Privacy Policy & Terms of Use

The Tummy Clinic Inc. ("The Tummy Clinic", "we", "us", or "our") operates a virtual specialty clinic providing care for digestive health conditions across multiple Canadian provinces. This document combines our Privacy Policy (Sections 1–12) and our Terms of Use (Sections 13–18).

By using our website, booking an appointment, or becoming a patient of The Tummy Clinic, you agree to the practices described below.

This policy is governed by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), and where applicable, by provincial privacy and health-information laws including Ontario's Personal Health Information Protection Act (PHIPA), British Columbia's Personal Information Protection Act (PIPA BC), Alberta's Health Information Act (HIA) and Personal Information Protection Act (PIPA AB), and equivalent legislation in the Maritime provinces. Practitioners providing care to you are also bound by the rules of their respective regulatory colleges (see Section 13).

If you have questions about this policy or our handling of your information, contact our Privacy Officer at hello@thetummyclinic.ca.

1. Information We Collect

1.1 Personal information you provide

When you book a discovery call, become a patient, request a callback, or contact us, we collect:

• Identification: name, date of birth, gender
• Contact details: email address, phone number, mailing address, province of residence
• Health information: symptoms, medical history, prior diagnoses, medications, lifestyle factors, lab results, treatment notes (collected only after you become a patient)
• Insurance and billing details: insurance provider, policy number, payment method
• Communications: content of emails, SMS messages, secure messages, and call notes between you and our team

1.2 Information collected automatically

When you visit our website, we automatically collect:

• Device and browser data: IP address, browser type and version, operating system, device type, screen resolution
• Usage data: pages viewed, time on page, referring URL, click activity, scroll depth, form interactions
• Marketing attribution: UTM parameters (utm_source, utm_medium, utm_campaign, etc.), Google Click ID (gclid), Facebook Click ID (fbclid), landing page, traffic source

This data is collected via cookies, local storage, and tracking pixels operated by us and the third-party services listed in Section 4.

1.3 Information from third parties

We may receive information about you from:

• Referring physicians or healthcare providers who refer you to our clinic
• Insurance providers, where you authorize coordination of benefits
• Other practitioners on our team, where you receive multidisciplinary care
• Marketing platforms (Google Ads, Meta) that report on ad performance

2. How We Use Your Information

We use personal information only for the purposes for which it was collected, including:

• Scheduling and confirming appointments
• Providing clinical care and follow-up
• Sending appointment reminders, treatment plans, lab results, and care-related communications
• Processing payments and submitting insurance claims
• Responding to inquiries and callback requests
• Improving our website, services, and patient experience
• Sending educational content, newsletters, or promotional updates only to those who have opted in
• Complying with our legal, professional, and regulatory obligations (CONO, CPSO, CCHPBC, CNDA, etc.)

We will not use personal health information for purposes unrelated to your care without your express consent.

3. SMS / Text Message Communications

If you provide your mobile phone number and consent to SMS communications, we may send you text messages related to:

• Appointment confirmations, reminders, and rescheduling
• Discovery call follow-ups and care plan updates
• Lab results notifications
• Administrative messages (billing, intake forms)

Message frequency varies based on your care stage. Message and data rates may apply. You may opt out at any time by replying STOP to any text message, or by emailing hello@thetummyclinic.ca. Reply HELP for assistance.

Consent to receive SMS messages is not a condition of booking an appointment or receiving care.

4. Cookies and Tracking Technologies

Our website uses cookies, local storage, and tracking pixels to operate, measure performance, and improve user experience. We use the following services:

Service	Purpose	Data shared
Google Tag Manager	Container for all other tracking tags	Device + page data
Google Analytics 4	Website analytics, traffic source attribution	Anonymized usage data, IP-truncated
Google Ads	Conversion tracking, remarketing	Click ID, conversion event
Meta Pixel (Facebook)	Conversion tracking, ad measurement	Page view, conversion event
Microsoft Clarity	Session replay and heatmaps for UX research	Pseudonymized session data
Hobber / GHL	Booking widget, contact management	Form submissions, calendar bookings
Amplitude	Product analytics	Event data

You can disable cookies through your browser settings. Disabling cookies may limit some website functionality. We do not use cookies or pixels to collect personal health information.

5. How We Share Information

We share personal information only as required to provide care or as required by law:

• Members of your circle of care: Your assigned practitioners (NDs, dietitians, psychotherapists, NPs, physicians) may access your file to coordinate care
• Service providers acting on our behalf (electronic medical records, billing, secure communications, hosting), bound by confidentiality and contractual obligations
• Insurance providers, where you have authorized us to submit claims
• Government, regulatory, or legal authorities, where required by law or compelled by valid legal process
• In the event of a clinic merger, acquisition, or transfer of assets, where successor entities assume the same privacy obligations

6. International Data Transfers

Some service providers (including Google, Meta, and certain hosting providers) may process data outside of Canada, including in the United States. Where this occurs, the data may be subject to the laws of the jurisdiction in which it is processed. We use only providers that maintain industry-standard safeguards.

7. Data Retention

We are required to keep patient records for at least 10 years, in accordance with the regulatory colleges governing our practitioners. Specifically:

• Health records are retained for a minimum of 10 years from the last patient interaction, or 10 years past the age of majority for minors
• Booking, billing, and contact records are retained for 7 years to meet tax and accounting obligations
• Marketing and analytics data is retained for up to 26 months
• SMS opt-in records are retained for as long as you remain opted in, plus 5 years for compliance recordkeeping

8. Security

We use reasonable administrative, technical, and physical safeguards to protect personal information, including:

• Encrypted transmission (TLS) for all data sent to and from our website and patient portal
• Encrypted storage of clinical records
• Access controls limiting personal health information to authorized members of your circle of care
• Staff training on PHIPA and privacy obligations

No system is perfectly secure. If we become aware of a breach affecting your personal information, we will notify you in accordance with applicable law.

9. Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you
• Correct information that is inaccurate or incomplete
• Withdraw consent for non-essential uses (e.g., marketing emails, SMS) at any time
• Request deletion of records that are not subject to legal retention requirements
• File a complaint with our Privacy Officer, or with the Office of the Privacy Commissioner of Canada (priv.gc.ca) or your provincial privacy commissioner

To exercise any of these rights, contact our Privacy Officer at hello@thetummyclinic.ca. We will respond within 30 days.

10. Children

Our services are not directed to children under the age of 16 without parental or guardian consent. We do not knowingly collect personal information from minors without proper authorization.

11. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or applicable law. The "Last updated" date at the top of this policy indicates when it was most recently revised. Material changes will be communicated through our website or, where appropriate, by direct notice to active patients.

12. Contact

Privacy Officer
The Tummy Clinic Inc.
Email: hello@thetummyclinic.ca
Website: https://www.thetummyclinic.ca

For complaints to a regulator:

• Federal: Office of the Privacy Commissioner of Canada — priv.gc.ca
• Ontario: Information and Privacy Commissioner of Ontario — ipc.on.ca
• British Columbia: Office of the Information and Privacy Commissioner for BC — oipc.bc.ca
• Alberta: Office of the Information and Privacy Commissioner of Alberta — oipc.ab.ca

13. Practitioner Regulation and Scope of Practice

The Tummy Clinic provides multidisciplinary virtual care delivered by Naturopathic Doctors (NDs), Registered Dietitians (RDs), Nurse Practitioners (NPs), Psychotherapists, and Medical Doctors (MDs). Each practitioner is licensed and regulated in the province in which they practise. Care is delivered only in provinces where a practitioner holds an active licence to do so.

Practitioners are bound by the standards of practice, codes of ethics, and confidentiality requirements of their respective regulatory colleges, including:

• College of Naturopaths of Ontario (CONO) — Ontario NDs
• College of Complementary Health Professionals of British Columbia (CCHPBC) — BC NDs
• College of Naturopathic Doctors of Alberta (CNDA) — Alberta NDs
• College of Physicians and Surgeons of Ontario (CPSO) — Ontario MDs
• College of Dietitians of Ontario and equivalent provincial bodies — RDs
• College of Nurses of Ontario (CNO) and equivalent provincial bodies — NPs
• College of Registered Psychotherapists of Ontario (CRPO) and equivalent provincial bodies — psychotherapists

Care is provided within the scope of each practitioner's licence. The Tummy Clinic does not provide services in provinces or territories where its practitioners are not authorized to practise. You may verify the regulatory status of any practitioner through the public register of the relevant college.

14. Medical Disclaimer and Emergencies

The information on our website, in our communications, and in any materials provided through our care is for general educational and informational purposes and to support the care relationship between you and your treating practitioner. It is not a substitute for the professional judgment of a qualified health practitioner, and it does not establish a practitioner-patient relationship until you have formally enrolled as a patient and a treating practitioner has accepted you into care.

Individual results from any care, treatment, or program described on our website will vary. No outcome is guaranteed.

15. Booking, Cancellation, and No-Show Policy

• Discovery calls are complimentary and may be cancelled or rescheduled at any time before the scheduled time using the link provided in your confirmation message.
• Paid appointments are subject to our cancellation policy as communicated at the time of booking. A minimum of 48 hours' notice is required to cancel or reschedule without a fee.
• No-shows and late cancellations may be subject to a fee, payable before further appointments can be scheduled.
• Repeated no-shows may result in discharge from the clinic, in accordance with the practitioner's professional obligations.

Specific cancellation terms applicable to your treating practitioner will be provided to you at the start of care.

16. Payment, Insurance, and Refunds

• Fees are quoted in Canadian dollars and are payable at the time of service unless otherwise arranged.
• The Tummy Clinic offers direct billing to participating insurers where available; otherwise, you will be issued a receipt suitable for submission to your insurance provider.
• Coverage varies by insurer, plan, and practitioner type. The Tummy Clinic makes no representation or warranty regarding insurance reimbursement.
• Refunds for unused services may be issued at the clinic's discretion, less any applicable administrative or no-show fees.

17. Limitation of Liability

To the maximum extent permitted by law:

• The Tummy Clinic, its directors, officers, employees, and contractors are not liable for any indirect, incidental, special, consequential, or punitive damages arising out of your use of our website, services, or communications.
• Nothing in these Terms limits the professional liability of an individual practitioner under the rules of their regulatory college, or the rights of a patient under provincial health legislation.
• Our website may contain links to third-party websites. We are not responsible for the content, privacy practices, or accuracy of information on those websites.

18. Governing Law

These terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable in Ontario, without regard to conflict-of-laws principles. Where care is delivered to a patient resident in another Canadian province, the privacy and health-information laws of that province also apply.

Any dispute arising under these terms shall be resolved in the courts of Ontario, except where the patient resides in another Canadian province and provincial law requires otherwise.

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