Inaya Care — Virtual Psychotherapy for South Asian Families | Ontario Privacy Policy — Inaya Care

Privacy Policy

Hussain Psychotherapy Professional Corporation
Effective Date: April 16, 2026  ·  Last Revised: April 16, 2026
Privacy Officer: Zain Hussain, RP (Qualifying)  ·  [email protected]
01

About This Policy

This Privacy Policy describes how Hussain Psychotherapy Professional Corporation, operating as Inaya Care ("Inaya Care," "we," "our," or "us"), collects, uses, discloses, retains, and protects personal information and personal health information in connection with the delivery of virtual psychotherapy services in Ontario, Canada.

This policy applies to all individuals who interact with Inaya Care, including prospective clients, active clients, and visitors to our website at inayacare.ca. By engaging with our services or website, you acknowledge that you have read and understood this policy.

02

About Inaya Care

Inaya Care is a virtual group psychotherapy practice operating under Hussain Psychotherapy Professional Corporation (Certificate of Authorization No. CA1516-701, issued by the College of Registered Psychotherapists of Ontario). We provide culturally attuned, faith-sensitive psychotherapy to South Asian individuals and families across Ontario, delivered entirely through secure virtual platforms.

Zain Hussain, Registered Psychotherapist (Qualifying), serves as Founder and Director and Privacy Officer. All clinical services are delivered by regulated health professionals registered with either the College of Registered Psychotherapists of Ontario (CRPO) or the Ontario College of Social Workers and Social Service Workers (OCSWSSW).

03

Legislative Framework

Inaya Care operates in compliance with the following legislation:

  • Personal Health Information Protection Act, 2004 (PHIPA) — governs the collection, use, and disclosure of personal health information by health information custodians in Ontario.
  • Personal Information Protection and Electronic Documents Act (PIPEDA) — governs personal information collected through our website and electronic communications.
  • Regulated Health Professions Act, 1991 (RHPA) — governs the professional obligations of regulated health professionals at Inaya Care.
  • Canada's Anti-Spam Legislation (CASL) — governs electronic commercial messages and SMS communications.
04

Who This Policy Applies To

This policy applies to:

  • Prospective clients who submit an inquiry through our website, Meta lead forms, or by contacting us directly.
  • Active clients receiving psychotherapy services through Inaya Care.
  • Visitors to our website at inayacare.ca.

This policy does not apply to independent contractor clinicians associated with Inaya Care, whose information is governed by their respective Independent Contractor Agreements and applicable professional regulations.

05

What Information We Collect

5.1 — Clinical Information (Active Clients)

Once you become an active client, we collect personal health information necessary to provide psychotherapy services, including:

  • Full name, date of birth, and contact information
  • Presenting concerns, mental health history, and relevant medical background
  • Session notes, treatment plans, and clinical assessments
  • Insurance and benefits information where applicable
  • Emergency contact details

5.2 — Inquiry and Lead Information (Prospective Clients)

When you inquire about our services through our website, a Meta lead form, or by contacting us directly, we collect:

  • Name, email address, and phone number
  • General reason for seeking therapy (as voluntarily provided)
  • Preferred clinician or service type
  • How you heard about Inaya Care

Inquiry data collected prior to becoming an active client is stored in our client relationship management system (GoHighLevel) and is not stored in our clinical records system (Jane App). Once you become an active client, your inquiry data in GoHighLevel is either deleted or retained only in de-identified form. Clinical records are maintained exclusively in Jane App.

5.3 — Website Data

When you visit inayacare.ca, we may automatically collect technical data including IP address, browser type, pages visited, and time spent on the site. This data is collected through cookies and the Meta Pixel (see Section 12).

06

How We Collect Information

We collect information through the following means:

  • Intake forms completed through Jane App (our electronic health record platform)
  • Meta lead generation forms on Facebook and Instagram
  • Direct contact via phone, email, or our website contact form
  • Consultation calls conducted by our operations team
  • Session notes and clinical documentation completed by your clinician
  • Cookies and tracking technologies on our website (see Section 12)
07

How We Use Your Information

7.1 — Clinical Purposes

Personal health information collected from active clients is used to:

  • Provide psychotherapy and related clinical services
  • Develop and maintain treatment plans
  • Coordinate care with other healthcare providers where authorized by you
  • Fulfill legal and professional obligations under PHIPA and CRPO/OCSWSSW standards
  • Provide official receipts for insurance reimbursement

7.2 — Administrative and Operational Purposes

Personal information is also used to:

  • Schedule and confirm appointments
  • Process payments and issue receipts
  • Communicate with you about your care
  • Respond to inquiries and follow up with prospective clients
  • Maintain records as required by law

7.3 — Marketing Purposes (Prospective Clients Only)

With your consent, inquiry data may be used to send follow-up communications about Inaya Care's services. You may withdraw consent to marketing communications at any time by replying STOP to any SMS or contacting us at [email protected]. We do not use clinical records for marketing purposes.

08

Independent Contractor Clinicians

Important — Custodianship Notice

Each clinician at Inaya Care is an independent contractor, not an employee. Under PHIPA, the health information custodian for your clinical records may be your treating clinician individually, Hussain Psychotherapy Professional Corporation, or both, depending on the specific circumstances. All clinicians at Inaya Care are bound by their Independent Contractor Agreements to maintain PHIPA-compliant records practices and to use only Corporation-approved systems for the storage and transmission of personal health information.

All clinicians associated with Inaya Care are registered with either CRPO or OCSWSSW and carry their own professional liability insurance. They are bound by the confidentiality obligations of their respective regulatory colleges in addition to the terms of their agreements with Inaya Care.

Clinical records are maintained in Jane App, which is used as the shared electronic health record platform for all clinicians operating under the Certificate of Authorization.

09

Disclosure of Information

We do not sell, rent, or trade your personal information or personal health information to any third party. We disclose your information only in the following circumstances:

  • With your consent — for example, to communicate with your family doctor or another healthcare provider
  • As required by law — including mandatory reporting obligations under Ontario law (duty to report, duty to warn)
  • To service providers — including Jane App and GoHighLevel, who process data on our behalf under confidentiality obligations (see Section 10)
  • In a medical emergency — to prevent serious harm to you or others
  • To our legal counsel — where required for the defence of a legal claim

We do not communicate your clinical information to your family doctor or any other healthcare provider without your explicit consent, except where required by law. If you wish to authorize communication with your family doctor, you will be asked to sign a written release of information.

10

Data Processors & Third-Party Platforms

Inaya Care uses the following third-party platforms to operate our services. Each platform processes data only as directed by us and is subject to confidentiality obligations:

Jane App

Electronic health record, scheduling, intake forms, and session billing. Canadian platform built for regulated health professionals. PHIPA-compliant. All clinical records stored exclusively here.

GoHighLevel

CRM for prospective client inquiries and pre-intake communications only. US-based platform. No clinical records or personal health information stored here.

Meta Platforms (Facebook/Instagram)

Lead generation through Meta lead forms. Meta's data practices are governed by Meta's own Privacy Policy. No clinical information is shared with Meta.

Wagepoint

Contractor payment processing for clinicians. Wagepoint does not process client personal information.

11

Cross-Border Data Transfers

Cross-Border Transfer Disclosure

GoHighLevel is a US-based platform. Inquiry data submitted by prospective clients and pre-intake communications may be stored on servers located outside Canada, including in the United States. This data is subject to the laws of the United States, including laws that may permit access by US government authorities. No clinical records or personal health information is transferred outside Canada. All clinical data remains within Jane App's Canadian infrastructure.

Meta Platforms, Inc. is also a US-based company. Data submitted through Meta lead forms is subject to Meta's Privacy Policy and may be processed on servers outside Canada.

By submitting an inquiry through our website or a Meta lead form, you consent to the transfer of your pre-intake inquiry data to GoHighLevel's US-based infrastructure for the purpose of follow-up communications about our services.

12

Website Data, Cookies & Meta Pixel

Our website at inayacare.ca uses cookies and similar tracking technologies to understand how visitors interact with our site. You may control cookie settings through your browser.

We use the Meta Pixel (Pixel ID: 795585630290719) on our website. The Meta Pixel is a piece of code that allows us to measure the effectiveness of our Facebook and Instagram advertising by tracking actions taken on our website, such as visiting a page or submitting a form. The Meta Pixel may collect your IP address, browser information, and pages visited, and transmit this data to Meta Platforms, Inc.

The Meta Pixel does not collect clinical information and is not connected to our electronic health record system. If you prefer not to be tracked by the Meta Pixel, you may opt out through Meta's Ad Preferences or use a browser extension that blocks tracking pixels.

13

SMS & Electronic Communications

By submitting your phone number through our website or a Meta lead form, you consent to receive SMS text messages from Inaya Care regarding your inquiry, appointment scheduling, and follow-up communications. Message and data rates may apply depending on your carrier and plan.

You may withdraw consent to SMS communications at any time by replying STOP to any message you receive from us. Once you opt out, you will receive a single confirmation message and no further SMS communications will be sent.

Our SMS communications are transmitted through GoHighLevel's messaging infrastructure and are subject to applicable A2P (Application-to-Person) messaging regulations in Canada and the United States.

14

Retention & Destruction of Records

We retain personal health information in accordance with CRPO record-keeping standards and applicable Ontario law:

  • Adult client records — retained for a minimum of 10 years from the date of the last professional service, or 10 years from the date the client turns 18, whichever is later.
  • Minor client records — retained until the client turns 18, plus an additional 10 years.
  • Pre-intake inquiry data (GoHighLevel) — retained for a maximum of 12 months from the date of inquiry if the individual does not become an active client, then deleted.
  • Website analytics data — retained in accordance with the data retention policies of the respective platforms.

When records reach the end of their retention period, they are destroyed securely. Electronic records are permanently deleted and physical records are cross-shredded.

15

Minimum Age

Inaya Care's services are intended for individuals 16 years of age and older. We do not knowingly collect personal information from children under the age of 16 without the consent of a parent or legal guardian.

If a prospective client is under the age of 16, we require written parental or guardian consent prior to the commencement of services. If you believe we have inadvertently collected information from a child under 16 without appropriate consent, please contact us immediately at [email protected].

16

Privacy Breach Notification

PHIPA Requirement

PHIPA requires health information custodians to notify affected individuals and the Information and Privacy Commissioner of Ontario (IPC) in the event of a privacy breach involving personal health information.

A privacy breach occurs when personal information is collected, used, or disclosed in a manner not authorized by PHIPA, or when information is stolen, lost, or accessed by an unauthorized person.

In the event of a privacy breach, Inaya Care will:

  • Contain and investigate the breach as quickly as possible
  • Notify affected individuals if the breach creates a real risk of significant harm
  • Notify the Information and Privacy Commissioner of Ontario (IPC) where required by law
  • Document the breach and corrective steps in our incident and compliance log
  • Take corrective steps to prevent a recurrence

If you believe your personal health information has been improperly accessed or disclosed, contact our Privacy Officer immediately at [email protected] or 437-292-4738.

17

Your Rights

Subject to applicable law, you have the following rights with respect to your personal information:

  • Right to access — you may request a copy of the personal information we hold about you
  • Right to correction — you may request that we correct inaccurate or incomplete information
  • Right to withdraw consent — you may withdraw consent at any time, subject to legal obligations that may require us to retain certain records
  • Right to lodge a complaint — you have the right to file a complaint with the Information and Privacy Commissioner of Ontario
18

Accessing & Correcting Your Information

To request access to or correction of your personal information, submit a written request to our Privacy Officer at [email protected]. We will respond within 30 days. There is no fee for submitting an access request, though a reasonable fee may apply for complex requests after prior notice.

19

Complaints

If you have a concern about how Inaya Care has handled your personal information, please first contact our Privacy Officer:

Zain Hussain, RP (Qualifying)

Privacy Officer, Inaya Care

Email: [email protected]

Phone: 437-292-4738

If you are not satisfied with our response, you may file a complaint with the Information and Privacy Commissioner of Ontario:

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8

Phone: 416-326-3333  |  Toll-free: 1-800-387-0073

Website: www.ipc.on.ca

20

Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. The most current version will always be available at inayacare.ca/privacy-policy. Material changes will be communicated to active clients by email.

21

Contact Us

For any questions or requests related to this Privacy Policy:

Inaya Care — Hussain Psychotherapy Professional Corporation

Privacy Officer: Zain Hussain, RP (Qualifying)

Email: [email protected]

Phone: 437-292-4738

Website: inayacare.ca

Certificate of Authorization: CA1516-701