention

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information. No internet transmission or storage system can be guaranteed completely secure.

We take reasonable steps to keep information accurate and complete for its intended use. Personal information is retained only for as long as reasonably necessary for the identified purposes and applicable legal, regulatory, insurance, and professional requirements, then securely destroyed or de-identified.

07

Your privacy choices and rights

Subject to applicable law and limited exceptions, you may ask to:

• Learn whether we hold personal information about you and how it has been used or disclosed.
• Access your personal information or request correction of inaccurate or incomplete information.
• Withdraw consent for future optional uses or disclosures.
• Stop receiving optional promotional communications.
• Ask a question or challenge our compliance with this policy.

We may need to verify your identity and authority before responding. A request concerning a clinical record may be directed to the practitioner or health information custodian responsible for that record.

08

Website, cookies, and third-party links

The website may use essential browser storage or similar technologies needed for navigation, preferences, security, or forms. If analytics or non-essential cookies are introduced, we will provide appropriate notice and choices where required.

Links to research, scheduling, payment, social media, or other third-party services are governed by those organizations’ privacy practices. We encourage you to review their policies before providing information.

09

Questions, requests, and complaints

Contact Preluma’s Privacy Contact at admin@preluma.health to ask a question, make an access or correction request, withdraw consent, or raise a concern.

If a privacy concern is not resolved, you may have the right to contact the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario, depending on the information and law involved.

We may update this policy as our practices, services, or legal obligations change. The current version and effective date will be posted on this page.