Effective Date: May 3, 2026
Last Updated: May 3, 2026

1. Our Commitment to Privacy

Urban Spa (operated by Paznor Group Inc.) is committed to protecting the privacy, confidentiality, and security of your personal and personal health information.

As a provider of regulated health services, we operate in accordance with:

• The Regulated Health Professions Act (RHPA)
• The standards of the College of Massage Therapists of Ontario
• Applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA)

We collect, use, and disclose personal information responsibly and only to the extent necessary to provide safe, effective, and professional services.

2. What Is Personal Information

Personal information means information about an identifiable individual, including:

• Name, phone number, email, and address
• Date of birth
• Health history, assessments, and treatment notes
• Financial and transaction records
• Any documentation related to your care

Business contact information used in a professional capacity is not considered personal information under privacy legislation.

3. Why We Collect Your Information (Primary Purposes)

We collect personal and health information in order to:

• Provide safe and appropriate treatments
• Assess your health needs and determine appropriate care
• Maintain clinical records in accordance with professional standards
• Monitor changes in your health over time
• Communicate with you regarding appointments and care

4. Secondary Uses of Information

We may also use your information for purposes related to your care, including:

• Processing payments and issuing receipts, including insurance receipts
• Internal quality assurance, training, and service improvement
• Meeting legal, regulatory, and professional obligations
• Communicating relevant services, promotions, or updates (with your consent)

You may opt out of marketing communications at any time.

5. Consent

Your consent is required for the collection, use, and disclosure of your personal information.

Consent may be:

• Express (written or verbal)
• Implied (e.g., providing information for the purpose of receiving care)

You may withdraw your consent at any time, subject to legal and regulatory requirements. Withdrawal of consent may impact our ability to provide services.

6. Disclosure of Information

Urban Spa does not sell or rent personal information.

We may disclose personal information in the following circumstances:

• With your consent
• To other regulated health professionals involved in your care
• To insurance providers for claims processing (with your authorization)
• When required or permitted by law
• To regulatory bodies such as the College of Massage Therapists of Ontario
• To authorized third-party service providers (e.g., payment processors, booking systems) under strict confidentiality agreements

7. Use of Third-Party Systems

Urban Spa uses secure third-party platforms to support booking, payment processing, and communication.

These providers are required to:

• Maintain appropriate privacy and security safeguards
• Use personal information only for authorized purposes

Clients are encouraged to review applicable third-party privacy policies where relevant.

8. Protection of Personal Information

We take reasonable steps to safeguard personal information, including:

• Secure electronic systems with restricted, role-based access
• Password protection and secure authentication practices
• Staff training on confidentiality and privacy obligations
• Secure storage of physical records
• Encryption or secure transmission where applicable

9. Record Retention

In accordance with professional and regulatory requirements:

• Client records are retained for a minimum of 10 years from the date of last treatment
• Records for minors are retained for 10 years after the client reaches age 18

Records are securely destroyed after the retention period.

10. Access to Your Information

You have the right to:

• Request access to your personal and health records
• Request corrections to inaccurate or incomplete information

Requests must be made in writing. We will respond within a reasonable timeframe in accordance with applicable legislation.

11. Website and Digital Privacy

When interacting with our website:

• Limited non-identifiable information may be collected (e.g., browser type, usage data)
• Information submitted through forms is used only for its intended purpose
• Online booking systems collect necessary information to manage appointments

12. Communication Preferences

We may contact you via phone, email, or text message for:

• Appointment confirmations and reminders
• Follow-up care
• Relevant service updates

You may opt out of non-essential communications at any time.

13. Contact Information

Urban Spa – We Care Team
388 Rogers St
Peterborough, ON K9H 1W7
Phone: 705-741-1212
Email: wecare@urbanspapeterborough.com

Our team is available Monday to Friday, 9:00 AM – 5:00 PM to assist with any questions or concerns.

14. Complaints Process

If you have concerns about how your personal information is handled:

1. Please contact Urban Spa directly
2. If your concern is not resolved, you may contact:

College of Massage Therapists of Ontario
1867 Yonge Street, Suite 810
Toronto, ON M4S 1Y5
Phone: 416-489-2626 | 1-800-465-1933
Fax: 416-489-2625
Email: cmto@cmto.com
Website: www.cmto.com

You may also contact the Office of the Privacy Commissioner of Canada.

15. Updates to This Policy

This Privacy Policy may be updated from time to time to reflect changes in legislation or business practices. The most current version will always be available on our website.