Privacy policy

Summary of key points

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use.

Do we process any sensitive personal information? Yes. When you choose to provide your ethnicity or faith orientation under “communities served,” we process this information only with your express consent. You may withdraw this consent at any time.

Do we collect any information from third parties? We do not collect any information from third parties.

Do we collect client or patient health information? No. The Therapist Referral Network collects information about therapists only. Referral requests describe client needs in general terms (presenting issue, age group, location) that are not personally identifiable under PIPEDA. We do not collect, store, or process any client or patient health information.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

Do our emails contain information about affiliated services? Yes. Referral notification emails include a section with information about Curio (curio.health) and Quitewell (quitewell.marketing), affiliated services that provide tools for therapist practices. This content is informational and incidental to the primary transactional purpose of the email. We do not send standalone marketing emails without separate consent.

1. What information do we collect?

Personal information you provide to us

We collect personal information that you voluntarily provide to us when you register on the Services, create or update your therapist profile, post referral requests, or otherwise contact us.

Account and identity information. When you create an account, we collect:

• Name
• Email address (via Google OAuth)
• Country (used to determine service availability)

Professional profile information. When you create your therapist profile, we collect:

• Display name, first name, middle name, and last name
• Professional bio
• Pronouns and gender
• Profile image
• Credentials and licensing level (e.g., Registered Psychotherapist, Supervised Practice)
• Primary credential designation
• Specialties and presenting issues you treat
• Therapeutic approaches (e.g., CBT, EMDR, psychodynamic)
• Modalities offered (in-person, virtual, phone)
• Location (city, province)
• Website URL and Psychology Today profile URL
• Contact email
• Languages spoken
• Age groups served
• Participants served (individual, couples, family, group)
• Therapy style preferences
• Insurance accepted, specific insurers, and direct billing availability
• Payment methods accepted
• Session rates (individual, couples, family, group)
• Pro bono and reduced fee availability
• Whether you are currently accepting clients
• Free consultation availability

Referral request information. When you post a referral request, we collect:

• Presenting issue
• Age group
• City and province
• Preferred modalities
• Insurance requirement
• Participant type
• Rate preference
• Therapist gender preference
• Preferred therapy types
• Preferred languages
• Additional context (free text)

Note: referral request fields describe the general needs of a referral and are not personally identifiable under PIPEDA. They do not constitute personal information about the client being referred. The “additional context” field accepts free text — therapists should not include client names or other personally identifying information in this field. We do not use free-text content for purposes beyond referral matching.

Waitlist information. If you are located in the United States, we collect your email address to notify you when the service becomes available in your region.

Sensitive personal information

See Section 2 below for detailed information about how we handle sensitive personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies, subject to your consent. You can find out more about this in our cookie policy.

The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services. This may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches, and other actions you take).
• Device data. Information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider, operating system, and system configuration information.
• Activity data. We track when you last used the platform to prioritize active profiles in referral matching. This timestamp is not displayed to other users.

What happens when you consent to analytics cookies

If you consent to analytics cookies via our cookie consent banner, the following technical data is shared with Google Analytics and PostHog for product improvement purposes:

• IP address (GA4 truncates before storage, but Google receives the full IP for geolocation processing)
• Client ID cookie (_ga — a pseudonymous identifier tied to browsing behavior)
• Device and browser identifiers (user agent, screen resolution, language, operating system)
• Browsing behavior (page views, clicks, events, session duration)

No therapist profile data is sent to analytics processors. Google Analytics and PostHog receive only technical and behavioral data from users who have opted in. We do not include therapist names, emails, or other profile identifiers in analytics events or URL parameters.

These services process data in the United States under their own privacy policies: Google Privacy & Terms, PostHog Privacy Policy.

2. Sensitive personal information

When you create your therapist profile, you may optionally provide:

• Ethnicity — the cultural or ethnic communities you serve
• Faith orientation — the faith communities you serve

This information is classified as sensitive personal information under PIPEDA because it may reveal racial or ethnic origins and religious or philosophical beliefs.

Why we collect it. This data enables culturally matched referrals between therapists — helping referring therapists find colleagues who serve specific communities.

It is optional. These fields are not required to use the platform. You can create a full profile and receive referral matches without providing communities served information.

Express consent required. We collect this data only with your express consent, provided via a separate, dedicated checkbox — not bundled with the general Terms of Service or Privacy Policy agreement. This checkbox appears adjacent to the ethnicity and faith orientation fields when you fill them in.

Withdrawal of consent. You can withdraw your consent at any time from your profile settings. When you withdraw consent:

• Your communities served data is removed from your public profile immediately
• The underlying data (ethnicity and faith orientation fields) is deleted immediately — not retained, not archived
• Your ability to use all other platform features is unaffected

On account closure. If you delete your account, all communities served data is deleted immediately regardless of consent status. There is no retention period for sensitive data.

Reclassification note. We frame ethnicity and faith orientation as populations you serve rather than personal identity attributes. However, because the Office of the Privacy Commissioner of Canada (OPC) may treat this as a proxy for personal identity, we apply express consent and independent withdrawability as safeguards.

3. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts
• To provide referral matching by comparing referral request criteria against therapist profiles based on specialties, location, language, modalities, and (where consent is given) communities served
• To send referral notifications by email via Resend when your profile matches a referral request
• To send fulfillment check emails to track whether referrals were successfully completed
• To maintain the directory by displaying your therapist profile to other registered therapists
• To improve our Services through analytics and product usage data (only with your cookie consent)
• To respond to your inquiries and provide customer support
• To protect our Services through security monitoring, fraud prevention, and abuse detection
• To comply with legal obligations including privacy law requirements and breach notification duties

4. What legal bases do we rely on to process your information?

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

How consent works on our platform:

We may be authorized by law to process your information without your consent in some exceptional cases, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If the information is publicly available and is specified by the regulations

5. When and with whom do we share your personal information?

We may need to share your personal information with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We establish data processing agreements with our third parties, which are designed to help safeguard your personal information. These agreements require that third parties cannot do anything with your personal information unless we have instructed them to do it, will not share your personal information with any organization apart from us, and commit to protect the data they hold on our behalf and to retain it for the period we instruct.

We remain accountable for your personal information even when it is processed by these third parties, in accordance with PIPEDA Principle 4.1.

We also may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

6. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services.

Essential cookies are required for the platform to function (authentication, session management) and are active by default.

Analytics cookies (Google Analytics, PostHog) are blocked by default and only activated when you provide express consent via our cookie consent banner. You can change your cookie preferences at any time using the cookie preferences link in our site footer, or through your account settings when logged in.

For more details, see our cookie policy.

7. How do we handle your social logins?

Our Services offer you the ability to register and log in using your Google account. Where you choose to do this, we will receive certain profile information about you from Google. The profile information we receive includes your name and email address.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by Google. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information.

8. Is your information transferred internationally?

Our application is deployed on Vercel (United States) and our database is hosted on Supabase (United States). All third-party processors listed in Section 5 are located in the United States.

If you are a resident of Canada, please be aware that your personal information is transferred to, stored by, and processed in the United States. The United States may not have data protection laws as comprehensive as those in Canada. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law, including:

• Entering into data processing agreements (DPAs) with all processors that handle personal information
• Requiring that processors maintain appropriate security safeguards (encryption at rest and in transit, access controls)
• Remaining accountable for your personal information under PIPEDA Principle 4.1, regardless of where it is processed

9. How long do we keep your information?

While your account is active

After you delete your account

Backup retention

Deleted data may persist in encrypted Supabase database backups for 7 to 30 days (depending on our plan tier) before automatic rotation removes it. During this period, backups are encrypted (AES-256) and are not selectively restored. We do not recover deleted personal information from backups unless legally compelled to do so.

Anonymization standard

When we anonymize data (for example, referral history for aggregate analytics), we follow the standard established by the Office of the Privacy Commissioner of Canada: there must be no serious possibility that the information can be re-identified, either alone or in combination with other available information. We aggregate data across multiple records and remove all direct and indirect identifiers.

10. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process, including:

• Encryption at rest (AES-256) and in transit (TLS)
• Access controls and authentication
• Server-side access controls on all database queries
• Audit logging for sensitive data access and consent changes
• SOC 2 Type 2 compliant infrastructure (Supabase)

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age. The Therapist Referral Network is designed for licensed therapists and therapists in supervised practice. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hi@therapistreferralnetwork.com.

12. What are your privacy rights?

Under PIPEDA and applicable provincial privacy legislation, you have the following rights:

Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent by:

• Updating your profile settings (for communities served consent)
• Using the cookie preferences link in the site footer or your account settings (for analytics cookies)
• Deleting your account (for all profile data processed under implied consent — see Section 18)
• Contacting us at hi@therapistreferralnetwork.com (for any other consent)

Please note that withdrawing consent will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications. We do not send standalone marketing or promotional emails without separate consent. All referral notification emails are transactional. If we ever introduce optional marketing communications, you will be able to unsubscribe at any time by clicking the unsubscribe link in those emails.

Account information. If you would like to review or change the information in your account, or terminate your account, you can log in to your account settings and update your profile or request account deletion. Upon your request to terminate your account, we will deactivate or delete your account and information according to the retention schedule described in Section 9.

Complaints and challenges. If you are dissatisfied with how we handle your personal information or respond to your privacy requests, you may:

1. Contact us at hi@therapistreferralnetwork.com to file a complaint. We will investigate and respond to your complaint.
2. If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca/en/report-a-concern.

13. Affiliated service communications

Referral notification emails sent by the Therapist Referral Network may contain a clearly delineated section with information about affiliated services:

• Curio (curio.health) — email encryption for therapist practices
• Quitewell (quitewell.marketing) — marketing tools for therapist practices

This content is informational and incidental to the primary transactional purpose of the email (delivering a referral match you signed up to receive). The sponsor section is separated from referral content and does not exceed a minor portion of the email.

The platform does not send standalone marketing emails promoting affiliated services without your separate, express consent. If we ever introduce such communications, we will provide a separate opt-in mechanism and include an unsubscribe option in every email, in compliance with Canada's Anti-Spam Legislation (CASL).

14. Breach notification

In the event of a breach of security safeguards involving your personal information that creates a real risk of significant harm, we will:

• Notify the Office of the Privacy Commissioner of Canada (OPC) as soon as practicable
• Notify you as soon as practicable, describing the nature of the breach, the personal information involved, the steps we have taken to reduce the risk of harm, and the steps you can take to protect yourself
• Maintain a record of the breach for 24 months, as required by PIPEDA

A “breach of security safeguards” means the loss of, unauthorized access to, or unauthorized disclosure of personal information resulting from a breach of our security safeguards or a failure to establish those safeguards.

15. Controls for do-not-track features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

16. Do we make updates to this notice?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Last updated” date at the top of this privacy policy. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

This policy is drafted to meet federal PIPEDA requirements. As we expand to additional provinces, we will update this policy to address applicable provincial privacy legislation.

17. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hi@therapistreferralnetwork.com or contact us by post at:

Gabriel Borges
Toronto, Ontario
Canada

Privacy accountability. Gabriel Borges is responsible for our privacy compliance practices and can be reached at the contact information above.

18. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

To review or update your personal information, log in to your account settings. To request account deletion or to exercise any other privacy right, please contact us at hi@therapistreferralnetwork.com. We will respond to all requests within 30 days.