FollowUp Solutions Inc. (“FollowUp Solutions,” “we,” “us,” or “our”) is committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website, platform, and services. We comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Personal Health Information Protection Act (“PHIPA”), or any other applicable provincial, territorial, or federal privacy legislation, and all other applicable privacy laws and guidelines from Canadian privacy regulators.

By using our website at https://followu.ca,  our platform, or any of our services, you agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy (“Policy”). This Policy is part of, and subject to, our Terms of Service.

1. Scope

This Policy applies to all personal information we collect from individuals who register for or use our free wellness and mental health services (“Users”). Users may choose to share information collected from one Provider with another Provider through the Platform, subject to their express consent.

It also applies to:

• Website Users – anyone who visits or interacts with our website or platform.
• Other Individuals – anyone who contacts us or provides information in connection with our services.

This Policy covers information collected through our website, platform, by phone, by email, and during in-person or virtual sessions.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• “FollowUp Solutions Services” means the range of wellness, mental health, and support services offered by FollowUp Solutions via its Platform, including wellness sessions, assessments, educational resources, and related digital tools.
• “Personal information” means any information about an identifiable individual, including “personal health information” (e.g., medical history or treatment details) collected during wellness sessions. It does not include information that has been anonymized or aggregated so that it cannot identify you.
• “Platform” means the online platform provided by FollowUp Solutions for delivering the FollowUp Solutions Services.
• “Providers” refers to licensed or certified professionals, such as therapists, counsellors, coaches, or other wellness practitioners, who are engaged by FollowUp Solutions to provide support, guidance, or therapeutic services to users through the Platform. Some Providers may be health information custodians under PHIPA or any other applicable provincial, territorial, or federal privacy legislation (“Personal Health Privacy Legislation”) and are responsible for complying with their legal obligations under Personal Health Privacy Legislation.
• “Session” means any live or asynchronous interaction, including messaging, audio, or video, conducted through the Platform between a User and a Provider.

3. Information We Collect

We collect only the information necessary to provide the FollowUp Solutions Services, operate our business, and comply with legal obligations.

3.1. Personal Information

• Registration Information: Name, email address, username, and password when you create an account.
• Service Information: Information you provide during wellness sessions, including health history, health status, medical records, session notes, and other health-related information (“Session Information”). Session notes and records may be stored on the Platform and, with your express consent, shared with other Providers you select.
• Payment Information: Credit card details, billing address, and bank account information for payment processing.
• Communications: Information you provide when you contact us for support, submit inquiries, or participate in surveys.
• Technical Support and Service Requests: Records of your interactions with our support team.
• Other Information: Any additional information you choose to provide to us.

3.2. Non-Personally Identifiable Information (“NPI”)

We collect NPI such as device information, IP address, browser type, operating system, usage data, and location data (if you enable location services). NPI is used to improve our services and cannot be used to identify you.

4. How We Collect Information

We collect information:

• Directly from you when you register, use our services, or communicate with us.
• Automatically through cookies and similar technologies when you use our website or the Platform.
• From third-party service providers (such as payment processors) as needed to deliver our services.

5. Purposes for Collection, Use, and Disclosure

We use your personal information for purposes that a reasonable person would consider appropriate in the context of our services, including:

• To provide, manage, and improve the FollowUp Solutions Services, including Wellness Sessions conducted by our Specialists.
• To establish and maintain our relationship with you.
• To process payments and manage billing.
• To communicate with you about your account, services, and updates.
• To respond to your inquiries and provide customer support.
• To understand your needs and preferences.
• To enforce our Terms of Service and comply with legal and regulatory requirements.
• To prevent, detect, and address fraud or security issues.
• To conduct research and analysis (using de-identified or aggregated data).
• For any other purpose for which you provide consent.

6. Consent

We obtain your consent for the collection, use, and disclosure of your personal information, except where otherwise permitted or required by law. Consent may be express (written, verbal, or electronic) or implied (for example, by providing information to access our services). You may withdraw your consent at any time, subject to legal or contractual restrictions. If you withdraw consent, we will explain any impact on your ability to use our services.

If you wish to share information collected from one Provider with another Provider through the Platform, we will obtain your express consent before facilitating such sharing. 

7. Compliance

FollowUp Solutions complies with Personal Health Privacy Legislation and acts as an agent of health information custodians (Providers) when processing personal health information on their behalf. Providers who are health information custodians are responsible for complying with their obligations under Personal Health Privacy Legislation, including the collection, use, and disclosure of personal health information.

8. Limiting Collection, Use, Disclosure, and Retention

We limit the collection of personal information to what is necessary for the purposes identified in this Policy. We do not use or disclose your information for purposes other than those for which it was collected, except with your consent or as required by law. We retain personal information only as long as necessary to fulfill the identified purposes or as required by law. When information is no longer needed, we securely delete or anonymize it.

Personal health information will be retained in accordance with the requirements of Personal Health Privacy Legislation and any applicable professional standards. If you request deletion of your information, we will coordinate with the relevant Provider to determine whether retention is required by law or professional obligations.