Interpersonal Wellness Services Inc.

Interpersonal Wellness Services Inc. (“IWS,” “we,” “us,” “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit our websites, register for programs, complete assessments, book services, purchase products, attend webinars/events, or otherwise interact with us.

This policy is intended to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s Anti-Spam Legislation (CASL), and Quebec’s Law 25 (Act respecting the protection of personal information in the private sector) where applicable.

1) Scope and What This Policy Covers

This policy applies to personal information we collect through:

• our websites and landing pages
• email and SMS communications
• booking and registration tools
• webinars and virtual meetings
• our learning platforms and assessments (including WIS®Resilience)
• customer support interactions
• intake and screening processes

Coaching and educational services are not medical care: Our services support coaching, learning, and well-being education, not medical diagnosis, treatment, or clinical care. During intake, we may collect limited information about your health or mental health status solely to determine whether coaching is appropriate for your circumstances or whether a referral to a healthcare professional may be more suitable. This screening information is collected for client safety and service appropriateness, is kept confidential, and is not used for any diagnostic or treatment purpose.

If you have concerns about your physical or mental health, please consult a qualified healthcare professional or emergency services.

Third-party links: Our websites may contain links to third-party websites, services, or resources. We are not responsible for the privacy practices or content of those external sites. We encourage you to review the privacy policies of any third-party sites you visit.

2) Personal Information We Collect

We collect information in three main ways: (a) information you provide, (b) information collected automatically, and (c) information from third parties (when permitted).

A) Information You Provide

Depending on how you interact with us, we may collect:

• Contact details: name, email, phone number, company, role, address (if needed for billing).
• Account and learning details: login credentials, course progress, completion, certificates (where applicable).
• Intake and screening information: limited health-related information you provide during intake to help us assess whether our coaching services are appropriate for your current circumstances. This may include information about current mental health support, medications that may affect participation, or conditions that may indicate clinical care is more appropriate than coaching.
• Bookings and event details: scheduling information, attendance, webinar registration details.
• Purchases and billing: billing address, transaction details, receipts, and payment status (payments are processed by third-party payment processors; we generally do not store full card numbers).
• Assessment, survey, and intake responses: responses you submit through our surveys, forms, and resilience/well-being tools, including the WIS®Resilience platform (see Section 9 for how we protect and retain this information).
• Communications: messages, requests, and feedback you send to us by email, chat, SMS, forms, or other channels.

B) Information Collected Automatically

When you visit our site or use our online services, we may automatically collect:

• IP address, device type, browser, operating system,
• pages viewed, links clicked, referral URLs, session activity,
• approximate location derived from IP (city/region-level),
• cookies and similar technologies (see Section 6).

C) Information from Third Parties (When Permitted)

We may receive limited information from:

• advertising platforms (e.g., Meta, LinkedIn) for campaign reporting
• webinar/event platforms (for attendance/registration)
• partners or referrers (if you consented to referral)

3) How We Use Personal Information

We use personal information for the following purposes:

• To assess service appropriateness: evaluating intake and screening information to determine whether our coaching services are suitable for your circumstances, and where appropriate, recommending alternative resources or professional support.
• To deliver services and products: registrations, onboarding, coaching/program delivery, course access, assessment delivery, and customer support.
• To process payments and transactions: billing, receipts, refunds, chargeback handling, and accounting recordkeeping.
• To communicate with you: confirmations, updates, service messages, and responding to inquiries.
• To send marketing communications (with consent where required): newsletters, offers, event invitations, and resources (you can unsubscribe anytime).
• To improve our website and offerings: analytics, troubleshooting, testing, and performance measurement.
• To maintain safety and integrity: security monitoring, fraud prevention, enforcing terms, and protecting our organization and users.
• To meet legal requirements: compliance, audits, dispute resolution, and responding to lawful requests.
• To support affiliate and referral programs: tracking referral sources and attributing sales for commission purposes (see Section 5D).

4) Consent and Legal Bases for Processing

We generally collect, use, and disclose personal information with your consent, except where permitted or required by law.

Intake and screening consent: When you provide health-related information during intake, you consent to our use of that information solely for the purpose of assessing whether coaching is appropriate for you. We will not use this information for any other purpose without your explicit consent.

When we process without explicit consent: In limited circumstances, we may process personal information without consent where permitted by law, including: to fulfill a contract with you (e.g., delivering a program you purchased), to comply with legal obligations, to protect vital interests, or where we have a legitimate business interest that does not override your privacy rights.

Email marketing (CASL): If you subscribe to our emails or opt in to receive marketing content, we may send you marketing messages. You can unsubscribe at any time using the link in our emails or by contacting us.

SMS messaging: If you opt in to SMS, we may send appointment reminders, event updates, and other messages via HubSpot. Message and data rates may apply. You can opt out by following the instructions in the message or contacting us.

Withdrawing consent: You may withdraw consent at any time, subject to legal or contractual restrictions. Withdrawing consent may affect our ability to provide certain services. To withdraw consent, contact us using the details in Section 13.

5) How We Share Personal Information

We do not sell your personal information. We may share it in these circumstances:

A) Service Providers (Processors)

We may share personal information with trusted service providers who help us operate our business, such as:

• CRM and marketing: HubSpot, GetResponse
• Email systems / deliverability: Zoho Mail; Amazon SES (email infrastructure), domain and email infrastructure providers
• Payments: Stripe
• Booking/scheduling: HubSpot scheduling, Google Calendar integrations, Calendly
• Webinars/meetings: WebinarJam, Zoom, Microsoft Teams
• Learning platforms: LearnWorlds; WIS®Resilience platform
• Surveys/forms: Google Forms, SurveyMonkey, WIS® survey tools
• Analytics/SEO: Google Analytics, Google Search Console
• Advertising: Meta (Facebook/Instagram), LinkedIn, Google ads (and potentially other ad platforms as used)
• Video hosting/embeds: Vimeo, YouTube
• File storage/collaboration: Google Drive, Dropbox, Microsoft OneDrive
• Website hosting/security/CDN: Hostinger, GoDaddy, Cloudflare

These providers are authorized to use personal information only as needed to provide services to us and are required to protect it.

B) Legal and Safety

We may disclose information if required to comply with law, regulation, court order, or lawful request, or to protect our rights, users, and safety.

C) Business Transactions

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate safeguards.

D) Affiliate and Referral Programs

If you are referred to us through an affiliate partner, we may share limited information with that affiliate for the purpose of tracking referrals and calculating commissions. This information is limited to: confirmation of purchase, transaction date, and general product/service category. We do not share your assessment responses, intake/screening information, detailed personal information, or contact details with affiliates.

E) Intake and Screening Information

We do not share intake or screening information with third parties except where: (a) required by law, (b) necessary to protect your safety or the safety of others, or (c) you have provided explicit consent. This information is never shared with affiliates, marketing partners, or organizational clients.

6) Cookies and Tracking Technologies

We use cookies and similar technologies to:

• keep the site working
• understand website performance and user behavior
• measure marketing effectiveness

We use tools such as Google Analytics and may use advertising pixels (e.g., Meta, LinkedIn) where enabled.

Cookie consent: When you first visit our website, you may be presented with options to accept or manage cookies. You can also control cookies through your browser settings at any time. Disabling cookies may affect site functionality.

Do Not Track signals: Some browsers offer a “Do Not Track” (DNT) setting. Our website does not currently respond to DNT signals. You can manage your tracking preferences through cookie settings and browser controls.

7) AI-Assisted Chat and Automated Tools

We may use automated tools, including AI-assisted features, to help respond to inquiries, route messages, or provide basic information.

Assessment scoring: Our WIS®Resilience platform uses automated scoring to organize your self-reported responses into structured indicators and insights. These scores are generated automatically based on your inputs and are designed to support personal development and organizational planning. They are not clinical assessments, diagnoses, or treatment recommendations. You may contact us to request information about how your scores were calculated.

Intake screening: Intake and screening information is reviewed by authorized personnel, not automated systems. Decisions about coaching appropriateness are made by qualified team members, not algorithms.

Please do not submit sensitive personal information (e.g., detailed medical histories, financial account numbers) through chat. If you require confidential support, contact us directly using the methods in Section 13.

Where AI tools are used, we apply reasonable safeguards to limit data exposure and use the tools only for support and service improvement purposes.

8) International Transfers

Some of our service providers may process or store information outside Canada (including in the United States or other jurisdictions). When information is processed outside Canada, it may be subject to the laws of that jurisdiction, including laws that may permit government access to data.

We take reasonable steps to ensure appropriate safeguards are in place when using service providers, including reviewing their privacy and security practices.

Intake and screening information: Where possible, we store intake and screening information on servers located in Canada. Where this is not feasible, we ensure appropriate contractual safeguards are in place with service providers.

9) Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, including to meet legal, accounting, and operational requirements.

General retention periods:

• Transaction and billing records: 7 years (to meet legal, tax, and accounting requirements).
• Intake and screening information: Retained with your client file for the duration of the coaching engagement, plus up to 7 years following completion (consistent with professional recordkeeping standards and potential legal requirements).
• Assessment and survey responses: Retained while your account is active, plus up to 3 years following account closure or your last interaction with us, unless you request earlier deletion.
• Marketing preferences and communication history: Until you unsubscribe or request deletion.
• Website analytics data: Aggregated and anonymized data may be retained indefinitely; identifiable data is retained according to our analytics provider’s policies (typically 14–26 months for Google Analytics).
• Customer support communications: Up to 3 years following resolution, unless a longer period is required for legal purposes.

When no longer needed, we securely delete, anonymize, or de-identify information where appropriate.

Assessment data protection: We recognize that WIS®Resilience assessment responses contain personal reflections about well-being and resilience. Access to individual assessment data is restricted to authorized personnel on a need-to-know basis. Organizational clients receive only aggregated, anonymized reports unless you have provided explicit consent for individual-level sharing.

Intake and screening data protection: Intake and screening information is treated with heightened confidentiality. Access is restricted to authorized coaching and administrative personnel directly involved in assessing service appropriateness and delivering services. This information is stored separately from marketing databases and is never used for promotional purposes.

10) Security Safeguards

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. These include encryption of data in transit, access controls, and regular security reviews.

Enhanced safeguards for sensitive information: Intake, screening, and assessment information receive additional protections, including restricted access permissions and secure storage practices.

No method of transmission or storage is 100% secure, but we work to maintain appropriate protections.

Breach notification: In the event of a data breach that poses a real risk of significant harm to you, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA. We will also take reasonable steps to mitigate any harm resulting from the breach.

11) Children’s Privacy

Our services are intended for adults. We do not knowingly collect personal information from children under 13 (or under the age of majority where applicable) without verified parental/guardian consent. If you believe a child has provided us personal information, contact us and we will take appropriate steps to delete that information.

12) Your Rights

Under applicable Canadian privacy laws, you may request:

• access to your personal information (including intake, screening, and assessment information)
• correction of inaccurate or incomplete information
• information about how we use and disclose your information
• deletion of your personal information (subject to legal and contractual limitations)
• withdrawal of consent (subject to legal/contractual limits)

Response timeframe: We will respond to access and correction requests within 30 days, as required by PIPEDA. If we need additional time, we will notify you of the delay and the reasons.

Quebec residents: If you are a Quebec resident, you may have additional rights under Law 25, including the right to data portability (receiving your personal information in a commonly used technological format). Contact us to make a request.

Complaints: If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca, or with your provincial privacy commissioner where applicable.

To make a privacy request, contact us using the details below.

13) Contact Us (Privacy Officer)

Person Responsible for Privacy Interpersonal Wellness Services Inc.

Address: PO Box 43026, RPO Kildonan Place, Winnipeg, MB., R2C 5G5, Canada

Email: admin@interpersonalwellness.com

Phone: 204 668-5283

Our Privacy Officer is responsible for overseeing compliance with this policy and applicable privacy laws. If you have questions, concerns, or requests regarding your personal information  including questions about intake, screening, or assessment data, please contact us using the information above.

14) Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Effective date” at the top indicates when it was last revised. Material changes will be posted on our website and/or communicated by email where appropriate. We encourage you to review this policy periodically.