New Leaf Autism & ABA Privacy Policy

---

New Leaf Autism & ABA Services Inc.
Effective Date: May 26, 2026

New Leaf Autism & ABA Services Inc. (“New Leaf,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information and personal health information of the families, learners, caregivers, staff, and visitors who use our website, mobile application, intake forms, services, and related platforms.

This Privacy Policy explains how we collect, use, store, disclose, and protect information when you use our website, mobile app, online forms, client portal, scheduling tools, communication tools, or ABA-related services.

By using our website, mobile application, or services, you agree to the practices described in this Privacy Policy.

We may collect personal information directly from you, from a parent or legal guardian, from authorized caregivers, from our staff, or through our website or mobile application.

The types of information we may collect include:

• Parent, guardian, caregiver, or client name
• Email address
• Phone number
• Mailing address
• Emergency contact information
• Relationship to the learner or client

• Learner name
• Date of birth or age
• Diagnosis or developmental information
• ABA service history
• Behavioural, clinical, educational, or developmental goals
• Intake information
• Assessment information
• Session notes
• Attendance records
• Program updates
• Scheduling information
• Funding or service-related information

When you use our website or mobile app, we may automatically collect limited technical information such as:

• Device type
• Operating system
• App version
• Browser type
• IP address
• Usage logs
• Error reports
• Date and time of access
• General interaction with the website or app

Where applicable, we may collect billing-related information, including invoice details, payment status, funding source, and related administrative records. We do not intentionally store full credit card numbers unless processed through a secure third-party payment provider.

We use personal information and personal health information only for reasonable purposes related to providing and managing our services.

We may use information to:

• Provide ABA services and related supports
• Complete intake and onboarding
• Schedule appointments and sessions
• Communicate with parents, guardians, caregivers, and staff
• Track learner progress
• Prepare programming, reports, and clinical documentation
• Manage attendance, staffing, billing, and administration
• Respond to questions or requests
• Improve our website, app, and services
• Maintain safety, quality assurance, and service continuity
• Meet legal, regulatory, professional, or contractual obligations
• Support internal business operations

We do not sell personal information or personal health information.

We collect, use, and disclose personal information with consent, except where permitted or required by law.

For children or individuals who are unable to provide consent on their own behalf, consent must be provided by a parent, legal guardian, or authorized representative.

You may withdraw consent at any time, subject to legal, contractual, clinical, or administrative requirements. Withdrawing consent may affect our ability to provide some services.

Our services are intended to support children, youth, families, and individuals receiving ABA-related services. Information about children is collected only with the involvement and consent of a parent, guardian, or authorized representative.

We do not knowingly collect personal information from children through our website or app without appropriate parent or guardian involvement.

We may share personal information only when necessary and appropriate.

Information may be shared with:

• New Leaf staff, clinicians, contractors, supervisors, or administrative personnel who require access to provide services
• Parents, guardians, caregivers, or authorized representatives
• Third-party service providers who support our website, mobile app, scheduling, billing, communication, data storage, or business operations
• Funding providers, where authorized or required
• Professional advisors, such as legal, accounting, insurance, or compliance advisors
• Regulators, government bodies, or law enforcement where required by law
• Other parties with your consent

Any third-party service providers we use are expected to protect information and use it only for the services they provide to us.

Our website, mobile app, or business systems may use third-party technology providers for hosting, cloud storage, analytics, app functionality, communication, scheduling, forms, payment processing, or technical support.

These providers may process limited personal information on our behalf. We take reasonable steps to work with providers that maintain appropriate privacy and security safeguards.

Examples of third-party services may include:

• Website hosting providers
• App hosting or database providers
• Email and communication platforms
• Scheduling or client management systems
• Payment processors
• Analytics or crash-reporting tools
• Cloud storage providers

If our app or website uses third-party analytics, crash reporting, or tracking tools, we use that information to monitor performance, improve reliability, and understand general usage. We do not use this information to sell personal data.

If you access New Leaf services through our mobile application, we may collect information necessary for account access, service delivery, app functionality, communication, scheduling, record keeping, and support.

The information collected through the app may be linked to your account or service profile where necessary to provide services.

We do not use the app to sell personal information. We do not permit third parties to use personal health information for advertising purposes.

If the app uses analytics or crash reporting, this information is used to improve app performance, troubleshoot errors, and maintain security.

We keep personal information and personal health information only as long as necessary for the purposes described in this Privacy Policy, or as required by law, professional standards, contractual obligations, insurance requirements, or business recordkeeping obligations.

When information is no longer required, we take reasonable steps to securely delete, destroy, anonymize, or archive it.

We use reasonable physical, administrative, and technical safeguards to protect personal information and personal health information against loss, theft, unauthorized access, disclosure, copying, misuse, or modification.

These safeguards may include:

• Password-protected systems
• Access controls
• Staff confidentiality expectations
• Secure storage
• Limited access based on role
• Encryption where appropriate
• Monitoring and security review
• Secure deletion practices

No website, mobile app, or electronic system can be guaranteed to be completely secure. We encourage users to protect their own devices, passwords, and account access.

You may request access to personal information we hold about you or your child, subject to legal, clinical, privacy, or administrative limitations.

You may also request that inaccurate or incomplete information be corrected.

To make a request, please contact us using the contact information below.

You may request that we delete certain personal information or close your app/account access, where applicable.

Some information may need to be retained for legal, clinical, billing, regulatory, insurance, or administrative reasons. Where full deletion is not possible, we will explain why and restrict further use where appropriate.

To request deletion or account removal, contact us at:

Email: [Insert Privacy Contact Email]
Subject Line: Privacy Request / Data Deletion Request

Our website may use cookies or similar technologies to improve website performance, remember preferences, understand site traffic, and improve user experience.

You can adjust your browser settings to block or delete cookies. Some website features may not function properly if cookies are disabled.

We may use your contact information to communicate with you about services, scheduling, intake, billing, updates, policy changes, or administrative matters.

We may also send service-related emails or app notifications. You may opt out of non-essential communications where applicable, but we may still send important service, safety, legal, or account-related messages.

Our website or app may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of third-party websites. We encourage users to review the privacy policies of any external sites they visit.

We may update this Privacy Policy from time to time. The updated version will be posted on our website with a revised effective date.

Continued use of our website, app, or services after changes are posted means you accept the updated Privacy Policy.

If you have questions about this Privacy Policy, our privacy practices, or your personal information, please contact:

New Leaf Autism & ABA Services Inc.
Privacy Officer: Kelly Burke
Email: info@newleafautism.com
Phone: 905-353-1725
Address: [Insert Business Address]

If you have a concern about how we handle personal information or personal health information, please contact us first so we can review and respond to your concern.

You may also have the right to contact the appropriate privacy regulator, including the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario, depending on the nature of the concern.

Our website and mobile app are not intended for emergencies or urgent clinical situations. If there is an emergency, immediate safety concern, or medical crisis, call 911 or contact the appropriate emergency service.