1. Who We Are and What This Policy Covers

CFS Recovery Inc. ("CFS Recovery," "we," "us," "our") is the controller of the personal information described here. We are incorporated in British Columbia, Canada, and operate the Services from offices in Canada.

This policy covers all websites, applications, member portals, communities, coaching sessions, assessments, and communications we own or operate (the "Services"). It does not cover unaffiliated sites we link to.

We do not represent that materials on the Services are appropriate or available for use outside Canada. Persons who choose to access the Services from other locations do so on their own initiative and are responsible for compliance with local laws, to the extent local laws apply.

2. Information We Collect

Information you give us directly

Identity and contact information: name, email address, postal address, telephone number.

Account information: username, password, member profile.

Payment information: billing name and address, and the details needed to process payment. Card numbers are collected and stored by our payment processors, not by us; we receive only a token and limited transaction details.

Application, intake and assessment responses: including your Nervous System Health Assessment answers, symptom history, and the goals you share with us.

Coaching content: messages you send to coaches and in the community, and what you share during coaching sessions.

Free-text you choose to provide: survey responses, support requests, testimonials, case-study consent forms.

Information generated by the Services

Recordings of group and individual coaching calls, where recording applies to that session.

Transcripts and summaries automatically generated from coaching sessions.

Engagement data: modules viewed, calls attended, progress within a recovery system.

Information collected automatically

Technical and routing data: IP address, device and browser type, operating system, referring URL, pages viewed, dates and times of access.

Cookies and similar technologies: see Section 8.

We collect personal information only when you voluntarily submit it, or automatically as described above. If you do not provide information marked as mandatory for a particular activity, you may not be able to take part in that activity.

3. Health-Related Information

Because of what we do, some of the information you share with us is sensitive health-related information. That includes symptoms, diagnoses you've received, medical history, and your recovery journey.

We treat this information as sensitive. We collect it only to deliver coaching and support to you, we limit internal access to the coaches and staff who need it, and we do not use it for advertising or share it with advertising platforms.

CFS Recovery does not provide healthcare services and is not a healthcare provider. Information you share with us is not a medical record and isn't protected by clinician-patient privilege.

4. How We Use Your Information

We use personal information to:

deliver the Services you signed up for, including coaching, community access, calls, and course materials;

create and administer your account, and process payments and refunds;

generate transcripts, summaries, and progress feedback for you and your coach;

respond to your questions and provide customer support;

send you newsletters, service messages, and information about products, services, and upcoming events (you can opt out at any time);

understand how the Services are used, measure traffic patterns in aggregate, and improve what we build;

operate, develop, and improve AI-based coaching tools as described in Section 6;

meet legal, accounting, tax, and regulatory obligations; and

detect, prevent, and address fraud, abuse, chargebacks, and security incidents.

Our legal bases (where GDPR/UK GDPR applies): performance of our contract with you; your consent (for marketing, recordings, AI-model training, and case-study use); our legitimate interests in operating and improving the Services and securing them; and compliance with legal obligations. Where we process health-related information, we rely on your explicit consent, which you may withdraw at any time.

5. Recordings, Transcripts and Community Content

Coaching calls may be recorded so that members can watch replays. Transcripts and summaries may be generated automatically from those sessions.

Nothing from your sessions will be used for marketing or promotional purposes without your express consent.

We occasionally share positive experiences and community wins on our social media to inspire others. To protect your privacy, personally identifiable information, such as full names, faces, or any other distinguishing details, will be blurred or omitted unless you have explicitly agreed to participate in a recovery interview or to have your content shared publicly.

If you sign our Consent Form for Release of Personal, Non-Identifying Information, we may share non-identifying details of your recovery, such as age range, gender, and a general overview of symptoms and progress, as part of case studies. You may withdraw that consent at any time by emailing [email protected], and doing so will not affect your current or future participation.

6. AI-Based Coaching Tools, De-identification, and Your Opt-Out

We develop and utilize AI-based coaching tools that support all clients. These tools are powered by models that improve with insights from coaching messages and sessions of all clients (including yours) so this collective knowledge can be used for everyone's benefit. These same models power AI-based tools for your coach, such as summaries and suggestions, and help us develop new products and services.

To protect your privacy, we take steps to de-identify and aggregate data we use to optimize AI models. That means removing or masking direct identifiers such as your name, email address, and contact details before the data is used for model optimization.

You can opt out at any time by emailing [email protected]. Opting out stops your coaching messages and sessions from being used to optimize or train these models going forward. It does not affect your access to the Services, your coaching, or your standing in any recovery system. Where model training requires your prior explicit consent under applicable law, we will not use your content for that purpose unless you have opted in.

We use reputable third-party AI and transcription providers to deliver these features. They act as our processors, are bound by contract to use your information only to provide services to us, and are not permitted to use your content to train their own general-purpose models.

AI-generated summaries and transcripts may contain errors. They are supportive tools, not a record of fact, and not medical advice.

7. How We Share Information

We do not sell your personal information, and we do not exchange or rent it.

We share personal information only in these circumstances:

Service providers ("processors") who help us run the business: hosting, email and newsletter delivery, course and community platforms, video conferencing, transcription and AI providers, payment processors, CRM and scheduling tools, and customer support tools. They may access personal information only to perform services for us, under contract, and may not use it for their own purposes.

Coaches and staff who work with you, on a need-to-know basis.

Professional advisers: accountants, auditors, insurers, and lawyers, where necessary.

Legal and safety reasons: where required by law, court order, or regulator, or where we reasonably believe disclosure is necessary to protect the rights, safety, or property of any person.

Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this policy continuing to apply.

With your consent: for anything else, including public testimonials and case studies.

Mobile and SMS data: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

8. Cookies, Analytics and Advertising Technologies

Cookies help track a visitor's session while online. A cookie is a small amount of data transferred to your browser by a web server and readable only by the server that set it. It cannot be executed as code and cannot deliver viruses. By showing how and when visitors use the Services, cookies help us keep improving them.

We use:

Strictly necessary cookies: required for login, security, and core site functions.

Analytics cookies: to understand traffic patterns and which areas of the Services need improvement. This data is used in aggregate, without identifying you individually.

Advertising and measurement technologies, including the Meta (Facebook) Pixel. The Pixel collects information about your interaction with our site, such as pages visited and actions taken, and may use hashed information (such as your email address or phone number, if provided) to help match your activity across devices and platforms. This helps us measure the effectiveness of our advertising, deliver targeted ads on Facebook and its partner sites, and build and refine custom audiences.

We do not use health-related information, assessment responses, coaching content, or session transcripts for advertising or audience targeting.

Your choices. Most browsers are set to accept cookies initially. You can set your browser to notify you when a cookie is offered, or to refuse cookies, though some pages that require authorization may not work if you do. You can learn more about Meta's practices in Facebook's Data Policy, and opt out of Meta tracking through Facebook's Ad Settings or browser-based opt-out tools. Where required by law, we ask for your consent to non-essential cookies through our cookie banner, and you can change that choice at any time.

9. Newsletters and Marketing Communications

We contact individuals who have specifically requested that we do so, who have signed up to receive our free newsletters, or who have purchased one of our products.

Every marketing email includes an unsubscribe link, and you can remove yourself at any time. You can also email [email protected] to update your information or to be removed from any postal, email, phone, SMS, or other list. Please include your exact name, email address, mailing address, and phone number so we can find and remove the right records. We will action your request promptly.

Even after you opt out of marketing, we will still send you essential service messages: receipts, renewal notices, security alerts, and changes to these policies.

10. Where and How We Store Your Information

Your information is stored with the service providers described in Section 7, including the list server that delivers our newsletters, and can be accessed only by those who need it to manage those lists and deliver the Services.

We maintain administrative, technical, and physical safeguards designed to protect personal information against loss, theft, and unauthorized access, use, or disclosure. Those safeguards include access controls, encryption in transit, and limiting staff access on a need-to-know basis. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

International transfers. We are based in Canada and use service providers located in Canada, the United States, and elsewhere. Where we transfer personal information outside your country, we rely on appropriate safeguards, such as standard contractual clauses, and your information remains subject to this policy.

11. How Long We Keep Your Information

We keep personal information only as long as necessary for the purposes described in this policy:

Account and coaching records: for the duration of your membership and for a reasonable period afterwards to support you if you return.

Recordings, transcripts, and summaries: for the period needed to deliver replays and coaching continuity, after which they may be deleted in line with our retention practices.

Payment and transaction records: as required by tax and accounting law.

Marketing contact details: until you unsubscribe or ask us to delete them.

We may delete Content, including recordings and transcripts, in connection with our data retention policies once it is no longer timely or relevant. You can ask us to delete your information sooner as described in Section 12.

12. Your Rights and Choices

Depending on where you live, you may have the right to:

access the personal information we hold about you and receive a copy;

correct information that is inaccurate or incomplete;

delete your personal information;

withdraw consent at any time, including consent to recordings, AI-model optimization, case-study use, and marketing;

object to or restrict certain processing;

portability: receive your information in a portable format;

opt out of the sale or sharing of personal information for targeted advertising (we do not sell personal information); and

not be discriminated against for exercising these rights.

To exercise any right, email [email protected]. We will verify your identity and respond within the time required by applicable law (generally 30 days under Canadian PIPEDA and GDPR). If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada, or to your local supervisory authority.

13. Children's Privacy

The Services are intended for adults aged 18 and over. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us at [email protected] and we will delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we do, we will post the updated policy on the Site, update the "Last updated" date above, and, where the change is material, notify you by email or another prominent communication. Please review this policy whenever you use the Services. Continued use after we post an update means you accept the changes.

15. Governing Law

This policy and any dispute arising from it are governed by the laws of the Province of British Columbia and the federal laws of Canada applicable in it, without regard to conflict-of-law principles. Disputes are handled as set out in Section 20 of our Terms of Service.

Contact Us

CFS Recovery Inc.

1119 Chaster Road, Gibsons, British Columbia, Canada, V0N 1V4

Email: [email protected]