1. INTRODUCTION
elunel ("we," "us," "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform, in compliance with:
- Personal Information Protection and Electronic Documents Act (PIPEDA)
- Ontario's Personal Health Information Protection Act (PHIPA) where applicable
- Other applicable Canadian federal and provincial privacy laws
2. HEALTH INFORMATION NOTICE
IMPORTANT: While elunel is a technology platform and not a health information custodian under PHIPA, some communications between clients and birth professionals may contain personal health information.
Birth professionals who are regulated health professionals or health information custodians are independently responsible for complying with PHIPA and other applicable health privacy laws. elunel does not control or direct how birth professionals handle health information.
3. INFORMATION WE COLLECT
3.1 Information You Provide
- Account Information: Name, email address, password, user type (client or birth professional)
- Profile Information: Display name, location, bio, services offered, photos, availability status
- Communication Data: Messages sent through our messaging system
- User Content: Any other information you choose to provide
3.2 Information Collected Automatically
- Usage Data: Pages viewed, features used, time spent on Platform
- Device Information: IP address, browser type, device type, operating system
- Cookies and Tracking: We use cookies and similar technologies (see Section 8)
4. HOW WE USE YOUR INFORMATION
We use collected information for the following purposes:
- To provide, maintain, and improve the Platform
- To create and manage your account
- To facilitate communication between clients and birth professionals
- To display birth professional profiles to clients
- To send administrative communications (account updates, security alerts)
- To respond to your inquiries and provide customer support
- To monitor and analyze Platform usage and trends
- To detect, prevent, and address fraud, security issues, and violations of our Terms
- To comply with legal obligations
5. DISCLOSURE OF YOUR INFORMATION
We may share your information in the following circumstances:
5.1 Public Profile Information
If you are a birth professional, your profile information (name, location, bio, services, photo, availability) is publicly visible to all Platform users.
5.2 Between Users
When you send messages through our Platform, the content is shared with the intended recipient.
5.3 Service Providers
We may share information with third-party service providers who perform services on our behalf (hosting, analytics, customer support), subject to confidentiality agreements.
5.4 Legal Requirements
We may disclose information if required by law, court order, or governmental regulation, or if necessary to protect our rights, safety, or property.
5.5 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred, subject to the same privacy protections.
6. YOUR PRIVACY RIGHTS
Under Canadian privacy laws, you have the right to:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete information
- Withdrawal of Consent: Withdraw consent for certain uses of your information (may limit Platform functionality)
- Deletion: Request deletion of your account and associated information, subject to legal retention requirements
- Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada
To exercise these rights, please contact us at [Insert Contact Email].
7. DATA SECURITY
We implement reasonable administrative, technical, and physical security measures to protect your information from unauthorised access, use, or disclosure. However, no internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security.
Security measures include:
- Encryption of data in transit and at rest
- Access controls and authentication requirements
- Regular security assessments and updates
- Employee training on privacy and security
8. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar technologies to:
- Maintain your login session
- Remember your preferences
- Analyse Platform usage and performance
- Improve user experience
You can control cookies through your browser settings, but disabling cookies may limit Platform functionality.
9. DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When information is no longer needed, we will securely delete or anonymise it.
Typical retention periods:
- Active accounts: Duration of account plus [X] years
- Closed accounts: [X] years after closure for legal compliance
- Messages: [X] years after account closure
10. CHILDREN'S PRIVACY
The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete it promptly.
11. THIRD-PARTY LINKS
The Platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.
12. INTERNATIONAL DATA TRANSFERS
Your information may be processed and stored on servers located outside of Canada. When we transfer information internationally, we ensure adequate safeguards are in place as required by Canadian privacy laws.
13. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform or via email. Your continued use after changes constitutes acceptance of the updated Privacy Policy.
14. CONTACT INFORMATION
For questions, concerns, or to exercise your privacy rights, please contact:
Privacy Officer
elunel
[Insert Business Address]
Ontario, Canada
Email: [Insert Privacy Email]
You also have the right to file a complaint with:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca
