Privacy Policy

Last Updated: September 15, 2022

Hello and welcome to the Oona Wellness Group. Please read our privacy policy below. It’s important that you know what type of information we collect about you, and how we will use and share that information.

We are Oona (“we,” “us,” or “our”), Canada’s leading studio for fertility, perinatal, pediatric and family wellness and education (“Services”).

Oona takes great care to protect your private and personal information under applicable legislation. Before you start using or browsing our Website, please take a moment to carefully read and understand our Privacy Policy, which tells you what personal information we collect about you, how we use that personal information, how this information may be shared, and what choices and rights you have with respect to this information.

Our Privacy Policy applies to your access and use of our Website, which includes (i) the website and content at https://oonacares.com (the “Website”); and (ii) any other mobile or web applications that we have now or in the future.

We are headquartered in Toronto and our Website is provided to you by us. If you are a resident of the European Union (“EU”), Oona is the controller of your personal data for the purposes of the EU data protection legislation.

This policy was originally written in English. To the extent a translated version conflicts with the English version, the English version governs. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Website. If you have questions or comments about this Privacy Policy, please contact us at: hello@oonacares.com.

1. WE COLLECT, USE, SHARE AND OTHERWISE PROCESS INFORMATION

Oona relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

• as necessary to provide the Website and fulfill what we promised. For example, we cannot respond to your inquiry if we do not collect your email address in our contact form;
• where you have consented to the processing of your information;
• where necessary to comply with a legal obligation, such as a court order or to exercise or defend legal claims;
• to protect your vital interests, or those of others, such as in the case of emergencies;
• where you have made the information public;
• where necessary in the public interest; and
• where necessary for the purposes of Oona’s or a third party’s legitimate interests, such as those of our service providers and partners.

2. OUR LEGITIMATE INTERESTS

Oona’s legitimate interests and those of our third-party service providers and partners include:

Providing and improving the Website. We do so as it is necessary to provide our Website to you, and to keep developing and improving the Website.

To respond to your inquiries. If you would like to inquire about our Services, we need to be able to contact you and respond to you.

Keeping the Website safe and secure. We do so as it is necessary to ensure the Website is secure, and to protect against fraud, spam and abuse, etc.

3. INFORMATION THAT OONA COLLECTS ABOUT YOU

When you use our Website, we collect various types of information about you. Some of this information like name and email address, can be used to identify you (“Personally Identifying Information” or “PII”), and some of this information, like activity and log data, cannot be used to identify you (“Non-Personally Identifying Information” or “Non-PII”).

The amount and type of Information we ask for depends on the nature of the interaction. We will only collect such information as is necessary or appropriate to fulfill the purpose of your requested interaction with Oona.

We collect information in a few different ways, including information that you enter when you fill in our contact form.

Information you provide us

We collect information that you provide us, including:

• Contact form information: We collect information you provide us in our contact form. This allows us to provide a personalized response to you.If you do not want to provide us with any personally-identifying information, do not fill out our contact form.
• Communications: When you communicate with us (via email, etc.), we store a copy of your communications.
  Booking through Jane: When you book your appointment online via Jane (Janeapp), a clinic management software that we use to allow you to book appointments online, we collect the information you provide. This allows us to send you reminders and communicate information that is related to your appointment.
• Workshops and classes sign-up information: We collect information you provide us through Mind Body Online, the booking software that we use to administer the online booking of our workshops and classes. This allows us to send you reminders and communicate information that is related to the class or workshop you signed up for.
• Surveys and contests: If you choose to participate in any of our surveys, or promotions, we will collect the information you provide us at that time.

Such information is generally considered to be personally identifying information.

Information from third parties

We collect information that third parties provide us, including publicly available information, and information from our partners and service providers. The information we receive from these other platforms for may or may not be considered Personally Identifiable Information.

• Publicly available information: We may collect information that you make available to the public, such as when you make an Instagram post about Oona on your public Instagram page.
• Service Providers: We may receive information about you from our partners, service providers and retail affiliates. For example, Mailerlite may provide us with your updated email address.

Information automatically collected when you use the Website

We collect certain information automatically whenever you use the Website.

• Website activity: We collect information about your use of the Website, including your browsing activity, the webpages you view, the date and time of your visit, geographic location, etc.
• Device information: We also collect information that your device provides us in connection with your use of the Website, such as your device type, browser type, IP address, etc.
• Cookies and similar technology: We use cookies in connection with your use of the Website to collect information related to what you see and interact with. Cookies are small files placed on your hard drive that assist us in providing our services. We may use cookies to collect usage information, determine our total audience size and traffic and determining which areas of the Website are of greatest interest to users. Note that if you wish, you can turn off cookies via your browser.
• Web Beacons/Pixel Tags: These are invisible tags placed on certain pages of our Website. When you access our Website, pixel tags generate a notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit. We may use web beacons to recognize users and access traffic patterns.

4. USE OF INFORMATION

In general, we use both Personally Identifiable Information and Non-Personally Identifiable Information in order to administer, operate and provide the Website to you.

Here are some of the ways that we use your information:

How we use your Personally Identifiable Information

• trouble-shooting technical issues that you encounter;
• to analyze, evaluate and improve the functionality and experience of our Website. For example, we use crash reporting to be able to fix issues promptly.
• to respond to inquiries when you contact us;
• to prevent fraud and to maintain a quality experience for our business purposes or legal reasons;
• to enforce our Privacy Policy;
• to provide you with system or administrative messages relating to the Website;
• to let you know about new features or updates to our Privacy Policy;
• to send you information about your relationship or transactions with us;
• to send you marketing communications (where you have opted-in to receive such messages);
• to administer surveys, contents or promotions (to the extent that you have opted-in to participate in these).

How we use your Non-Personally Identifiable Information

• to analyze, evaluate and improve our Website functionality and experience. For example, we use crash reporting to be able to fix issues promptly and analytics to gain insight into what actions you are taking within the Website;

Aggregated Statistics

We may also de-identify or aggregate the information collected in connection with the Website, in ways that do not personally identify you. From time to time, we may use this aggregated Non-PII to perform statistical analyses of user behavior and demographics in order to measure the interest in the Oona Services and use of our Website, or to publish trends such as number of website visits, etc.

Any use of your information that is incompatible with these uses will be disclosed to you in advance so that you may opt out of such uses at your discretion.

5. SHARING YOUR INFORMATION

We will not rent or sell your information to anyone.

We share your information in the following ways:

Staff

We may share your information with individuals who work at and with Oona including our admin staff, practitioners and independent contractors such as workshop instructors and doulas.

Service Providers

We may share your information with third parties who provide services to Oona such as hosting by WordPress, mailing list management by Mailerlite, analytics and reporting by Google Analytics, etc. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. Except as otherwise stated in this Privacy Policy, these third party service providers are required not to use your information other than to provide the services requested by us.

Legal Requests

We cooperate with law enforcement inquiries and demands for information that are made under force of law. Therefore, we may disclose your information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), in accordance with the applicable law (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, in accordance with the applicable law (c) as otherwise required under any applicable law.

We may also disclose your information if we determine in good faith that disclosure is reasonably necessary or appropriate to protect the property rights of Oona, third parties, yourself or the public at large.

Sale of Business

If Oona becomes involved in a business merger, acquisition, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your information in connection with such transaction. If we do this, such disclosure will be subject to confidentiality arrangements that are typical of such transactions.

Marketing

We do not share your information with third parties for promotional purposes unless you have opted-in to such disclosure. If you have opted-in to have your information shared, you may choose to opt-out from receiving further communications from any third party that is not our agent or service provider at any time by contacting the third-party directly.

6. PROTECTING YOUR INFORMATION

Oona strives to protect your information. We use commercially reasonable administrative, technical, and physical measures to safeguard your information in our possession against loss, theft and unauthorized use, disclosure or modification. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. For data transmission security, we use standard encryption protocols (SSL/HTTPS) for transmission of information. The encryption process protects your information by scrambling it before it is sent to and from us. Our hosting service providers for our database and application are reputable third-party hosting service providers whose privacy, security, transparency and industry-specific standards are best-in-class. Our systems and databases are backed up regularly to help protect your information in case of an uncontrollable catastrophe.

Unfortunately, no data transmission over the web and mobile applications and the internet and no storage of data can be guaranteed to be 100% secure. Therefore, while we strive to make all reasonable efforts to use commercially acceptable means to protect your information, we cannot guarantee the security of any information you transmit to us, and you acknowledge that there is always some risk when transmitting information to us through the Website.

7. OUR PRIVACY COMMITMENT TO YOU

We are committed to protecting your privacy and ensuring the confidentiality of your personal health information. The types of personal health information we collect may include your name, date of birth, health history, OHIP number and records of the care provided to you. We collect, use and disclose personal health information for the following purposes:

• to provide fertility, prenatal, postpartum and pediatric health services to our patients
• to obtain payment for services provided (from you, OHIP, WSIB, your private insurer or others)
• to teach students and to provide continuing education
• to our staff
• to comply with our regulatory obligations to the following regulatory bodies:
  • College of Massage Therapists of Ontario
  • College of Chiropractors of Ontario
  • College of Naturopaths of Ontario
  • College of Occupational Therapists of Ontario
  • College of Registered Psychotherapists of Ontario
  • College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario
  • Ontario Association of Osteopathic Manual Practitioners
  • International Board of Certified Lactation Consultant
• to advise clients about special events or opportunities (but we will always obtain express consent to do so)
• To fundraise or provide marketing activities for the operations of our organization, with the express or implied consent of our clients.
• for other purposes permitted by law

We will collect, use and disclose only as much personal health information as is needed to achieve these purposes. You can withhold or withdraw your consent to the collection, use or disclosure of your personal health information by contacting us (details below).

Access to Health Records

You have the right to seek access to your health records that we keep and to ask us to correct a record if you believe it is inaccurate or incomplete. Please contact us for more information.

Questions or Concerns?

If you have questions or want to make a complaint about our privacy practices, please contact: Sarah Mickeler at 416-960-5656 or hello@oonacares.com

You also have the right to complain to the Information and Privacy Commissioner of Ontario at the address below if you have concerns about our privacy practices or how your personal health information has been handled:

Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8
Telephone: Toronto Area (416/local 905): (416) 326-3333
Long Distance: 1 (800) 387-0073 (within Ontario)
TDD/TTY: (416) 325-7539
FAX: (416) 325-9195
www.ipc.on.ca

8. DATA RETENTION

We retain information as long as it is necessary to provide the Website or respond to you and others, subject to any legal obligations to further retain such information. Information will generally be kept until it is no longer necessary to provide the Website, respond to you or until you ask us to delete it, whichever comes first. We may however retain information to comply with the law, to prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will, of course, be subject to this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services to you may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to Oona, such as statistics related to the use of the Website.

9. MANAGING YOUR SETTINGS

Adjusting Email Preferences

If you originally subscribed or opted-in to receive newsletter communications from Oona, you may unsubscribe by following the instructions contained at the bottom of each type of email.

Updating Information

You may correct, amend or update your information that is inaccurate at any time by contacting us at: hello@oonacares.com.

Deleting Information and Accounts

You may request that your information is deleted by contacting us at: hello@oonacares.com. Oona will generally respond to your request within 10-14 business days.

10. EU MEMBER RIGHTS

Read this if you live in the EU!

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We described these rights below:

Access and Porting

If you require access to or need to download a copy of your information, please contact us at: hello@oonacares.com. We will generally respond to your request within 10-14 business days.

Correcting and Deleting

You can also rectify, restrict, limit or delete much of your information by contacting us at hello@oonacares.com. We will generally respond to your request within 10-14 business days.

Object

Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke Consent

Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

Complain

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Response

We will respond to all requests that we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identify in order to help us respond efficiently to your request.

11. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The Website is hosted and operated from within the United States and Canada. If you are located outside of the United States or Canada and choose to use the Website or provide information to us, you acknowledge and understand that your information will be transferred, processed and stored in the United States or Canada, as it is necessary to provide the Website and our obligations to you under the Terms of Service.

12. CHILDREN

The Website is not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18 years of age. In the event that we learn that we have collected personal information from a child under 18 years of age, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us as at hello@oonacares.com.

13. ADDITIONAL DETAILS

Information provided on our Website

This website is not intended to be used to provide medical advice. As such, nothing on this website should be construed as medical advice. If you require medical advice, please contact your primary healthcare provider or contact us to make an appointment with one of our practitioners.

Feedback

Please feel free to send us comments, register a complaint, or ask questions about our Services. We may store your communications, including any personal information you include in them, so that we can effectively respond to you.

Links to Other Websites

Oona Services may contain links to other websites on the internet maintained by third parties. Clicking on a link to a third party site will make you leave the Website and go to the site you requested. We cannot control the activities of third parties. Therefore, we cannot accept responsibility for any use of your information by such third parties, and we cannot guarantee that these third parties will adhere to the same privacy practices as Oona. We encourage you to carefully review the privacy policies of any other service provider from whom you request services.

14. CHANGES IN THIS PRIVACY POLICY

Oona reserves the right to make changes to this Privacy Policy at any time and in our sole discretion, so please check back frequently. If we decide to change our privacy practices, we will post the changes to this Privacy Policy, as an update alert on our Website, by sending you an e-mail update, and/or any other places we deem appropriate so that you can be made aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

15. QUESTIONS

If you have questions about this Privacy Policy, please contact us at hello@oonacares.com