Privacy Policy

LAST UPDATE OF THIS PRIVACY POLICY  May 29, 2025

BEFORE USING OUR WEBSITE, PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy is applicable to Primal Athletics (“The Company”) and sets out our policy on the gathering and use of information on this site. The Company is committed to providing safe website for visitors of all ages and has implemented this Privacy Policy to demonstrate our firm commitment to your privacy. The Company complies with Canadian Federal and Provincial privacy laws and regulations including the Personal Information and Electronic Documents Act.

There may be links from our Site to other web site; note that this Privacy Policy applies only to our Site and not to web site of other companies or organizations to which our Site may be linked. You must check on any linked site for the privacy policy that applies to that site and/or make any necessary inquiries in respect of that privacy policy with the operator of the linked site. These links to third party website are provided as a convenience and are for informational purposes only. The Company does not endorse, and is not responsible for, these linked websites.

Although you are not required to register to access our Site, you may be asked to provide us with personal information when you visit certain sections of our Site. Your use of our Site signifies your acknowledgement and consent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not continue to use our Site. Your continued use of the Site signifies your acceptance of these terms and any changes in effect at the time of use.

COLLECTION OF PERSONAL INFORMATION

Personal Information is information about you that identifies you as an individual, for example, your name, address, e-mail address, or telephone number.

We collect information that you voluntarily provide to us through responses to surveys, search functions, questionnaires, feedback, Tell Your Story forms and the like. We may also ask you to provide additional information such as your e-mail address if you want to obtain additional services, information, participate in a contest or to resolve complaints or concerns.

HOW DOES COMPANY USE INFORMATION GATHERED ABOUT ONLINE VISITORS?

Before forwarding us any personal information, please be advised that any information gathered on our Site may be used in the aggregate for research and development relating to our Site and/or for future site development and, if you ask us to, to send you promotional materials. In particular, we may use information gathered about you for the following purposes: to monitor interest in our range of products and/or services and to assist us to tailor the content of our Site to your needs by collecting information about your preferences through tracking of patterns page views on our Site; to create a profile relating to you in order to show you the content that might be of interest to you and to display the content according to your preferences; and, in circumstances where you have indicated that you wish to receive additional information, to send you information about us and promotional material about our products together with details of any offers we may have available from time to time.

PROMOTIONAL AND INFORMATIONAL OFFERS

With the permission of an online visitor, information submitted at the time of registration or submission may be used for marketing and promotional purposes by the Company provided notice of this fact is made available online. If a visitor objects to such use for any reason, he/she may prevent that use, either by e-mail request or by modifying the registration information provided. The Company uses reasonable efforts to maintain visitors’ information in a secure environment. If you have submitted personal information and want to change it or opt-out, please contact us as described below.

DISCLOSURE OF INFORMATION

The Company will not disclose personal information that you provide on its Site to any third parties other than to a Company agent except: i) in accordance with the terms of this Privacy Policy, or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order, and/or iii) if you are reporting an adverse event/side effect, in which case the Company may be required to disclose such information to bodies such as, but not limited to, Canadian and/or international regulatory authorities. Please note that any of these disclosures may involve the storage or processing of personal information outside of Canada and may therefore be subject to different privacy laws than those applicable in Canada, including laws that require the disclosure of personal information to governmental authorities under circumstances that are different than those that apply in Canada.

COOKIES

The Company, in common with many web site operators, may use standard technology called “cookies” on its Site. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser; however, some areas of the Site may not function properly if you do so.

PROTECTION OF CHILDREN ONLINE

The Company considers the protection of children’s privacy, especially online, to be of the utmost importance. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, our Site or help-seeking information lines.

ADDITIONAL TERMS FOR CERTAIN WEBSITE

The following additional information applies to our Site that require registration. Generally, you are not required to provide personal information as a condition of using our Site, except as may be necessary to provide you with a product or service that you have requested. However, some of our Site are restricted to certain individuals such as health care professionals or our prescription drug patients and we may require these individuals to register upon entry by providing us with certain information.

PROTECTION OF INFORMATION:

Our Commitment to Security
We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. The Company applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

Storage of Information
Personal information you share with us is stored on our database servers at Company data centers (in whatever country they may be located), or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Policy.

Policy Change

If we alter our Privacy Policy, any changes will be posted on this page of our Site so that you are always informed of the information we collect about you, how we use it and the circumstances under which we may disclose it.

ACCEPTANCE OF OUR PRIVACY POLICY

By using this Site or any other The Company Site or interactive banner ads, you signify your acceptance of our Privacy Policy, and you adhere to the terms and conditions posted on the Site. By submitting your information, you agree that it will be governed by our Privacy Policy.

Primal Athletics Inc. Privacy Policy

At Primal Athletics Inc., we are committed to protecting your privacy and ensuring the security of your personal health information (PHI) in compliance with the Personal Health Information Protection Act (PHIPA), Ontario. This privacy policy outlines how we collect, use, store, and disclose your PHI, including the use of third-party services like JaneApp for secure health record management.

1. Collection of Personal Health Information (PHI)

We collect PHI to provide kinesiology and rehabilitation services. PHI includes:
– Your name, date of birth, and contact information
– Your medical history, injury details, and treatment plans
– Assessment results, rehabilitation progress, and session notes
– Insurance information (if applicable)

How We Collect PHI:
– Directly from you (via intake forms, assessments, or consultations)
– Through JaneApp, our PHIPA-compliant electronic health record system
– From healthcare providers (with your consent)

2. Use of JaneApp for Secure PHI Management
Primal Athletics uses JaneApp, a third-party PHIPA-compliant electronic medical record (EMR) system, to securely store and manage PHI.

How JaneApp Protects Your PHI:
– Data is stored on secure, encrypted Canadian servers (PHIPA requirement).
– Restricted access: Only authorized staff can view your records.
– Audit logging: Tracks access to ensure compliance.
– Two-factor authentication (2FA): Prevents unauthorized access.
– Data backups: Ensures PHI is not lost due to system failures.

By using our services, you consent to the collection and storage of your PHI in JaneApp.

3. Your Rights Under PHIPA

Under PHIPA, you have the right to:
– Access your PHI: Request copies of your records at any time.
– Request corrections: If any PHI is inaccurate, you can request corrections.
– Withdraw consent: You may withdraw consent for PHI collection, except where required by law.
– Restrict disclosures: Limit how and with whom your PHI is shared.
– File a complaint: If you believe your PHI is mishandled, you can contact the Ontario Information and Privacy Commissioner (IPC).

To exercise these rights, please contact us at info@primalathletics.ca

4. Disclosure of PHI

We do not sell or use PHI for marketing purposes, PHI is only shared:
– With your consent (e.g., sharing with other healthcare providers).
– As required by law (e.g., court orders, public health reporting).
– For insurance purposes, only with your authorization.

If PHI is disclosed, it is protected through secure communication channels.

5. Security and Retention of PHI

Primal Athletics follows strict PHIPA security standards:
– Encryption: All PHI is stored securely in JaneApp’s encrypted system.
– Access Controls: Only authorized staff can access PHI.
– Secure Communications: Emails containing PHI are encrypted or sent via secure portals.
– Retention Policy: PHI is retained for 10 years after last client contact (or longer for minors).

If you request PHI deletion, we will anonymize records where legally permitted.

6. PHI Breach Notification

If a data breach occurs, we will:
1. Notify affected individuals as required by PHIPA.
2. Report the breach to the Ontario Information and Privacy Commissioner (IPC).
3. Take immediate steps to secure data and prevent future breaches.

If JaneApp experiences a breach affecting your PHI, we will ensure you receive timely notification.

7. Updates to this Policy

We may update this policy to reflect changes in PHIPA regulations or our practices. If significant changes occur, we will notify affected individuals.
Contact Information
For any privacy concerns, requests, or inquiries, contact:
Primal Athletics
Email: info@primalathletics.ca
Phone: 647 896-3294

If you believe your privacy rights have been violated, you may file a complaint with the Ontario Information and Privacy Commissioner at www.ipc.on.ca.

By using our services, you acknowledge and agree to this privacy policy.