Privacy Policy
Effective date: October 7, 2026
CareCircle provides a mental health practice platform and an invited client portal. This notice explains how personal information is handled during the beta. It should be read with the subprocessor list, retention policy, and data safety request process.
Who is responsible
The licensed professional or practice that invites a client is responsible for the clinical record and decisions about care, access, correction, and retention. In Ontario, that practice or professional may be a health information custodian under the Personal Health Information Protection Act (PHIPA); CareCircle acts on its instructions as a service provider and, where applicable, an agent. CareCircle is responsible for its own account, support, security, and business records. This split does not remove CareCircle's own privacy duties.
CareCircle's person responsible for the protection of personal information is Nicholas Ponari, Data Privacy Officer, nicholas@ponari.ca, 5150 Rue Buchan, Montréal, Québec H4P 0A9, Canada. For a clinical-record request, contact your practice first; if you cannot reach it, contact the Privacy Officer and we will route the request securely. Do not send clinical details in an ordinary email.
Information and purposes
| Information | Why it is used |
|---|---|
| Name, contact details, account credentials, role, and practice affiliation | Create accounts, verify identity, control access, send essential service notices, and support the account. |
| Appointment, intake, clinical note, file, message, and video-call information supplied by a practice or client | Enable the practice to deliver and coordinate mental health or clinical services. The practice determines the clinical purpose. |
| Invoice and payment status information | Help the practice bill, reconcile, and keep required financial records. |
| Device, session, security, and access records | Operate the service, investigate misuse, protect accounts, and diagnose failures. |
| Error reports from the web application, backend, and mobile app | Find and fix software faults. A report records what failed and where (the error, a redacted message, the page or screen, the app version, and the browser or device type), not who it happened to. |
| Support requests and feedback | Answer requests, investigate incidents, and improve the service. |
The portal may include optional wellness or AI features. Clinical or journal content must not be sent to OpenAI unless the practice and client have made an informed, separate opt-in for that feature. See subprocessors. CareCircle does not sell client health information or use it for behavioural advertising.
Where information goes
The current beta uses US-hosted services and may transfer personal and health information outside Canada and Québec. The web application and Convex backend are currently deployed through Vercel and Convex. Video, transactional email, and mobile notification services may also process information outside Canada, and error reports are sent to Sentry in the United States; see the subprocessor list for categories and known or unconfirmed locations. Foreign laws may permit access by authorities in those countries. Required transfer assessments, written safeguards, and provider-region verification must be completed before real client information is put into the beta; this notice alone does not satisfy those duties. We plan to move the Next.js application and self-hosted Convex backend to a sovereign VPS in Canada, preferably Québec. This is a plan, not a statement that the beta is already Canadian-hosted; other processors may still transfer data abroad after that move.
We share data only as needed with the practice, its authorized users, processors listed above, and others when directed by the practice or required by law. A practice is responsible for its own notices and client consent or other lawful authority to use CareCircle.
Security and retention
We use account authentication, role-based access controls, transport security, and security headers. No Internet service can promise absolute security. CareCircle does not claim end-to-end encryption for all data, SOC 2 certification, HIPAA compliance, or completed compliance with every Canadian law. Known beta gaps and implemented measures are listed in Security Practices. Retention depends on the type of record and the practice's professional duties; see Retention.
Your choices and rights
You may ask to access or correct information, withdraw a consent where consent is the basis for processing, and request deletion, de-indexing, portability, or information about disclosures where applicable law provides those rights. Clinical record requests go to the practice first because it controls the record. CareCircle will help the practice respond, and will handle requests concerning records it controls. Some information must be kept under professional, tax, or legal obligations. We will verify identity before releasing sensitive information and explain any refusal or delay. Clients can export their data and delete their account themselves in Settings; see Data Safety for how that works and for the manual process that covers every other request.
Applicable laws may include the federal Personal Information Protection and Electronic Documents Act (PIPEDA), Québec's private-sector privacy law as amended by Law 25, Ontario's PHIPA, and the Personal Information Protection Act (PIPA) in British Columbia or Alberta. Which law applies depends on the practice, province, information, and transaction. Listing these laws is not a claim of certification or blanket compliance.
Questions and complaints
Raise a clinical-record concern with your practice first. For CareCircle handling, contact Nicholas Ponari at nicholas@ponari.ca or the postal address above. If the issue remains unresolved, you may contact the appropriate regulator: the Office of the Privacy Commissioner of Canada (OPC), the Commission d'accès à l'information du Québec (CAI), or the Information and Privacy Commissioner of Ontario (IPC) for Ontario PHIPA matters. A provincial privacy commissioner may also be appropriate in British Columbia or Alberta. The regulator with jurisdiction depends on the facts; you do not need CareCircle's permission to contact one.
We will post material changes to this notice before they take effect and seek a new choice where the law requires it.