WHEREAS Reflective Insights Limited respects its user’s privacy.

WHEREAS this Privacy Policy summarizes what personal information and/or personal health information we collect, how we use and disclose this information, and how you can get in touch with us to correct any issues or inaccuracies in the information we collect. It applies only to information collected by Reflective Insights Limited, its website www.reflectiveinsights.ca, and any affiliated third-party websites and applications including but not limited to social media accounts.

WHEREAS by engaging with Reflective Insights Limited and using its website www.reflectiveinsights.ca, and any affiliated third-party websites and applications including but not limited to social media accounts, you signify your consent to the terms of our Privacy Policy contained herein. If you do not agree with any terms of this Privacy Policy, please do not use this Site or submit any personal information and/or personal health information to us.

WHEREAS we reserve the right to modify or make changes to this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on our Site. It is your responsibility to ensure your consent to this Privacy Policy is ongoing and informed. Please visit the Site frequently to ensure you inform yourself of the terms herein because your continued use of the Site after any such changes constitutes your acceptance of this Privacy Policy, as revised.

LAST UPDATED: June 1, 2025

 Reflective Insights Limited (hereinafter the “Company”, “We”, and/or “Us”) collects its user’s (hereinafter “Your” and/or “You”) Personal Information and/or Personal Health Information when You voluntarily choose to provide it to the Company, its website www.reflectiveinsights.ca, and any affiliated third-party websites and applications including but not limited to social media accounts (the “Site”), or when You provide it to Us through other means.

1.  Information We Collect

We “Reflective Insights Limited” may collect the following types of information:

1. Personal Information voluntarily submitted (Personal information is information about an identifiable individual (“Personal Information”):

• Name
  
  
• Email address
  
  
• Phone number
  
  
• Information shared via contact forms or during consultation bookings

1. Personal Health Information (for therapy clients):
   If you become a client, additional personal health information will be collected during intake and sessions. This information is stored securely in accordance with Canadian privacy laws in the JaneApp.

2.  How We Collect Your Information

We may collect Personal Information and/or Personal Health Information when You:

• Contact Us through email, telephone, mail, or other correspondence
• Register for a service We provide
• Register to receive a free resource from Us
• Register to receive our newsletter
• Complete our intake forms prior to therapy sessions
• Provide information during therapy sessions
• Book appointments through our online scheduling system including free 15-minute appointments
• Submit information through contact forms on our website
• Participate in surveys or feedback requests
• Sign up for workshops or events we host

Website Usage Data:
Basic analytics (e.g., pages visited, browser type) may be collected via cookies or third-party services like Google Analytics. While this data is pseudonymized, it may be considered personal information and/or personal health information under PIPEDA. We use this data to improve our site’s performance and user experience.

3.  How We Use Your Information

Purpose of Use

The Personal Information and Personal Health Information We collect may be used by Us for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to You at the time of Your providing that information to Us and to which You consent. We will not use your personal information and/or personal health information for any other purposes without obtaining your additional consent, except as required by law.

4.  Consent

By providing your information through this website or engaging in therapy, you consent to its collection and use as outlined here. We will obtain your express consent before collecting, using, or disclosing your personal information and/or personal health information for any purpose not described in this policy. You may withdraw your consent for non-therapeutic communications at any time by contacting us, though this may affect our ability to provide certain services.

You are always in control of Your Personal Information and/or Personal Health Information. It is Your decision whether to disclose Personal Information and/or Personal Health Information to Us, however, if You choose not to provide Us with Your Personal Information and/or Personal Health Information, We reserve the right to refuse to provide You with any products or services provided by Us.

5.  Record Keeping and Storage

Client records are stored securely in JaneApp, a Canadian-based, privacy-compliant platform that maintains servers exclusively in Canada. We have a signed Business Associate Agreement with JaneApp ensuring compliance with PHIPA and PIPEDA requirements for health information storage and processing.

Data Retention and Destruction

We retain Personal Information and/or Personal Health Information that We collect only as long as necessary for the purposes for which it was collected, to meet legal requirements, to demonstrate that We have met any obligations which may be owing to You pursuant to contract, but not common law, to preserve our rights for any claims which might be made against Us pursuant to any legal limitations periods prescribed by law. We destroy Personal Information and/or Personal Health Information when it is no longer needed.

When personal information and/or personal health information is no longer required for its intended purposes or to meet legal obligations, we will securely destroy, delete, or anonymize it using industry-standard methods appropriate to the medium on which it is stored. For physical records, this includes secure shredding or incineration. For digital records, we use secure deletion methods that prevent recovery of the information.

• Records are retained for at least 10 years after the end of service (or 10 years after the client turns 18 for minors).
  
  
• Paper notes (if used) are securely shredded after being transferred to the digital file.
  
  
• Only the therapist has access to your full client file unless release of information is legally required or explicitly authorized by you.

6.  Confidentiality and Disclosure

Any information you share with your registered nurse psychotherapist is private and confidential. We respect your confidentiality and will not release information without your written consent. There are some limits to confidentiality, and in these circumstances, your therapist can share confidential information that you have provided, without your consent. Registered Nurse Psychotherapists are required ethically and by law to release information (and do not require your consent) when:

• The client poses a risk of seriously harming themselves or someone else.
• There is suspected abuse or neglect of a child or vulnerable adult.
• A regulated health professional is behaving in a way that endangers others.
• We received a subpoena or court-ordered to provide information. We may be required to release some information. In such a case, we will consult with other professionals and limit the release to only what is necessary by law.
• There is a medical emergency that arises during our session where urgent disclosure of your information to medical professionals is required for your immediate safety.
• Your therapist is engaged in receiving “supervision”, where peer to peer consultation with a senior therapist occurs and during these conversations, details of counseling including documentation will be shared respectfully and in compliance with all College of Nurses regulations. This supervision process is important for therapists to receive feedback and provide the best possible service to their clients. We will provide details of supervision we are engaged in, if applicable, related to your treatment upon your request.

Additionally, we may consult with another psychotherapist (without using identifying information) to support your care.

All personal information and/or personal health information collected in the course of our work will be managed in compliance with Ontario’s Personal Health Information Protection Act (PHIPA). Information will only be collected, used, and disclosed as permitted by law.

7.  Email and Digital Communication

If you contact Reflective Insights Limited by email, please note:

• Emails are only checked twice per week.
  
  
• Email is not suitable for crisis communication.
  
  
• We use industry-standard encryption and secure platforms for digital communications, but no digital communication is 100% secure. For sensitive health information, we recommend using our secure client portal through JaneApp rather than email.

8.  Third-Party Websites & Cookies

Third-Party Websites and Applications

We also actively use various third-party websites and applications, such as Instagram, Facebook, LinkedIn, Google Analytics, JaneApp, and Stripe. These may collect your IP address and require cookies to work properly. These services are governed by the privacy policies of the third-party providers and are not within our control or scope. We encourage you to review the privacy policies of these third-party services for more information on how they collect, use, and protect your data.

Cookie Information

This website may use cookies to gather limited, non-personal data to enhance your experience. You can adjust your browser settings to disable cookies at any time.

 

Our website uses cookies and similar tracking technologies to collect information about your browsing behavior. This information helps us improve our website functionality and provide a better user experience. The information collected through cookies includes your IP address, browser type, operating system, and the pages you visit.

If you choose to disable cookies through your browser settings, please be aware that some features of our website may not function properly. This could limit your ability to use certain interactive elements, save preferences, or access personalized content.

9.  Your Rights

You have the right to:

• Request access to your records
  
  
• Correct any inaccuracies in your file
• Withdraw consent for communication outside of therapy
• Request a copy of your records (in writing with a signed release form)

10.      Opt-Out Rights and Data Deletion

You also have a right to opt-out of any future communications from the Company and ask Us to delete any data We have about You. You can do this by contacting Us using the contact information provided below.

To exercise your opt-out or data deletion rights, please:

• Email Us at contact@reflectiveinsights.ca with the subject line “Opt-Out/Data Deletion Request”
• Submit your request through the secure form on our website

Upon receiving your request, We will confirm receipt within 3 business days and process your request within 30 days. Please note that certain records may need to be retained for legal, professional, or regulatory requirements (such as health records that must be maintained for 10 years). We will clearly explain any limitations on data deletion in our response to your request.

For communications opt-out, please specify which types of communications you wish to stop receiving (e.g., newsletters, appointment reminders, educational materials, or all communications). Opting out of communications will not affect your ability to receive essential service-related messages regarding your care or account.

11.      Security

We implement comprehensive security safeguards to protect your information, including:

• Technical measures: encryption, password-protected devices, secure platforms.
• Physical measures: locked filing systems, controlled access to offices.
• Administrative measures: staff privacy training, confidentiality agreements, and regular security audits.

All measures comply with PIPEDA and PHIPA requirements for personal information and personal health information protection.

12.      California Residents’ Rights

If You are a California resident, You have the right to request information from the Company regarding the manner in which We use and/or store Your personally identifiable information and share Your information with third parties. You may contact Us at the following email address: contact@reflectiveinsights.ca.

13.      Liability Limitation

While We do have a legitimate interest in taking precaution to protect Your Personal Information and/or Personal Health Information and other information provided to Us by You, and shall take all reasonable precautions to protect Your information against unauthorized access, unlawful processing, accidental loss or misrepresentation, destruction or damages, You hereby accept and agree that We do not guarantee Your transmission of information and Personal Information and/or Personal Health Information using electronic means to Us is without risk, and You hereby release the Company from any potential liability resulting from, and indemnify the Company for, any damages that arise as a result of any unlawful processing, accidental loss, destruction and damage of Your information. In the event that We become aware of a breach, You will be notified via email.

14.      Changes to this Policy

This Privacy Policy may be updated to reflect changes in legislation or services. We will notify active clients of material changes to this policy via email or secure message. All changes will be posted on this page with a revised effective date and continued use of our services after such changes constitutes acceptance of the updated policy.

15.      GDPR Data Controller Information

The data controller responsible for Your personal information and/or personal health information for the purposes of General Data Protection Regulation (“GDPR”) compliance is:

Reflective Insights Limited
Email: contact@reflectiveinsights.ca
Address:
PO BOX 99900 – LJ 722 747
RPO Wonderland Rd. South
London, ON N6K 0E6

As the data controller, we determine the purposes and means of processing your personal data. We are responsible for responding to data subject requests, ensuring lawful processing of your data, and implementing appropriate technical and organizational measures to protect your information. You may contact us at the details above to exercise your rights under GDPR, including the right to access, rectify, erase, restrict processing, data portability, and object to processing.

16.      Ownership of Information

We warrant that We are and shall remain the sole owners of the information collected on the Site, including Your Personal Information and/or Personal Health Information, however, We reserve the right to transfer Personal Information and/or Personal Health Information in the event that We merge with or are acquired by a third party. We also may disclose Your Personal Information and/or Personal Health Information for any other purpose permitted by law or to which You consent. We shall not sell or rent your information, including Personal Information and/or Personal Health Information, to any third parties.

17.      Cross-Border Data Transfers

Some or all of the Personal Information and/or Personal Health Information We collect may be stored or processed in jurisdictions outside of Canada, including in the United States of America. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

18.      Contact Us

For any questions or requests regarding your privacy or records, contact at contact@reflectiveinsights.ca.