PRIVACY POLICY
Embolden Mental Health & Psychotherapy
Effective Date: February 17, 2026
Last Updated: February 17, 2026
Website: www.emboldenmentalhealth.com
1. INTRODUCTION
Welcome to Embolden Mental Health & Psychotherapy ("Embolden," "we," "us," or "our"). We are committed to protecting the privacy and confidentiality of your personal information, including your personal health information ("PHI"). We understand that privacy is especially important when seeking mental health support, and we take this responsibility seriously.
This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information and personal health information through our website (www.emboldenmentalhealth.com), our therapy services, and all related communications. This policy applies to all individuals who visit our website, contact us, or receive therapy services from Embolden Mental Health & Psychotherapy.
Embolden Mental Health & Psychotherapy is located in Courtice, Ontario, and provides virtual psychotherapy services throughout the Province of Ontario. As a provider of health care services in Ontario, we operate as a Health Information Custodian under Ontario's Personal Health Information Protection Act, 2004 ("PHIPA"). We also comply with the Personal Information Protection and Electronic Documents Act ("PIPEDA"), Canada's federal privacy law, where applicable.
By using our website, contacting us, or receiving our services, you acknowledge that you have read and understood this Privacy Policy.
2. WHO WE ARE
Practice Name: Embolden Mental Health & Psychotherapy
Clinic Director: Ashley Latendresse, Registered Psychotherapist
Location: Serving Courtice and all of Ontario virtually
Email: info@emboldenmentalhealth.com
Website: www.emboldenmentalhealth.com
Regulatory Body: College of Registered Psychotherapists of Ontario (CRPO)
For privacy-related questions or concerns, please contact our Privacy Officer:
Privacy Officer: Ashley Latendresse
Email: info@emboldenmentalhealth.com
You may also contact the Information and Privacy Commissioner of Ontario:
Toronto Area: 416-326-3333
Long Distance: 1-800-387-0073
Email: commissioner@ipc.on.ca
3. PERSONAL INFORMATION WE COLLECT
We collect and maintain various types of personal information and personal health information in order to provide our services. The categories of information we may collect include:
Identifying Information: Your name, date of birth, gender, pronouns, and other identifying details.
Contact Information: Your email address, phone number, and mailing address.
Health Information: Information about your physical and mental health, medical history, treatment plans, therapy session notes, clinical assessments, diagnoses, and other health-related information provided by you or generated during the course of your treatment.
Appointment Information: Details about your scheduled appointments, session history, cancellations, and rescheduling.
Payment and Billing Information: Credit card or other payment details, insurance information, receipts, and billing records.
Emergency Contact Information: The name and contact details of your designated emergency contact.
Communications: Emails, phone call records, voicemails, contact form submissions, and other messages exchanged between you and our practice.
Consent and Intake Forms: Completed intake forms, informed consent documents, and any other forms you submit to us.
Website Usage Information: Information about how you use our website, including your IP address, browser type, pages visited, time spent on pages, and other analytics data collected through cookies and similar technologies.
Newsletter Information: Your first name and email address if you subscribe to our newsletter.
Referral Information: If you were referred to us, details about the referral source, with your consent.
4. HOW WE COLLECT YOUR INFORMATION
We collect personal information and personal health information through the following methods:
Directly From You: When you fill out intake forms, consent forms, contact forms on our website, or provide information during therapy sessions (including virtual sessions), phone calls, and email communications.
Through Our Website: When you visit our website, submit a contact form, subscribe to our newsletter, or book a consultation through our website.
Through Jane App (Electronic Medical Records): We use Jane App as our electronic medical records (EMR) and practice management platform. When you book appointments, complete intake forms, attend virtual sessions, or make payments through Jane App, your information is collected and stored securely within this system. Jane App is compliant with PHIPA and PIPEDA. For more information on Jane App's privacy practices, please see Jane App's Privacy Policy at jane.app/privacy-policy.
Through Virtual Therapy Sessions: When you attend online therapy sessions through our secure telehealth platform (Jane App's Online Appointments feature), which uses end-to-end encrypted video connections.
Through Third-Party Referrals: With your consent, from other healthcare providers, professionals, or referral sources.
Through Cookies and Analytics Tools: Through technologies embedded in our website that collect usage data (see Section 12: Cookies and Tracking Technologies for details).
5. WHY WE COLLECT YOUR INFORMATION AND HOW WE USE IT
We collect, use, and disclose your personal information and personal health information for the following purposes:
Providing Therapy Services: To deliver psychotherapy, counselling, and related mental health services, including conducting assessments, developing treatment plans, providing therapy sessions, and tracking treatment progress.
Appointment Management: To schedule, confirm, reschedule, and manage your appointments, and to send you appointment reminders via email or text.
Communication: To respond to your inquiries, contact form submissions, phone calls, and emails, and to communicate with you about your care.
Billing and Payment Processing: To process payments, issue receipts, and manage your account and billing records.
Intake and Consent: To collect and manage the forms necessary to begin and continue your treatment.
Continuity of Care: To share information, with your express consent, with other healthcare providers involved in your care for the purpose of providing or assisting in providing health care to you.
Legal and Regulatory Compliance: To comply with applicable laws, regulations, and professional obligations, including those imposed by the College of Registered Psychotherapists of Ontario (CRPO), PHIPA, PIPEDA, and other relevant legislation.
Quality Improvement: To improve the quality of our services, website, and client experience.
Newsletter and Marketing: If you subscribe to our newsletter, to send you mental health insights, practical strategies, and updates about our services. You can unsubscribe at any time.
Website Analytics: To understand how visitors use our website so we can improve its content and functionality.
Safety: To prevent or address a risk of serious harm to your health or safety, or the health or safety of others, as permitted or required by law.
6. WHO WE SHARE YOUR INFORMATION WITH
We respect the confidentiality of your personal information and personal health information. We do not sell, trade, or rent your information to third parties. We may share your information only in the following circumstances:
Jane App (EMR and Practice Management): Your personal information and personal health information are stored in Jane App, which acts as our electronic medical records provider and practice management platform. Jane App is a service provider and agent acting on our behalf. Jane App is PHIPA and PIPEDA compliant and does not use your information for its own purposes. Jane App stores data securely on servers located in Canada.
Payment Processors: Your payment information is processed by secure, third-party payment processors integrated with Jane App. We do not store your full credit card information on our own systems.
Other Healthcare Providers: With your express consent, we may share your personal health information with other healthcare providers involved in your care, such as physicians, psychiatrists, or other therapists, for the purpose of providing or assisting in providing health care to you.
Professional Supervisors and Consultants: In some cases, our therapists may consult with clinical supervisors or colleagues for professional development and quality of care purposes. In these instances, your identifying information is removed or kept to a minimum, and confidentiality is maintained.
Website Hosting and Analytics Providers: Our website is hosted by a third-party platform provider. We also use analytics tools that collect anonymous or aggregated website usage data (see Section 12).
UserWay (Accessibility Widget): We use the Accessibility by UserWay widget on our website (see Section 13). UserWay does not collect personal information from users interacting with the widget.
Newsletter Service Provider: If you subscribe to our newsletter, your first name and email address are stored by our newsletter service provider for the sole purpose of delivering newsletters to you.
Legal Requirements: We may disclose your personal information or personal health information without your consent where required or permitted by law, including:
- To comply with a court order, subpoena, or other legal process.
- To report suspected child abuse or neglect, as required under the Child, Youth and Family Services Act, 2017.
- To eliminate or reduce a significant risk of serious bodily harm to you or another person.
- To comply with reporting obligations under the Regulated Health Professions Act, 1991 or the Psychotherapy Act, 2007.
- To respond to a request from the Information and Privacy Commissioner of Ontario.
- As otherwise required or permitted by PHIPA, PIPEDA, or other applicable legislation.
7. DATA RETENTION
We retain your personal information and personal health information in accordance with applicable laws, professional standards, and regulatory requirements.
Clinical Records: Under Ontario law and the standards set by the College of Registered Psychotherapists of Ontario (CRPO), clinical records for adult clients are retained for a minimum of 10 years following the date of the last entry in the record, or 10 years after the client reaches the age of 18, whichever is later. After the applicable retention period has expired, records are securely destroyed.
Billing and Financial Records: Billing and financial records are retained for a minimum of 7 years as required by the Canada Revenue Agency for tax and financial reporting purposes.
Website and Analytics Data: Anonymous website usage data collected through cookies and analytics tools is retained for the period specified by the applicable analytics provider and is used solely for website improvement purposes.
Newsletter Subscriber Data: If you subscribe to our newsletter, your name and email are retained until you unsubscribe or request their deletion.
Contact Form Submissions: Information submitted through our website contact form is retained for as long as necessary to respond to your inquiry and for any follow-up communication.
When personal information or personal health information is no longer required for the purposes for which it was collected, or once the applicable retention period has expired, we will securely destroy, erase, or anonymize the information using methods appropriate to the sensitivity of the information (such as secure shredding for paper records and permanent deletion for electronic records).
8. HOW WE PROTECT YOUR INFORMATION
We are committed to protecting your personal information and personal health information using appropriate security safeguards. The measures we have in place include:
Secure Electronic Medical Records: We use Jane App, a PHIPA-compliant and PIPEDA-compliant EMR system, which employs encryption for data in transit and at rest, secure data storage on Canadian servers, access controls, and regular security monitoring.
Encrypted Virtual Sessions: All virtual therapy sessions conducted through Jane App use end-to-end encrypted video connections, ensuring that your sessions remain private between you and your therapist.
Access Controls: Access to your personal information and personal health information is restricted to authorized staff and therapists who require access in order to provide your care or manage your account. Each authorized user has unique login credentials, and access levels are assigned based on role.
Password Protection and Authentication: All systems containing personal information or personal health information are protected by strong passwords and, where available, multi-factor authentication.
Staff Training: All therapists and staff at Embolden Mental Health & Psychotherapy are trained on their obligations regarding privacy, confidentiality, and the secure handling of personal information and personal health information in accordance with PHIPA, PIPEDA, and professional standards.
Secure Communications: We encourage clients to communicate sensitive information through secure means. Please be aware that standard email is not fully secure, and we recommend using the Jane App client portal for sensitive communications where possible.
Physical Safeguards: Any paper records containing personal information or personal health information are stored in locked, secure locations with access restricted to authorized personnel.
Despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. In the event of a data breach, we will follow the breach notification procedures outlined in Section 9.
9. DATA BREACH NOTIFICATION
In the event of a breach of security safeguards involving your personal information or personal health information, we will take the following steps:
Containment and Assessment: We will immediately take steps to contain the breach and assess the scope and impact of the incident, including what information was affected and who may be impacted.
Notification to Affected Individuals: If the breach creates a real risk of significant harm to you, we will notify you as soon as reasonably possible. Notification will include a description of the breach, the type of information involved, the steps we have taken to address the breach, and what you can do to protect yourself.
Notification to the Information and Privacy Commissioner of Ontario: Where required by PHIPA or other applicable legislation, we will report the breach to the Information and Privacy Commissioner of Ontario.
Notification to the Privacy Commissioner of Canada: Where required by PIPEDA, we will report the breach to the Office of the Privacy Commissioner of Canada.
Notification to Professional Regulatory Bodies: Where applicable, we will notify the College of Registered Psychotherapists of Ontario (CRPO) or other relevant regulatory bodies as required.
Remediation: We will take appropriate steps to prevent similar breaches from occurring in the future, including reviewing and updating our security measures and procedures.
10. YOUR RIGHTS
Under PHIPA and PIPEDA, you have the following rights regarding your personal information and personal health information:
Right of Access: You have the right to request access to the personal health information we hold about you. We will respond to your request within 30 days. Access requests can be made orally or in writing to our Privacy Officer at info@emboldenmentalhealth.com.
Right to Correction: If you believe that the personal health information we hold about you is inaccurate or incomplete, you have the right to request a correction. If we agree that a correction is warranted, we will make the correction and notify any third parties to whom the information has been disclosed. If we do not agree that a correction is warranted, we will attach a statement of disagreement to your record.
Right to Withdraw Consent: You have the right to withdraw your consent for the collection, use, or disclosure of your personal information or personal health information at any time, subject to legal or contractual restrictions and reasonable notice. Please note that withdrawing consent may affect our ability to provide you with certain services. Withdrawal of consent does not apply retroactively.
Right to Complaint: You have the right to make a complaint about our privacy practices. Complaints can be directed to our Privacy Officer at info@emboldenmentalhealth.com. If you are not satisfied with our response, you may also file a complaint with the Information and Privacy Commissioner of Ontario or the Office of the Privacy Commissioner of Canada.
Right to Be Informed: You have the right to be informed about our privacy practices, including how we collect, use, disclose, and protect your personal information and personal health information. This Privacy Policy is part of our commitment to transparency.
Limitations on Access: There are limited circumstances in which we may refuse or limit access to your personal health information, as permitted under PHIPA. These include situations where providing access could reasonably be expected to:
- Result in a risk of serious harm to your health or safety, or the health or safety of another person.
- Lead to the identification of a third party who provided information in confidence.
- Reveal information that is subject to legal privilege.
If we refuse or limit access, we will provide you with written reasons for the refusal and inform you of your right to make a complaint to the Information and Privacy Commissioner of Ontario.
To exercise any of your rights, please contact our Privacy Officer:
Email: info@emboldenmentalhealth.com
We will respond to all requests in accordance with the timelines and procedures required by applicable law.
11. CONSENT
Under PHIPA, we require your consent in order to collect, use, and disclose your personal health information. Consent may be express or implied, depending on the circumstances:
Express Consent: We obtain your express consent (written or verbal) when we collect your personal health information for the first time, typically through our intake and consent forms completed via Jane App. Express consent is also required when disclosing your personal health information to third parties not directly involved in your care (such as an insurance company, lawyer, employer, or family member).
Implied Consent: In some cases, consent may be implied. For example, when you provide personal health information to your therapist during a session for the purpose of receiving treatment, your consent to the collection and use of that information for treatment purposes may be implied.
Consent for Minors: If a client is under the age of 16, consent may be provided by a parent or legal guardian, in accordance with PHIPA.
You may withdraw your consent at any time by contacting our Privacy Officer at info@emboldenmentalhealth.com. Please note that withdrawal of consent may limit our ability to continue providing services, and it does not apply retroactively to information already collected, used, or disclosed with your consent.
12. COOKIES AND TRACKING TECHNOLOGIES
Our website (www.emboldenmentalhealth.com) uses cookies and similar tracking technologies to improve your browsing experience and to help us understand how visitors use our site.
What Are Cookies: Cookies are small text files that are stored on your device (computer, tablet, or smartphone) when you visit a website. They help the website recognize your device and remember certain information about your visit.
Types of Cookies We Use:
Essential Cookies: These cookies are necessary for our website to function properly. They enable basic features such as page navigation and access to secure areas of the site. The website cannot function properly without these cookies.
Analytics Cookies: We may use analytics tools (such as those provided by our website hosting platform) to collect anonymous, aggregated data about how visitors use our website. This includes information such as pages visited, time spent on pages, referring websites, and general location data. This data helps us improve our website content and user experience. Analytics cookies do not collect personal health information.
Third-Party Cookies: Our website may contain embedded content or links to third-party services (such as social media platforms) that may set their own cookies. We do not control the cookies set by these third parties, and we encourage you to review their respective privacy policies.
Managing Cookies: You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of our website. You can also opt out of certain analytics tracking by using browser plugins or settings provided by the analytics service.
Our website does not use cookies to collect personal health information, and we do not use cookies for targeted advertising purposes.
Do Not Track: Some browsers offer a "Do Not Track" feature that sends a signal to websites requesting that your browsing activity not be tracked. At this time, our website does not respond to "Do Not Track" signals, but we do not engage in behavioral tracking or targeted advertising.
13. WEBSITE ACCESSIBILITY (ACCESSIBILITY BY USERWAY)
Embolden Mental Health & Psychotherapy is committed to ensuring that our website is accessible to all individuals, including people with disabilities. To support this commitment, we use the Accessibility by UserWay widget on our website.
What is UserWay: UserWay is a third-party accessibility tool that provides a suite of features designed to improve the accessibility of our website and enhance compliance with the Web Content Accessibility Guidelines (WCAG) 2.1, the Accessibility for Ontarians with Disabilities Act (AODA), and other applicable accessibility standards.
Features Included in the UserWay Accessibility Widget:
- Screen Reader: Provides auditory feedback for on-screen content, reading aloud text, descriptions, and navigational elements for users who are visually impaired.
- Contrast Adjustments: Includes options to invert colors, apply dark mode, and use Smart Contrast, which dynamically adjusts color contrast for optimal readability.
- Bigger Text: Allows users to increase text size for enhanced readability, with multiple levels of adjustment.
- Text Spacing: Provides options for light, moderate, and heavy line spacing to improve readability.
- Dyslexia-Friendly and Legible Fonts: Offers specialized font choices designed to improve readability for users with dyslexia.
- Highlight Links: Visually emphasizes hyperlinks to help users quickly identify clickable elements.
- Big Cursor: Enlarges the cursor for better visibility.
- Reading Mask: Applies a semi-transparent overlay around the cursor to help users focus on specific content.
- Reading Guide: Provides a horizontal guide to help users follow lines of text.
- Hide Images: Removes visual elements from the page, focusing solely on text content for users who prefer a simplified view.
- Tool Tips: Displays alt text descriptions when users hover over or focus on images, offering additional context about the image content.
- Dictionary: Offers definitions and additional context for words on the page.
- Keyboard Navigation Enhancements: Improves navigation for users who rely on keyboard-only interaction.
- Page Structure and Navigation Tools: Helps users navigate the structure of the page more easily.
Privacy and UserWay: UserWay does not collect personal information from users interacting with the accessibility widget. The widget is designed to enhance accessibility without compromising user privacy. For more information on UserWay's privacy practices, please visit userway.org/privacy.
The UserWay widget appears as a floating icon on our website. You can click on it at any time to access and customize these accessibility features to suit your needs.
14. THIRD-PARTY LINKS
Our website may contain links to external websites or services that are not operated by Embolden Mental Health & Psychotherapy. These may include links to resources, blog references, social media platforms, or other third-party services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party website you visit.
15. SOCIAL MEDIA
Embolden Mental Health & Psychotherapy may maintain a presence on social media platforms (such as Instagram or Facebook) for the purpose of sharing mental health information, practice updates, and educational content.
Please be aware that any information you share on social media platforms is governed by the privacy policies of those platforms, not this Privacy Policy. We strongly advise against sharing personal or health-related information through social media channels, comments, or direct messages on social media platforms.
If you wish to communicate with us about your care or share personal information, please use secure methods such as the Jane App client portal or email us directly at info@emboldenmentalhealth.com.
We will never disclose the identity of our clients on social media, confirm or deny that any individual is a client, or share any client information through social media platforms.
16. CHILDREN AND MINORS
Embolden Mental Health & Psychotherapy provides services to children, teens, and adults. For clients under the age of 16, consent for the collection, use, and disclosure of personal health information is typically provided by a parent or legal guardian, in accordance with PHIPA.
Our website is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 through our website. If you believe we have inadvertently collected information from a child under 13 through our website, please contact us immediately so that we can take appropriate steps.
17. ONTARIO'S PERSONAL HEALTH INFORMATION PROTECTION ACT (PHIPA)
As a provider of health care services in Ontario, Embolden Mental Health & Psychotherapy and each of our therapists operate as Health Information Custodians under the Personal Health Information Protection Act, 2004 (PHIPA).
PHIPA governs how health information custodians in Ontario collect, use, disclose, retain, and dispose of personal health information. PHIPA has been deemed "substantially similar" to Canada's federal privacy law, PIPEDA, where health records are concerned.
Under PHIPA:
- We collect, use, and disclose your personal health information only with your consent or as permitted or required by law.
- We limit the collection of personal health information to what is reasonably necessary for the purposes identified.
- We take reasonable steps to ensure that your personal health information is accurate, complete, and up to date.
- We protect your personal health information with appropriate security safeguards.
- We make information about our privacy policies and practices available to you.
- We respond to requests for access to or correction of personal health information within 30 days.
- We retain your personal health information for the periods required by law and professional standards, and securely destroy it when it is no longer needed.
For more information about your rights under PHIPA, please contact our Privacy Officer at info@emboldenmentalhealth.com or the Information and Privacy Commissioner of Ontario.
18. PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT (PIPEDA)
In addition to PHIPA, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada's federal privacy law, where applicable. PIPEDA applies to the collection, use, and disclosure of personal information in the course of commercial activity.
Under PIPEDA, we are committed to the following principles:
Accountability: We are responsible for the personal information in our custody and control, and we have designated a Privacy Officer to oversee our compliance.
Identifying Purposes: We identify the purposes for which we collect personal information at or before the time of collection.
Consent: We obtain meaningful consent for the collection, use, and disclosure of personal information, except where exempted by law.
Limiting Collection: We collect only the personal information necessary for the identified purposes.
Limiting Use, Disclosure, and Retention: We use, disclose, and retain personal information only for the purposes for which it was collected, unless we have your consent or are required by law to do otherwise.
Accuracy: We take reasonable steps to keep personal information accurate, complete, and up to date.
Safeguards: We protect personal information with security safeguards appropriate to the sensitivity of the information.
Openness: We make our privacy policies and practices readily available.
Individual Access: Upon request, we will inform you of the existence, use, and disclosure of your personal information and give you access to it.
Challenging Compliance: You may challenge our compliance with these principles by contacting our Privacy Officer.
19. DISCLAIMER
The information provided on our website (www.emboldenmentalhealth.com), including blog posts, articles, and other resources, is intended for general informational and educational purposes only. It is not a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of a qualified health provider with any questions you may have regarding a medical or mental health condition.
The use of our website does not establish a therapist-client relationship. A therapist-client relationship is established only through a formal intake process, which includes the completion of intake and consent forms and the commencement of treatment.
20. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make changes, we will update the "Last Updated" date at the top of this policy.
If we make significant changes to how we handle your personal information or personal health information, we will notify you by posting a prominent notice on our website and, where appropriate, by contacting you directly via email.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
21. CONTACT US
If you have any questions, concerns, or complaints about this Privacy Policy, our privacy practices, or how we handle your personal information or personal health information, please contact us:
Embolden Mental Health & Psychotherapy
Privacy Officer: Ashley Latendresse
Email: info@emboldenmentalhealth.com
Website: www.emboldenmentalhealth.com
If you are not satisfied with our response to your privacy concern, you may contact:
Information and Privacy Commissioner of Ontario
Toronto Area: 416-326-3333
Long Distance: 1-800-387-0073
Email: commissioner@ipc.on.ca
Website: www.ipc.on.ca
Office of the Privacy Commissioner of Canada
Toll-Free: 1-800-282-1376
Website: www.priv.gc.ca
Thank you for trusting Embolden Mental Health & Psychotherapy with your care. Your privacy is important to us, and we are committed to safeguarding it.