Privacy Policy

Good Comfort (“Good Comfort,” “we,” “our,” “us”) is committed to protecting your privacy and handling personal information with transparency, respect, and care. This Privacy Policy explains how we collect, use, disclose, protect, and store personal information in compliance with:

• PIPEDA – Personal Information Protection and Electronic Documents Act (Canada)

• PHIPA (Ontario) – Personal Health Information Protection Act (voluntarily applied where we receive health-related information)

• Ontario Consumer Protection Act (CPA) – standards for transparency and fair business practices

By using our website, assessment tools, or services, you consent to the practices described in this policy.

1. Scope of This Policy

This Privacy Policy applies to:

• Our website and digital platforms

• Our Good Comfort Care Assessment tools

• Phone, SMS, email, and virtual communications

• Any wellness, support, transportation, or coordination services we provide

This policy does not apply to:

• The independent privacy practices of service partners

• Regulated health professionals who operate under their own PHIPA obligations

2. Information We Collect

We collect only the information reasonably necessary to provide, coordinate, and improve our services.

2.1 Information From Website Forms

When you join our mailing list, request a call, or submit an inquiry, we collect:

• First and last name

• Email address

This allows us to follow up, respond to your questions, and provide updates.

2.2 Information From the Care Assessment Tools

To recommend appropriate services, we collect:

• Who needs the care

• Care category and type

• Timing and urgency of care

This may include general health-related details but does not include diagnoses or clinical medical history.

2.3 Optional Information You Choose to Share

You may voluntarily provide additional context such as:

• Mobility considerations

• Lifestyle or wellness preferences

• Scheduling needs

• Communication preferences

These optional details are collected only with your consent.

2.4 Automatically Collected Information

We may automatically collect:

• IP address

• Device and browser information

• Pages viewed and time spent on the site

• Cookies and tracking technologies

This helps us improve website performance and user experience.

3. How We Use Your Information

We use personal information only for purposes that a reasonable person would expect, including:

• Recommending, coordinating, and delivering services

• Responding to inquiries and providing customer support

• Matching your needs to appropriate care, wellness, or transportation services

• Sending confirmations, updates, reminders, and scheduling notifications

• Improving our website, assessment tools, and user experience

• Ensuring legal and regulatory compliance

• Detecting and preventing fraud or unauthorized access

We do not use your information for unrelated purposes without your consent.

4. Our Legal Basis for Use

Our legal bases include:

• Express consent, such as when you submit an assessment or form

• Implied consent, when information is shared to enable service delivery

• Legal obligations, such as responding to lawful requests or court orders

PHIPA Clarification:

Good Comfort is not a “Health Information Custodian” under PHIPA.

However, where we receive information that may be considered personal health information, we voluntarily follow PHIPA principles, including:

• Limited collection

• Limited use and disclosure

• Accuracy

• Secure retention and access controls

5. Sharing and Disclosure of Information

We do not sell, rent, or trade personal information.

We may share information only with:

5.1 Service and Technology Partners

To deliver or coordinate services, we may share necessary information with:

• Transportation partners

• Customer support or scheduling partners

• Technology, hosting, and analytics providers

• Wellness or care service partners

All partners must meet confidentiality and data protection standards equivalent to Canadian law.

5.2 Legal, Regulatory, or Safety Reasons

We may disclose information:

• When required by law, subpoena, or court order

• To investigate potential fraud or misuse

• To protect someone’s safety or prevent harm

We disclose only what is legally required.

6. Cookies and Tracking Technologies

We may use cookies, analytics tools, and similar technologies to:

• Improve website functionality

• Understand user behaviour

• Enhance navigation and user experience

You may adjust your browser settings to manage or disable cookies.

7. Data Security

We use administrative, technical, and physical safeguards to protect personal information, including:

• Encrypted website connections (HTTPS)

• Secure servers and firewalls

• Access controls

• Secure data handling and retention procedures

• Staff training on confidentiality and privacy

While no system is entirely secure, we take reasonable steps to protect your information.

8. Data Retention

We retain personal information only as long as necessary to:

• Provide services

• Fulfill the purposes described in this policy

• Meet legal, tax, and operational requirements

When information is no longer required, it is securely deleted or anonymized.

9. Data Breach Notification

If a breach of security involving personal information occurs, we will:

• Notify affected individuals as soon as feasible

• Report the breach to the Office of the Privacy Commissioner of Canada when legally required

• Maintain records of all breaches, as mandated by PIPEDA

10. Your Rights

You have the right to:

• Access your personal information

• Request corrections to inaccurate information

• Withdraw consent (subject to service limitations)

• Request deletion where legally permissible

• Ask how your information has been used or disclosed

We may require identity verification before responding.

11. Providing Information About Someone Else

If you provide information about a family member, you confirm that:

• You have their consent; or

• You have legal authority to act on their behalf

Good Comfort does not knowingly collect data from children under 13 without parental involvement.

12. International Transfers

Some service or hosting partners may process data outside Canada.

Where transfers occur, we ensure protections equivalent to Canadian privacy laws.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The “Last Updated” date reflects the latest version.

Continued use of our services indicates acceptance of updates.

14. Contact Us

For questions, requests, or concerns about this Privacy Policy:

Good Comfort — Privacy Office

Email: wecare@goodcomfort.ca

Phone: 647-795-3923

Address: Scrivener Square, Toronto, ON M4W 3X9