EVOLVE
Privacy Policy
EVOLVE Physiotherapy Ltd. • Effective date: 06 September 2026
At EVOLVE Physiotherapy Ltd. (“EVOLVE,” “we,” “us,” or “our”), protecting the personal information of our clients and Program participants is one of our priorities. This policy explains what personal information we collect, why we collect it, how we use and protect it, and the choices and rights available to you. By checking the agreement box provided when you create your account, you acknowledge that you have been provided, have read, and agree to this Policy.
1. Scope of this Policy
This Policy applies to EVOLVE's collection, use, and disclosure of personal information in connection with our clinical services and our educational programs ("Programs"), and to service providers who collect, use, or disclose personal information on our behalf. EVOLVE is based in British Columbia and is subject to British Columbia's Personal Information Protection Act (PIPA). Because our Programs are offered to participants across Canada, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) may also apply to certain interprovincial or international activities involving personal information, and other privacy laws may apply depending on the circumstances. Where more than one privacy law applies, we aim to meet whichever standard offers you greater protection.
2. Definitions
Personal Information means information about an identifiable individual, such as name, contact details, age, education, and employment information. It does not include Contact Information.
Contact Information means information that would let us reach you at a place of business, such as your name, title, business phone number, business address, or business email, and is not covered by this Policy.
Privacy Officer means the individual responsible for EVOLVE's compliance with this Policy and applicable privacy law.
3. What We Collect and Why
We collect personal information necessary for the following purposes: to verify your identity; to open and manage your account; to process registration and payment for a Program; to enroll you and provide you with Program materials and mentorship; to communicate with you about a Program you're enrolled in; to issue certificates of completion; to maintain a high standard of service; to meet regulatory or legal requirements; and, where you have separately consented, to contact you about future Programs.
4. Consent
4.1 We collect, use, and disclose personal information only with your consent, except where we're permitted or required by law to do so without it.
4.2 Consent may be express or implied, including where you voluntarily provide information for a purpose that is obvious in the circumstances.
4.3 Consent to this Privacy Policy is separate from consent to receive marketing communications. We ask for marketing consent separately, as described in section 9.
4.4 You may withdraw consent for certain uses of your personal information, subject to legal and contractual restrictions; doing so may limit our ability to provide you with a Program or service, which we will explain if it applies.
5. How We Use and Disclose Personal Information
We use and disclose personal information to fulfill the purposes described above, or a reasonably related purpose, such as improving our Programs based on participant feedback. We do not sell personal information or participant lists, and we do not disclose personal information to third parties for their own marketing purposes.
6. We May Collect, Use or Disclose Personal Information Without Consent
In limited circumstances permitted by law, including: where required or permitted by law; in an emergency that threatens someone's life, health, or personal security; where the information is available from a public source; where we need legal advice; to collect a debt owed to us; to protect against fraud; or to investigate a suspected breach of an agreement or contravention of law.
7. Service Providers and Cross-Border Processing
7.1 We use Thinkific Labs Inc. (“Thinkific”) to host and deliver our Programs, and third-party payment processors (such as Stripe) to process payments. In relation to the personal information you provide through these services, EVOLVE is the organization responsible for that information, and Thinkific and our payment processors act as our service providers, processing personal information on our instructions and for our purposes.
7.2 Thinkific's infrastructure providers store and process personal information in the United States. This means your personal information is stored and processed outside Canada, and may be accessible to courts, law enforcement, and regulatory authorities in the United States under that country's laws. Our payment processors may also store or process information outside Canada. We take reasonable steps to require our service providers to protect personal information to a standard comparable to this Policy, including through contractual commitments such as standard contractual clauses.
7.3 You can find more information about Thinkific's own privacy and data practices, including its subprocessors, at thinkific.com/privacy-policy, thinkific.com/dpa, and thinkific.com/thinkificsubprocessors.
8. Session Recordings
Live Program sessions, including mentorship sessions, may be recorded, with reasonable advance notice, and made available to participants enrolled in that Program for a limited period. Recordings are retained only as long as reasonably necessary for that purpose and are subject to the access and use restrictions in our Terms of Use & Participant Agreement.
9. Marketing Communications
We will only send you marketing communications about future Programs if you have separately opted in, which you may do at registration or afterward. You can withdraw this consent, and unsubscribe from marketing communications, at any time. This is separate from operational communications about a Program you're enrolled in, which we send as part of delivering that Program.
10. Cookies and Analytics
Our website and the Platform may use cookies and similar technologies to operate the site and understand how it's used. You can control cookies through your browser settings; disabling them may affect site functionality.
11. Retention
We retain personal information only as long as necessary to fulfill the purposes it was collected for, or as required by law. Where we use personal information to make a decision that directly affects you, we retain it for at least one year afterward so you have a reasonable opportunity to request access to it.
12. Accuracy
We take reasonable steps to keep personal information accurate and complete where it may be used to make a decision about you or disclosed to another organization. You may ask us to correct your personal information by writing to our Privacy Officer with enough detail to identify the information and the correction sought.
13. Security and Breach Response
13.1 We protect personal information using reasonable security measures appropriate to its sensitivity, including access controls limiting personal information to staff and service providers who need it, and contractual security requirements for our service providers.
13.2 We securely destroy or anonymize personal information when it's no longer needed, and review our security practices as technology and risks change.
13.3 If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the appropriate privacy regulator, and keep a record of the breach, as required by applicable law.
14. Access and Correction
14.1 You have the right to access your personal information, subject to limited exceptions, such as where disclosure would reveal personal information about another individual.
14.2 To request access, write to our Privacy Officer with enough detail to identify the information you're seeking. We will respond within 30 days, or provide written notice if we need more time.
14.3 A minimal fee may apply for providing access; we will tell you the cost in advance and confirm you'd like to proceed.
14.4 If we refuse a request in full or in part, we will explain why in writing and describe the recourse available to you.
15. Questions and Complaints
Our Privacy Officer is responsible for EVOLVE's compliance with this Policy and applicable privacy law. Direct any questions, concerns, or complaints about this Policy, or our handling of your personal information, in writing, to our Privacy Officer at [email protected]. If we're unable to resolve your concern, you may also contact the Office of the Information and Privacy Commissioner for British Columbia.
16. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices or the law. We will post the updated Policy with a new effective date, and where a change is material, we will take reasonable steps to bring it to your attention.