Privacy Policy

Effective date: July 2026

DRAFT — for legal review. Not yet legal advice. This policy is a working draft and must be reviewed by a Canadian health-privacy lawyer before it is relied on.

1. Who we are, and who holds your health records

Curalia is operated by Tigris Guardians Inc. (“Curalia”, “we”, “us”). Curalia is a technology platform that lets patients in Ontario book and attend virtual (video or voice) minor-ailment consultations with licensed pharmacists at partner pharmacies.

Under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA), each partner pharmacy — not Curalia — is the health information custodian of your clinical information. Curalia acts as the pharmacy’s electronic service provider and agent: we provide the technology (booking, secure video, messaging, records infrastructure) on the pharmacy’s behalf and under its direction. Your clinical care is provided by the pharmacy and its pharmacists, who remain responsible for your health records under their professional and college rules.

2. What we collect

Account information: your name, email address, and contact details.
Location and province: to show nearby partner pharmacies and to confirm you are in Ontario at the time of a consultation (you attest to this before each visit).
Health-card verification (masked): we never store your full health-card number. Only a masked form (the last 3 digits) is kept, so the pharmacy can match your record. The pharmacist verifies your physical health card with you on the video call.
Booking and consultation details: the reason for your visit, appointment times, the pharmacy and pharmacist you saw, and any information you choose to share for your consultation (for example, current medications — sharing them is optional, though it helps the pharmacist review your safety).
Consent records: your virtual-care consent and in-province attestation, captured each visit.
Technical information: device and app data needed to run the service securely (for example, sign-in events and audit logs).

3. Why we collect it

To let you find a pharmacy, book a consultation, and connect by secure video or voice.
To let the pharmacy identify you, verify your health card, and provide your care.
To notify you about your appointments and prescriptions. Push notifications never contain health information.
To keep the service safe: we keep audit logs of all clinical and role-based actions so that access to records can be reviewed.
To meet legal obligations, including PHIPA obligations owed to the custodian pharmacies.

We do not sell your data. We do not use your health information for advertising. We do not share your information with data brokers.

4. Where your data lives — Canada only

All Curalia data — databases, application services, and file storage — is stored and processed in Google Cloud’s northamerica-northeast1 region in Montréal, Canada.

Video and voice consultations run on Curalia’s own self-hosted media server in Montréal. Your call media never leaves Canada, and calls are not recorded — by us or by the platform.

All data is encrypted in transit (TLS for app traffic; DTLS-SRTP for call media) and encrypted at rest (AES-256).

5. Who can see your information

Your pharmacy: staff at the partner pharmacy you book with can see the records they need to care for you. Access is enforced so that pharmacy staff can only see records belonging to their own pharmacy.
Curalia: as the pharmacies’ service provider, our access is limited to what is needed to operate, support, and secure the platform, and all such access is subject to audit logging.
No one else, except where the law requires disclosure.

6. How long we keep it

Platform data (your account, bookings, and consents) is kept while your account is active. Clinical records created by the pharmacy are retained by the pharmacy in accordance with Ontario College of Pharmacists record-keeping requirements — those retention periods are set by the pharmacy as custodian, not by Curalia. [TODO: confirm specific platform retention periods with legal counsel.]

7. Your rights

Access and correction: you may request access to, or correction of, your personal health information. Because the pharmacy is the custodian of your clinical records, we will route clinical-record requests to the pharmacy; we will help with any platform-held data directly.
Deletion: you can delete your account at any time from within the app. When you do, your platform data is purged and your past appointments are anonymized. The pharmacy retains its own clinical records as required by its college rules — Curalia cannot delete records the pharmacy is legally required to keep.
Withdraw consent: you may withdraw your consent to virtual care at any time before or during a consultation.
Complaints: you may complain to us, to the custodian pharmacy, or to the Information and Privacy Commissioner of Ontario (IPC).

8. If something goes wrong

If personal health information is lost, stolen, or accessed without authority, we will contain the incident, notify the affected custodian pharmacies without delay, and support them in notifying affected patients and, where required, the Information and Privacy Commissioner of Ontario, as PHIPA requires. We maintain a written breach-response protocol.

9. Not for emergencies

Curalia is not for medical emergencies. If your symptoms are severe, call 911 or go to the nearest emergency department.

10. Contact

Privacy contact: contact@tigris-guardians.com
Tigris Guardians Inc., [TODO: corporate address]

Information and Privacy Commissioner of Ontario: www.ipc.on.ca

11. Changes to this policy

If we make material changes, we will post the updated policy here and update the effective date above.