INTRODUCTION

Route 2 Wellness (“Company,” “we,” or “us”) respects your privacy and is committed to protecting it through this Privacy Policy. This page outlines how we collect, use, and safeguard your personal information when you visit our website, www.route2wellness.com, or use our services.

Our privacy commitment is based on the ten principles contained in The Personal Information Protection and Electronic Documents Act (“PIPEDA”) of Canada.

By using the website, you accept and agree to be bound by this Privacy Policy.  If you do not agree, please do not access or use the website.

SCOPE OF POLICY

This Privacy Policy applies to:

* All content, functionality, and services offered on or through www.route2wellness.com, (the “website”), whether as a guest or as a registered user.

* This policy applies to Personal Information collected via the website and through email, text, forms, applications, or other electronic communications between you and us.

DEFINITION OF PERSONAL INFORMATION

Under PIPEDA, Personal Information refers to any information about an identifiable individual, excluding business contact information such as the name, title, business address or telephone number of an employee of an organization.

WHY WE COLLECT PERSONAL INFORMATION

We collect Personal Information to:

* Provide nutrition counselling, education, and dietetic services

* Distribute publications and educational content on health and nutrition

* Track preferences and keep you informed about relevant products and services

* Process transactions and event registrations

How we collect personal information

5.1 Information You Provide Directly

We collect personal information when you:

* Fill out forms on our website

* Communicate with us via email or contact forms

* Participate in surveys, contests, comments, or feedback requests

* Make a purchase or register for an event

Examples of Personal Information collected directly:

* First and last name

* Full addresses

* Email addresses

* Phone numbers

* Financial information related to transactions

* Age and gender

5.2  Information Collected Automatically:

We may automatically collect data through Google Analytics, cookies, and similar technologies including:

* Location and browsing patterns

* Device information and IP address

* Website visit details (pages visited, time spent, referring/exit pages

* Social media pixels for marketing and advertising purposes

Automatic data is used for statistical purposes and to improve our website and our service offerings. When combined with voluntarily provided information, it may be associated with personal profile.

5.3  Third Party Cookies and tracking

Third parties, such as advertisers, ad networks and servers, and content providers, may use cookies or tracking technologies on our website. These parties may collect data to:

* Deliver interest-based advertising

* Track user activity across different websites and online services

Email Information

If you choose to correspond with us through email, we are committed to keeping your email address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address except as required by law.

All emails sent by us will be in compliance with the Canadian Anti-Spam Legislation (“CASL”). In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further email communication from us.  Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the email.

Sensitive Information Collection

For clients receiving services or potential clients seeking assistance, we may collect sensitive health information, including:

* Medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors, physical, nutritional, or mental health

* Information from other health service providers involved in your care (such as family doctors, naturopathic doctors, or specialists)

* Referral letters, medical reports, test results (such as pathology results, imaging reports), and health records

* Healthcare identifiers and insurance details

Sensitive information is only collected when necessary for service delivery and with informed consent.  

How we use your information

Your personal information may be used to:

* Deliver nutrition and dietetic services

* Improve website functionality and user experience

* Send relevant product or service updates

* Process payments and manage subscriptions

* Comply with legal obligations and enforce terms of service

* Deliver targeted advertising aligned with your preferences

Disclosure of Personal Information

We do not sell, rent, lease or otherwise transfer personal information. We may disclose information only:

* To enforce our terms of service or legal agreements

* To successors in the event of a business sale, merger or  restructuring

* As required by law enforcement or regulatory authorities

We collect, hold, use and disclose personal information as is reasonably necessary for us to operate our business and provide our services, including for the following purposes:

* to contact and communicate with clients and potential clients;

* for the purpose of booking and delivering nutrition and dietetics services and products;

* to deliver digital and physical products;

* to ensure we are the right fit for clients;

* to ensure the accurate and safe provision of services;

* to communicate with other healthcare providers involved in a person’s care;

* to conduct activities relating to research, quality assurance and improvement processes, accreditation, audits, risk and claims management, client satisfaction surveys and staff education and training;

* to market to you and others, including remarketing (this may involve the use of a Facebook pixel or similar technology to allow us to display our advertising to you elsewhere on the internet, for example, on Google or Facebook);

* when required for administrative and internal record keeping

* for statistical purposes; and

* as required by law

We only collect, hold, use and disclose sensitive information where it is necessary for us to provide a service we have been engaged to perform, and not for any unrelated purposes (for example, for research or marketing), unless we have received the person’s prior informed consent.

We do not disclose personal information to overseas recipients.

Data Security Measures

We use physical, organizational, and technological safeguards to protect personal information, including:

* premises security and restricted file access

* security software and firewalls

* password and security policies

Note: email is not a fully secure medium.

Access, Updates, and  Corrects

Since we use your personal information to provide goods or services to you, it is important that the information be accurate and up to date. 

If any of your information changes, is inaccurate or incomplete, please inform us so that we can make any necessary changes.

Access to Personal Information

Upon request, we will provide you with details regarding the personal information that we hold about you in certain circumstances such as set out in the Canadian Privacy Act. We will respond promptly to any reasonable request for access to your personal information and will advise you of the cost, if any, prior to the retrieval of such records or information.

We will not respond to requests for access to personal information that are frivolous, vexatious or repetitious.  In certain circumstances, we may be unable to provide access to some or all of the personal information that we hold about you.

Visitor GDPR Rights

If you are visiting this website from within the European Union (“EU”), you are entitled to certain information and have certain rights under the General Data Protection Regulation (GDPR) of the EU which include the following:

* We will retain any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) we decide that the value in retaining the data is outweighed by the costs of retaining it.

* You have the right to request access to your data that we store and the rights to either rectify or erase your personal data.

* You have the right to seek restrictions on the processing of your data.

* You have the right to object to the processing of your data and the right to the portability of your data.

* To the extent that you provided consent to our processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.

We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.

For more information about your rights as a website visitor from the EU and the GDPR, please see The European Commission website.


VISITOR CCPA Rights

If you are visiting this website from within California, you are entitled to certain information and have certain rights under the California Consumer Privacy Act (CCPA) which include the following:

* You have the right to ask a business to disclose to you: (1) the categories and/or specific pieces of personal information they have collected about you, (2) the categories of sources for that personal information, (3) the purposes for which the business uses that information, (4) the categories of third parties with whom the business discloses the information, and (5) the categories of information that the business sells or discloses to third parties. You can make a request to know up to twice a year, free of charge.

* You have the right to request that the business delete personal information they collected from you, and tell their service providers to do the same, subject to certain exceptions (such as if the business if legally required to keep the information).

* You have the right to request the business to stop selling or sharing your personal information (“opt-out”), including via a user-friendly global privacy control. Businesses cannot sell or share your personal information after they receive your  opt-out request unless you later authorize them to do so again.

* You have the right to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

You have the right to be notified, before or at the point businesses collect your personal information, of the types of personal information they are collecting and what they may do with that information.

Generally, businesses cannot discriminate against you for exercising your rights under the CCPA. Businesses cannot make you waive these rights, and any contract provision that says you wave these rights is unenforceable.

For more information about your rights as a website visitor from California, and the CCPA, please see The California Consumer Privacy Act Website.

VISITOR QUEBEC RIGHTS

If you are visiting this website from within the Province of Quebec, you are entitled to certain information and have certain rights under The Privacy Legislation Modernization Act or Law No. 25, which include the following:

* Right to information: you have the right to understand how your personal information is collected, used, and disclosed. This includes information about any third-party recipients of their data.

* Right to access: you have the right to request access to your personal information held by the organization, allowing you to understand how it is being used.

* Right to rectification: you have the right to request that inaccurate or incomplete information be corrected.

* Right to erasure (right to be forgotten): you have the right to request that your personal information be deleted, subject to certain exceptions. This right is not currently present in most U.S. state laws.

* Right to object to automated decision-making: you have the right to object to decisions made solely based on automated processing and potentially request human intervention.

* Right to data portability: individuals can request their personal information in a structured format, making it easier to transfer it to another organization.

For more information about your rights as a website visitor from Quebec, please see the Commission d’accès à l’information du Québec (CAI).

Changes to this Privacy Policy

We may update our Privacy Policy from time to time without notice.  Please check our Website for the most up-to-date version of the policy.

Questions, concerns or requests for access

If you have any questions or concerns regarding our Privacy Policy, please contact us h[email protected]