Privacy Policy

Effective Date: April 1, 2026

At Comfora Home Care ("Comfora," "we," "us," or "our"), we are committed to protecting the privacy of our clients, website visitors, and users. This Privacy Policy describes how we collect, use, disclose, retain, and safeguard your personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Ontario's Personal Health Information Protection Act, 2004 (PHIPA), and all other applicable federal and provincial privacy legislation. By accessing our website (www.comfora.ca) or using our services, you acknowledge and agree to the practices described in this policy.

1. Definitions

For the purposes of this Privacy Policy:

• "Personal Information" means any information about an identifiable individual, including but not limited to name, address, phone number, email address, date of birth, financial information, and any other information as defined under PIPEDA.
• "Personal Health Information" (PHI) means identifying information about an individual in oral or recorded form that relates to the individual's physical or mental health, health care history, plan of service, payments or eligibility for health care, donation of body parts or bodily substances, or the individual's health number, as defined under PHIPA.
• "Services" means any and all home care, companionship, personal support, and related services provided by Comfora.

2. Information We Collect

We may collect the following categories of personal information:

• Identity Information: Full name, date of birth, gender, marital status, and government-issued identification numbers where required.
• Contact Information: Mailing address, email address, phone numbers, and emergency contact details.
• Health Information: Medical history, diagnoses, treatment plans, medications, allergies, care assessments, physician referrals, insurance and benefits information, and other health-related records necessary for the provision of care.
• Financial Information: Billing addresses, payment card details, banking information, and transaction records necessary for processing payments for our services.
• Employment and Background Information: For caregivers and employees, we collect resumes, references, criminal background checks, professional certifications, and employment history.
• Digital and Technical Information: IP addresses, browser type, operating system, device identifiers, cookies, referring URLs, pages visited, and interaction data collected through your use of our website.
• Communications: Records of correspondence, feedback, complaints, and inquiries submitted through our website, email, phone, or other channels.

3. Purposes of Collection, Use, and Disclosure

We collect, use, and disclose personal information for the following purposes:

• To provide, coordinate, and manage home care and related services, including care assessments, care planning, and service delivery.
• To communicate with clients, family members, and authorized representatives about care, scheduling, and service-related matters.
• To process billing, payments, and insurance claims.
• To comply with applicable legal and regulatory obligations, including reporting requirements under Ontario's health care and employment legislation.
• To recruit, screen, train, and manage caregivers and employees.
• To improve and develop our services, website functionality, and user experience.
• To send service updates, newsletters, and promotional communications (with your consent, where required).
• To investigate complaints, enforce our legal rights, and protect the safety and security of our clients, staff, and the public.
• To fulfill any other purpose for which you provide your information or to which you consent.

We reserve the right to use de-identified, aggregated, or anonymized data for analytics, research, quality improvement, and business purposes without restriction, as such data does not constitute personal information.

4. Consent

By providing your personal information to Comfora, you consent to its collection, use, and disclosure as described in this Privacy Policy. Consent may be express (written or verbal) or implied, depending on the circumstances and the sensitivity of the information.

For Personal Health Information, we will obtain your express consent unless collection, use, or disclosure without consent is permitted or required by PHIPA or other applicable law (for example, to provide or assist in providing health care, to comply with a legal obligation, or in an emergency).

You may withdraw your consent at any time by contacting us in writing, subject to legal or contractual restrictions and upon reasonable notice. Withdrawal of consent may limit or prevent us from providing certain services to you. Comfora is not responsible for any consequences arising from your withdrawal of consent.

5. Disclosure of Personal Information

We may disclose your personal information to:

• Health Care Providers: Physicians, specialists, hospitals, and other health care providers involved in your care.
• Insurance Companies and Funders: To process claims, verify coverage, and facilitate payment for services.
• Government and Regulatory Bodies: As required or permitted by law, including but not limited to the Ontario Ministry of Health, public health authorities, and regulatory colleges.
• Service Providers and Contractors: Third-party vendors who assist us in operating our business (e.g., IT providers, payment processors, cloud storage providers), subject to confidentiality agreements and data protection obligations.
• Legal and Professional Advisors: Lawyers, accountants, auditors, and insurers as necessary to obtain professional advice or protect our legal interests.
• Law Enforcement: Where required by law, court order, or to protect the rights, safety, or property of Comfora, its clients, employees, or the public.

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the successor entity, provided that the successor agrees to be bound by terms consistent with this Privacy Policy.

6. Data Security

We employ commercially reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, loss, theft, alteration, or destruction. These measures include, but are not limited to, encryption, secure servers, firewalls, access controls, staff training, and regular security assessments.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security and shall not be liable for any unauthorized access, breach, or loss of personal information except to the extent required by applicable law.

7. Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. In accordance with Ontario law, Personal Health Information is retained for a minimum of ten (10) years from the date of the last entry, or in the case of a minor, ten (10) years after the individual reaches the age of eighteen (18), whichever is later. After the applicable retention period, personal information is securely destroyed, erased, or de-identified.

Comfora reserves the right to retain de-identified or aggregated data indefinitely for analytical and business improvement purposes.

8. Your Rights

Subject to certain exceptions permitted by law, you have the right to:

• Request access to the personal information we hold about you.
• Request correction of inaccurate or incomplete personal information.
• Withdraw your consent to the collection, use, or disclosure of your personal information (subject to legal and contractual limitations).
• File a complaint with Comfora's Privacy Officer or with the Office of the Information and Privacy Commissioner of Ontario regarding the handling of your personal information.

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within thirty (30) days, or such other time period as required by applicable law. We may charge a reasonable fee for access requests that require significant effort to fulfill. We reserve the right to refuse access where permitted or required by law.

9. Cookies and Tracking Technologies

Our website uses cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity, improve website functionality, analyze traffic, and deliver targeted content. By continuing to use our website, you consent to the use of these technologies.

Types of cookies we use include:

• Essential Cookies: Required for the website to function properly.
• Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics).
• Marketing Cookies: Used to deliver relevant advertisements and track campaign performance.

You may disable cookies through your browser settings; however, doing so may affect the functionality and your experience on our website. Comfora is not responsible for any diminished functionality resulting from your choice to disable cookies.

10. Third-Party Links

Our website may contain links to third-party websites or services. Comfora is not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. Your interaction with third-party websites is at your own risk.

11. Children's Privacy

Our website is not directed to individuals under the age of sixteen (16). We do not knowingly collect personal information from children under 16 through our website. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it promptly. Where services are provided to minors, consent is obtained from a parent or legal guardian.

12. International Data Transfers

Your personal information may be stored or processed by third-party service providers located outside of Ontario or Canada. In such cases, your information may be subject to the laws of the jurisdiction in which it is stored or processed. We take reasonable steps to ensure that any such transfers are subject to appropriate safeguards; however, by using our services, you acknowledge and consent to the potential transfer of your personal information outside of Canada.

13. Changes to This Privacy Policy

Comfora reserves the right to modify, update, or replace this Privacy Policy at any time at our sole discretion. Changes will be posted on our website with a revised effective date. Your continued use of our website or services after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer:

• Email: info@comfora.ca
• Phone: 833-377-1234
• Address: 210-2030 Bristol Circle, Oakville ON L6H 0H2

You may also contact the Office of the Information and Privacy Commissioner of Ontario at www.ipc.on.ca if you have concerns about how your personal information is being handled.