Version:     1.0

     Date of Publication:     June 12, 2026

     Effective Date:     March 24, 2026

     Issued by:     Privacy & Compliance Officer

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Table of Contents

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• 1. Introduction
• 2. Scope and Applicability
• 3. Definitions
• 4. Regulatory Requirements
• 5. Policies
• 6. Procedures
• 7. Roles and Responsibilities
• 8. Documentation and Record-Keeping
• 9. Monitoring and Reporting
• 10. Training and Awareness
• 11. Risk Management
• 12. Audits and Reviews
• 13. Corrective Actions
• 14. Penalties and Sanctions
• 15. Continuous Improvement
• 16. Appendices

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1. Introduction

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1.1 Purpose

This document outlines the Terms & Conditions and Privacy Policy ("Terms") governing the use of the July Health Inc. website, its content, and any associated services. Its purpose is to establish a legally binding agreement between July Health Inc. and all individuals who access or use our online platforms, and to outline the principles and procedures we follow to protect the privacy of individuals whose Personal Information is collected, used, and disclosed through their interaction with our website.

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1.2 Context

As a provider of outpatient care, mental health, and miscellaneous health practitioner services across all Canadian provinces and territories, July Health Inc. handles Personal Information and, in the context of direct service delivery, Personal Health Information. It is essential to have clear, enforceable terms and a robust privacy framework to protect the Company, its intellectual property, and its users. These Terms ensure that all parties understand their rights, obligations, and the rules of engagement when interacting with our digital properties, and build trust by ensuring legal compliance and transparency in our data handling practices.

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1.3 Objectives

• To define the permissible uses of the Company's website and content.
• To be transparent with individuals about what Personal Information we collect, why we collect it, and how it is used and protected.
• To ensure all Personal Information collected through our website is managed in accordance with Canadian privacy laws.
• To outline user responsibilities, conduct, and our disclaimers of warranties and limitations of liability.
• To provide a clear framework for individuals to access their information, resolve disputes, and address privacy-related concerns.

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2. Scope and Applicability

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2.1 Scope

These Terms apply to all aspects of the July Health Inc. website, including but not limited to all text, graphics, data, services, and other content available on or through the website. The geographical scope of these Terms is all of Canada.

This policy also applies to all Personal Information collected, used, or disclosed by July Health Inc. from individuals who interact with our website, regardless of their location within Canada. This includes information collected through contact forms, newsletter sign-ups, cookies, and other web technologies.

This policy's scope is distinct from, but complementary to, policies governing data collected during the provision of direct health services. For specific details on the handling of Personal Health Information collected for therapeutic purposes, users who become clients must refer to the relevant consent form provided at the start of service.

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2.2 Applicability

These Terms are applicable to all persons who access, browse, or use the July Health Inc. website, including casual visitors, registered users, and paying customers ("Users"). By accessing or using the website, you agree to be bound by these Terms.

This policy is also binding on all employees, contractors, and third-party agents of July Health Inc. who have access to or are involved in the processing of Personal Information collected via the website.

For Clients receiving specific health services, the terms outlined in their service-specific consent form will supplement and, where there is a conflict, supersede the general terms in this document.

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3. Definitions

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4. Regulatory Requirements

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July Health Inc. operates in compliance with applicable Canadian federal and provincial laws and regulations. These Terms are designed to be consistent with these legal frameworks.

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5. Policies

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5.1 Acceptance of Terms

By accessing and using the Website, you accept and agree to be bound by these Terms. If you do not agree to these Terms, you must not access or use the Website.

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5.2 Disclaimer: Not Medical Advice

The Content provided on the Website is for informational purposes only and is not intended as a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on this Website.

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5.3 Use of the Website

You agree to use the Website and Services only for lawful purposes and in a manner that does not infringe the rights of, restrict, or inhibit anyone else's use and enjoyment of the Website. Prohibited behavior includes harassing or causing distress to any person, transmitting obscene or offensive content, or disrupting the normal flow of dialogue within the Website.

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5.4 Intellectual Property

All Content on the Website is the property of July Health Inc. or its licensors and is protected by copyright, trademark, and other intellectual property laws. You may not modify, copy, reproduce, republish, upload, post, transmit, or distribute any Content without the Company's prior written consent.

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5.5 User Accounts

To access certain Services, you may be required to create an account. You are responsible for maintaining the confidentiality of your account information, including your password, and for all activity that occurs under your account. You agree to notify the Company immediately of any unauthorized use of your account.

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5.6 Privacy and Personal Information

July Health Inc. is committed to protecting your privacy. Our practices are designed to comply with PIPEDA and applicable provincial privacy legislation.

•       Accountability:      We have appointed a Privacy & Compliance Officer who is responsible for our compliance with these privacy principles.
•       Identifying Purposes:      We collect Personal Information through the Website for purposes such as responding to inquiries, processing registrations, providing newsletters, and improving our Website and Services. We will identify the purposes for which PI is collected at or before the time of collection.
•       Consent:      Your knowledge and consent are required for the collection, use, or disclosure of Personal Information, except where inappropriate. By using this Website, you consent to the collection and use of your PI as described in this policy. You may withdraw consent at any time, subject to legal or contractual restrictions.
•       Limiting Collection:      We limit the collection of Personal Information to that which is necessary for the purposes identified by the Company.
•       Limiting Use, Disclosure, and Retention:      Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required by law. We will retain PI only as long as necessary for the fulfillment of those purposes.
•       Accuracy:      We will endeavor to keep Personal Information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
•       Safeguards:      We protect Personal Information with security safeguards appropriate to the sensitivity of the information.

•       Openness:      We will make readily available to you specific information about our policies and practices relating to the management of Personal Information.
•       Individual Access:      Upon request, you shall be informed of the existence, use, and disclosure of your Personal Information and shall be given access to that information. You are entitled to challenge the accuracy and completeness of the information and have it amended as appropriate.
•       Challenging Compliance:      You can address a challenge concerning compliance with the above principles to our Privacy & Compliance Officer.

The collection, use, and disclosure of Personal Health Information (PHI) for Clients receiving health services are governed by stricter rules outlined in service-specific agreements and consent forms, such as the "Dietitian Consent Form - All Provinces except QC" and "Consent Form - Quebec (English)".

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5.7 Financial Terms and Payment

Fees for any Services will be set out on the Website or in a separate service agreement. You agree to pay all applicable fees for Services you purchase. All payments are processed through a third-party payment processor.

Specific payment terms, cancellation policies, and fees for no-shows or late cancellations for clinical services are detailed in the applicable Client consent form or service agreement.

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5.8 Termination

The Company may, in its sole discretion, terminate or suspend your access to all or part of the Website and Services for any reason, including, without limitation, breach of these Terms.

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5.9 Limitation of Liability and Disclaimer of Warranties

The Website and its Content are provided on an "as is" and "as available" basis. The Company makes no warranties, expressed or implied, and hereby disclaims all other warranties. In no event shall July Health Inc. be liable for any direct, indirect, incidental, special, or consequential damages arising out of the use or inability to use the Website or Services.

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5.10 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to its conflict of law provisions.

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6. Procedures

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6.1 Account Registration

To register for an account to book Services, Users must typically select an appointment type and schedule a time using the online booking calendar. Users must complete the online registration form with accurate information. Upon submission, a confirmation may be sent.

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6.2 Reporting a Violation of Terms

To report a violation of these Terms, Users should contact the Privacy & Compliance Officer by emailing privacy@julyhealth.com, providing specific details of the alleged violation. The Privacy & Compliance Officer is the central point of contact for all legal and privacy matters and will triage inquiries to other roles as needed.

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6.3 Accessing or Correcting Your Personal Information

To request access to, or correction of, your Personal Information held by July Health Inc., please submit a written request to the Privacy & Compliance Officer at privacy@julyhealth.com. This officer serves as the central point of contact for such requests and will ensure they are directed to the appropriate personnel. We will respond to your request in accordance with applicable privacy laws.

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7. Roles and Responsibilities

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8. Documentation and Record-Keeping

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8.1 Required Documents

The Company will maintain records of user acceptance of these Terms, records of payment transactions, communications related to non-compliance reports, and records of privacy-related inquiries and requests.

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8.2 Record-Keeping Protocols

Administrative records related to the administration of these Terms, such as payment histories or general correspondence, will be retained for a period of ten years or as required by applicable law. Clinical records containing Personal Health Information (PHI) will be retained for the longer of either ten years or the period required by the applicable provincial legislation and the professional college governing the practitioner.

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9. Monitoring and Reporting

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9.1 Compliance Monitoring

The Company reserves the right to monitor usage of the Website to ensure compliance with these Terms. This may include automated monitoring of traffic and manual review of reported issues.

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9.2 Reporting Protocols

Any suspected breach of these Terms or a privacy-related concern should be reported immediately to the Privacy & Compliance Officer at privacy@julyhealth.com. In addition, Users have the right to complain to the Privacy Commissioner of Canada at any time if they are not satisfied with our privacy practices.

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10. Training and Awareness

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10.1 Training Programs

All Company employees and contractors who manage the Website or interact with Users are trained on these Terms and the Company's associated policies upon hiring and on an ongoing basis.

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10.2 Awareness Campaigns

Updates to these Terms will be communicated to Users via on-site notifications, email, or other appropriate channels. Continued use of the Website after such notification constitutes acceptance of the revised Terms.

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11. Risk Management

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11.1 Risk Assessments

The Company periodically conducts risk assessments to identify potential risks associated with the Website and Services, including risks of misuse, data breaches, and non-compliance with these Terms.

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11.2 Mitigation Strategies

Mitigation strategies include implementing technical and administrative security measures, clarifying policies, providing clear disclaimers, and establishing procedures for handling non-compliance.

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12. Audits and Reviews

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12.1 Internal Audits

Internal reviews of these Terms and related procedures will be conducted annually or as needed to ensure they remain relevant, effective, and compliant with legal requirements.

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12.2 External Audits

The Company may engage third-party auditors to review its compliance with regulatory standards, which may include an assessment of the adequacy of these Terms.

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12.3 Review Mechanisms

This policy shall be reviewed periodically or in response to significant changes in legal requirements or business operations.

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13. Corrective Actions

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13.1 Non-Compliance Handling

Upon identification of a breach of these Terms, the Company will investigate the matter and take appropriate action, which may range from a warning to immediate termination of access.

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13.2 Corrective Action Plans

For systemic issues, a corrective action plan will be developed to address the root cause and prevent recurrence.

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14. Penalties and Sanctions

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14.1 Consequences of Non-Compliance

Non-compliance with these Terms by a User may lead to sanctions imposed by the Company, including but not limited to temporary suspension of account access, permanent termination of the account, and legal action where warranted.

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14.2 Enforcement Mechanisms

The Company will enforce these Terms through its designated compliance personnel and automated systems where applicable.

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15. Continuous Improvement

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15.1 Feedback Loops

Users may provide feedback on these Terms or their experience with the Website by emailing privacy@julyhealth.com.

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15.2 Process Improvements

The Company is committed to continuously improving its policies and procedures based on user feedback, internal reviews, and changes in the regulatory landscape.

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16. Appendices

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16.1 References

• Personal Information Protection and Electronic Documents Act (PIPEDA)
• Canada's Anti-Spam Legislation (CASL)
• Relevant Provincial Health Information and Consumer Protection Acts
• An Act to modernize legislative provisions as regards the protection of personal information (Quebec Law 25)

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