1. Who this policy covers
This policy is about Trean Health Inc. (“Trean Health”, “we”), the technology company that operates trean.ca and the platform behind it. It governs personal information we collect from visitors, enquirers and prospective patients under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
It does not cover your medical record. Clinical care is provided by Trean Clinical Services Inc., a separate and independent medical practice, which is the health information custodian for your personal health information under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). Its privacy policy governs that information and is a separate document.
Where we handle health information, we do so only as their service provider. Where Trean Health processes personal health information on the platform, it does so solely on behalf of, and under the written instructions of, Trean Clinical Services Inc. We do not use it for our own purposes.
2. What we collect, and why
| Category | What it includes | Why |
|---|---|---|
| Eligibility check | Age band and province only | To tell you whether we can help before you give us anything else |
| Enquiry details | Name, email, and the area of care you selected | To contact you and route you to the right service |
| Partner enquiries | Name, business name, email, phone, interests | To respond to gym and trainer enquiries |
| Website analytics | Aggregate usage with IP anonymisation | To understand how the site is used |
| Support correspondence | What you send us | To answer you |
We do not collect clinical information on this website. The eligibility check asks your age band and province. The enquiry form asks which area of care you are interested in. Neither asks about symptoms, conditions, medications or results, and nothing clinical is stored by Trean Health.
3. Consent
- We ask for what we need at the point we need it, and we tell you why.
- You may withdraw consent at any time by contacting our Privacy Officer. Withdrawal is not retroactive.
- We do not require consent to unrelated purposes as a condition of using the site.
4. Marketing
We do not use health information for marketing. If you ask us to keep you informed we will email you, and every message will have an unsubscribe link, as required by Canada’s Anti-Spam Legislation (CASL). We do not sell personal information and we do not run advertising trackers on pages about health conditions.
5. Service providers, and where information is processed
| Provider | Purpose | Processed in |
|---|---|---|
| HubSpot | Enquiry and contact records. No clinical data. | United States |
| Cloudflare | Website hosting and delivery | Canada (regional localisation) |
| Google Analytics 4 | Aggregate website analytics, IP anonymised | United States |
| TELUS Health | Clinical record system, on behalf of the practice | Canada |
Your clinical record never leaves Canada. The TELUS Health clinical record system and our laboratory partner operate in Canada, and our website is served from Cloudflare’s Canadian region. The only information processed outside Canada is contact and enquiry data in HubSpot and aggregate, IP-anonymised website analytics, both in the United States. Information processed outside Canada is subject to the laws of that country, including lawful access by foreign authorities. No clinical information is held outside Canada.
6. Your rights
- Access. You may ask what personal information we hold about you and get a copy. We will respond within 30 days.
- Correction. You may ask us to correct information that is inaccurate or incomplete.
- Withdraw consent. At any time, subject to legal and contractual limits, which we will explain if they apply.
- Deletion. You may ask us to delete your enquiry record. Note that this does not extend to your medical record, which the practice must retain by law.
- Complain. To our Privacy Officer, and to the Office of the Privacy Commissioner of Canada at any time.
Office of the Privacy Commissioner of Canada · 30 Victoria Street, Gatineau QC K1A 1H3 · 1-800-282-1376 · priv.gc.ca
7. Safeguards
- Encryption in transit and at rest.
- Access limited to those who need it, and logged.
- Contractual privacy and security obligations on every service provider.
- No clinical data on the public website, which is a static site with no database.
If something goes wrong, we will notify you and the Office of the Privacy Commissioner of Canada where a breach creates a real risk of significant harm, as PIPEDA requires, and we will keep a record of every breach whether or not it is reportable.
8. How long we keep it
Enquiry records are kept for 24 months from your last contact with us, then deleted. Aggregate analytics are kept in a form that does not identify you.
9. Cookies
We use cookies necessary for the site to work and, with analytics enabled, cookies that tell us how the site is used in aggregate. You can refuse non-essential cookies without losing access to anything.
10. Children
Our services are for adults. We do not knowingly collect information from anyone under 18, and the eligibility check stops before collecting contact details if you tell us you are under 18.
11. Contact
Dr Karim Vellani — Privacy Officer, Trean Health Inc.
- 11-345 Bloor St E, PB #204, Toronto, Ontario M4W 3J6
- privacy@trean.ca
- 1-833-987-3265
12. Changes
We will post any updated version here with a new date. Where a change is significant we will tell you directly.