Privacy Policy

Summary

In plain English, medical information is kept medical: private and never used for marketing. Marketing information is used to remind you about appointments and help us improve how we find and support people who may benefit from our services.

We try to treat your information as we would like our own information to be treated. We do not sell your personal information. We use it only to provide services, improve our systems, and support patient care.

We may use de-identified or aggregated information to understand how our platform works, improve service quality, and better target potential clients.

Clinical information is handled by Bespoke Medical Clinic within secure medical record systems. It may be shared with laboratories, regulated service providers, or legal authorities where required by law, but is otherwise kept confidential in accordance with applicable health privacy laws.

1. Scope and Accountability

Vitality-Again.com (the "Platform," "we," "us," or "our") is a Canadian digital health platform operated as a joint initiative between Bespoke Medical Clinic and SHG Studios (also known as Snakehead Games Inc.).

• Bespoke Medical Clinic is an Ontario-based hormone clinic with over 20 years of clinical experience and is responsible for medical operations in full.
• SHG Studios is an Ontario-based digital media company responsible for platform development, marketing systems, and technical operations.

Bespoke Medical Clinic provides clinical services and medical oversight through licensed Canadian healthcare professionals operating under appropriate medical supervision. SHG Studios provides the digital infrastructure and marketing systems enabling access to care.

For the purposes of applicable privacy legislation:

• SHG Studios is responsible for personal information collected through the Platform prior to transfer into Bespoke Medical Clinic's clinical systems.
• Once an individual enters clinical care and information is collected within Bespoke Medical Clinic's secure medical record systems, Bespoke Medical Clinic is responsible for that information in accordance with applicable health privacy legislation, including PHIPA where applicable.

This Privacy Policy describes how personal information collected through the Platform is handled in accordance with PIPEDA and applicable provincial health privacy legislation, including Ontario's PHIPA where applicable.

At present, we operate only in Canada in jurisdictions where we have appropriate medical licenses and capacity.

2. Information We Collect

Through the Platform, prior to transfer into Bespoke Medical Clinic's clinical systems, we collect:

• Contact information (name, email address, phone number)
• General eligibility and screening responses
• Appointment request information
• Marketing interaction data
• Technical data such as IP address, browser type, device type, and site usage

The Platform collects information for marketing, eligibility screening, and care coordination purposes. You must opt in to access reminders and targeting.

Clinical intake forms, diagnostic information, and medical records are collected and maintained directly within Bespoke Medical Clinic's secure clinical systems (such as Jane App or similar electronic medical record systems).

SHG Studios does not access, store, or manage clinical records maintained within those systems, except where necessary to provide technical support under appropriate safeguards.

3. How Your Information Is Used

Personal information collected through the Platform may be used to:

• Respond to inquiries
• Conduct general eligibility screening
• Coordinate appointment requests
• Communicate about services
• Improve platform performance and user experience
• Measure marketing effectiveness

We do not use personal health information for advertising.

We may use non-health information for marketing measurement and audience building, including remarketing and similar tools. Marketing tools may involve limited data sharing with advertising platforms for measurement purposes.

We do not sell personal information.

Once in the clinical stage, Bespoke uses relevant patient information to support care. That information is not shared back to the Platform except in de-identified or aggregated form that does not identify individuals.

4. Consent

By submitting information through the Platform, you consent to collection, use, and disclosure for the purposes described in this Policy.

You may withdraw consent at any time, subject to legal, contractual, and system restrictions. Withdrawal may limit our ability to provide services.

You may opt out of non-essential communications using the unsubscribe link in emails and other communications.

5. Sharing of Information

Personal information may be shared only as necessary:

• With Bespoke Medical Clinic for scheduling or coordination of care
• With secure third-party service providers supporting hosting, communications, marketing analytics, or payment processing
• To comply with legal obligations

All service providers are contractually required to safeguard personal information consistent with Canadian privacy standards.

Clinical records are maintained by Bespoke Medical Clinic and its healthcare professionals in accordance with applicable health privacy legislation.

6. Data Security and Safeguards

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, or modification.

Safeguards include:

• Encryption in transit (SSL/TLS)
• Role-based access controls
• Secure hosting infrastructure
• Restricted access to authorized personnel

While no system can guarantee absolute security, reasonable safeguards are maintained. We try to treat your information as we would want our own information treated.

7. Data Breach Notification

In the event of a breach of security safeguards involving personal information under our control, we will comply with applicable breach notification obligations under Canadian privacy laws.

Where required, this may include:

• Notification to affected individuals
• Reporting to the Office of the Privacy Commissioner of Canada
• Record-keeping of security incidents

If a breach involves clinical records maintained by Bespoke Medical Clinic, breach response will be handled in accordance with applicable health privacy legislation.

8. Cookies, Analytics, and Marketing Technologies

The Platform uses cookies and similar technologies to support essential functionality and measure usage.

With consent, analytics and marketing tools may collect technical data such as IP address, device information, and interaction data to measure performance and optimize marketing efforts.

These tools may support remarketing and audience measurement functions using non-health information.

9. Retention and Storage

Personal information is retained only as long as necessary to fulfill the purposes described in this Policy or as required by law.

Clinical record retention is governed by Bespoke Medical Clinic and applicable health privacy legislation.

Information may be stored or processed in Canada or other jurisdictions depending on service providers used. Service providers are required to protect personal information in accordance with applicable privacy laws and appropriate security standards.

10. Access and Correction

You may request access to personal information held by SHG Studios and request corrections, subject to legal limitations.

Requests relating to clinical records must be directed to Bespoke Medical Clinic.

Detailed identity verification is required before processing requests.

11. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised effective date.

12. Privacy Contact

For privacy-related questions or requests, contact:
privacy@vitality-again.com

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.