PRIVACY POLICY

Virtual Health Coaching Services

Last Updated: January 6, 2026

1. INTRODUCTION

Aloka Holistic Health Coaching ("Company," "we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our virtual health coaching services.

We are a business based in Quebec, Canada, and this policy complies with applicable privacy legislation, including:

The Act respecting the protection of personal information in the private sector, as amended by Law 25
The Personal Information Protection and Electronic Documents Act (PIPEDA)
Canada's Anti-Spam Legislation (CASL)

2. PERSON RESPONSIBLE FOR PERSONAL INFORMATION

In accordance with Quebec's privacy laws, we have designated a person responsible for the protection of personal information within our organization:

Privacy Officer

Alexandra Oliverio

Aloka Holistic Health Coaching

alexandra@alokasante.com

3. PERSONAL INFORMATION WE COLLECT

3.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including:

Identity Information: name, date of birth, gender
Contact Information: email address, phone number, mailing address
Payment Information: credit card details, billing address (processed through secure third-party payment processors)
Health-Related Information: health goals, lifestyle habits, dietary preferences, fitness levels, wellness concerns, general health information, medical and family history, and other information you choose to share during coaching sessions
Communication Records: emails, chat messages, session notes, and feedback you provide

3.2 Information Collected Automatically

When you access our website or use our services, we automatically collect certain information:

Technical Data: IP address, browser type and version, operating system, device information
Usage Data: pages visited, time spent on pages, click patterns, referring website
Cookie Data: Please see our separate Cookie Policy for details on how we use cookies and similar technologies

4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes:

4.1 Service Delivery

To provide, personalize, and improve our virtual health coaching services
To schedule and conduct coaching sessions
To create and maintain your account
To process payments and send invoices

4.2 Communication

To respond to your inquiries and provide customer support
To send appointment reminders and service-related notifications
To send promotional communications (with your consent)

4.3 Business Operations

To analyze usage patterns and improve our services
To ensure the security and integrity of our systems
To comply with legal obligations

5. LEGAL BASIS FOR PROCESSING

Under Quebec and Canadian privacy law, we process your personal information based on:

Consent: For health-related information, marketing communications, and cookies
Contract Performance: To provide the services you have requested
Legal Obligation: To comply with applicable laws and regulations
Legitimate Interest: For business operations, security, and service improvement, where such interests are not overridden by your rights

6. CONSENT

6.1 Express Consent

We obtain your express consent before collecting or using sensitive personal information, including health-related information. You provide this consent when you sign up for our services and complete our intake forms.

Your health-related information is used exclusively to provide your coaching services and is never shared with third parties without your explicit written consent, except where required by law or to prevent imminent harm.

6.2 Withdrawal of Consent

You may withdraw your consent at any time by contacting our Privacy Officer. Please note that withdrawing consent may affect our ability to provide certain services to you. We will inform you of any consequences of withdrawal upon request.

7. DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information with:

7.1 Service Providers

Payment processors for transaction handling
Video conferencing platforms for session delivery
Cloud storage providers for data hosting
Email service providers for communications

7.2 Legal Requirements

We may disclose your information when required by law, court order, or government request, or when necessary to protect our rights, safety, or property, or those of others.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections.

We do not sell your personal information to third parties.

8. TRANSFERS OUTSIDE QUEBEC

Some of our service providers may be located outside Quebec or Canada. When we transfer personal information outside Quebec, we ensure that appropriate safeguards are in place to protect your information.

9. DATA RETENTION

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Our retention periods are:

Account Information: 5 years from the date of the last session
Session Records: 5 years from the date of the last session
Payment Records: 7 years for tax and accounting purposes
Marketing Preferences: Until you withdraw consent or request deletion

10. YOUR RIGHTS

Under Quebec's privacy legislation, you have the following rights:

Right of Access: You may request access to the personal information we hold about you
Right to Rectification: You may request correction of inaccurate or incomplete information
Right to Deletion: You may request deletion of your personal information, subject to legal retention requirements
Right to Data Portability: You may request a copy of your information in a structured, commonly used format
Right to Withdraw Consent: You may withdraw consent for processing at any time
Right to De-indexation: You may request that links to your information be de-indexed from search results

To exercise any of these rights, please contact our Privacy Officer. We will respond to your request within 30 days. If we cannot fulfill your request, we will provide reasons in writing.

11. SECURITY MEASURES

We implement appropriate technical and organizational measures to protect your personal information, including:

Encryption of data in transit and at rest
Secure access controls and authentication
Regular security assessments and updates
Employee training on data protection
Confidentiality agreements with staff and service providers

12. CONFIDENTIALITY INCIDENT RESPONSE

In the event of a confidentiality incident (data breach) involving your personal information that presents a risk of serious injury, we will promptly notify you and the Commission d'accès à l'information du Québec, as required by law. We maintain an incident register as required under Quebec's privacy legislation.

13. CHILDREN'S PRIVACY

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be communicated to you by email or through a notice on our website at least 30 days before they take effect. The "Last Updated" date at the top of this policy indicates when it was last revised.

15. COMPLAINTS

If you have concerns about our handling of your personal information, please contact our Privacy Officer first. If you are not satisfied with our response, you have the right to file a complaint with:

Commission d'accès à l'information du Québec

525, boul. René-Lévesque Est, bureau 2.36

Québec (Québec) G1R 5S9

Phone: 1-888-528-7741

Website: www.cai.gouv.qc.ca

16. CONTACT US

For questions about this Privacy Policy or our privacy practices, please contact:

Aloka Holistic Health Coaching

Attention: Privacy Officer

Email: alexandra@alokasante.com

17. LANGUAGE

This Privacy Policy is available in both English and French. In the event of any discrepancy between the two versions, the French version shall prevail in accordance with the Charter of the French Language.

Cette politique de confidentialité est disponible en français et en anglais. En cas de divergence entre les deux versions, la version française prévaudra conformément à la Charte de la langue française.