PRIVACY POLICY
My Growth Counselling
www.mygrowthcounselling.ca
Effective Date: February 17, 2026
Last Updated: February 17, 2026
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TABLE OF CONTENTS
1. Introduction
2. Who We Are
3. What Personal Information We Collect
4. How We Collect Your Information
5. Why We Collect Your Information
6. How We Use Your Information
7. Who We Share Your Information With
8. Consent
9. How Long We Keep Your Information
10. How We Protect Your Information
11. Your Rights as a Client
12. Cookies and Tracking Technologies
13. Website Accessibility (UserWay)
14. Privacy Breach Notification
15. Compliance with Ontario and Canadian Privacy Laws (PHIPA and PIPEDA)
16. Children and Minors
17. Third-Party Links
18. Social Media
19. Changes to This Privacy Policy
20. How to Contact Us
21. How to File a Complaint
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1. INTRODUCTION
My Growth Counselling is committed to protecting the privacy and confidentiality of your personal information and personal health information. We understand the sensitive nature of the information you share with us in the course of therapy, and we take our responsibility to safeguard that information very seriously.
This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information and personal health information when you visit our website, use our services, or communicate with us. It also explains your rights regarding your information and how you can exercise those rights.
By using our website or engaging our therapy services, you acknowledge that you have read and understood this Privacy Policy. If you have any questions, please contact us using the details provided in Section 20.
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2. WHO WE ARE
Practice Name: My Growth Counselling
Therapist: Sherriden Brown, Registered Psychotherapist
Registration: College of Registered Psychotherapists of Ontario (CRPO), Registration #11090
Certification: Canadian Certified Counsellor (CCC), Canadian Counselling and Psychotherapy Association (CCPA), #10010120
Location: 92 Lakeshore Road East, Mississauga, Ontario L5G 4S2, Canada
Phone: (289) 276-7423
Email: sherriden@mygrowthcounselling.ca
Website: www.mygrowthcounselling.ca
Sherriden Brown is a Health Information Custodian under Ontario's Personal Health Information Protection Act, 2004 (PHIPA) and is responsible for the collection, use, disclosure, and protection of your personal health information.
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3. WHAT PERSONAL INFORMATION WE COLLECT
We may collect the following categories of personal information and personal health information from you:
Identifying Information: Your full name, date of birth, gender, pronouns, and marital or relationship status.
Contact Information: Your email address, phone number, mailing address, and emergency contact details.
Health Information: Mental health history, presenting concerns, therapy goals, treatment notes, session records, diagnosis information, emotional and psychological assessments, medication information, and any other health-related information you share during the course of therapy.
Appointment Information: Dates, times, and types of therapy sessions (in-person or virtual), cancellations, and rescheduling details.
Financial and Payment Information: Credit card or payment details, insurance information, billing records, receipts, and fee-related correspondence.
Communication Records: Emails, phone call logs, text messages, voicemails, and messages submitted through our website contact form (including your first name, last name, phone number, email, subject, and message content).
Intake and Consent Forms: Information provided through intake questionnaires, informed consent documents, and any other clinical forms.
Technical and Website Data: IP address, browser type, device information, pages visited on our website, referring website, and other analytics data collected through cookies and similar technologies.
Referral Information: Name and contact details of the referring professional, if applicable.
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4. HOW WE COLLECT YOUR INFORMATION
We collect your personal information and personal health information through the following methods:
Website Contact Forms: When you submit a message through the contact form on our website, we collect your first name, last name, phone number, email address, subject, and message content.
Online Booking Platform (Jane App): When you book a free consultation or therapy session through our online booking system (Jane App), we collect the information you provide during the booking and intake process. Jane App is a Canadian-based electronic medical records (EMR) and practice management platform.
Direct Communication: Information you share with us via email, phone, text message, or in person during therapy sessions, consultations, or other communications.
Therapy Sessions: Information you disclose during in-person or virtual therapy sessions, including verbal and written disclosures.
Virtual Therapy (Telehealth): When you participate in virtual therapy sessions, technical information related to the video conferencing platform may be collected.
Intake and Consent Forms: Information you provide when completing intake questionnaires, consent forms, and other clinical documentation.
Referrals: If you are referred to us by another healthcare provider, we may receive relevant referral information with your consent.
Cookies and Website Analytics: Our website may collect technical data through cookies, web beacons, and analytics tools as described in Section 12.
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5. WHY WE COLLECT YOUR INFORMATION
We collect your personal information and personal health information for the following purposes:
Providing Therapy Services: To provide you with psychotherapy, couples counselling, individual therapy, family therapy, and related mental health services.
Appointment Management: To schedule, confirm, reschedule, or cancel therapy sessions, including sending appointment reminders.
Communication: To respond to your inquiries, follow up on your care, and communicate with you about your therapy.
Billing and Payment Processing: To process payments, issue receipts, and manage billing for therapy services.
Clinical Record-Keeping: To create and maintain clinical records as required by the College of Registered Psychotherapists of Ontario (CRPO) and applicable laws.
Legal and Regulatory Compliance: To comply with legal obligations under PHIPA, PIPEDA, the Psychotherapy Act, 2007, the Regulated Health Professions Act, 1991, and other applicable legislation.
Continuity of Care: To coordinate care with other healthcare providers within the circle of care, where applicable and with your consent.
Improving Our Services: To improve our website, services, and the overall client experience.
Safety: To protect the health and safety of you or others where there is a serious and imminent threat, as permitted by law.
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6. HOW WE USE YOUR INFORMATION
We use your personal information and personal health information in the following ways:
- To deliver psychotherapy and counselling services tailored to your needs.
- To maintain accurate and complete clinical records of your therapy.
- To schedule and manage your appointments through our booking system (Jane App).
- To process payments and provide receipts for therapy sessions.
- To communicate with you regarding your therapy, appointments, and account.
- To comply with our professional and legal obligations as a Registered Psychotherapist regulated by the CRPO.
- To respond to inquiries submitted through our website, email, phone, or text.
- To improve the functionality and user experience of our website.
- To analyze website traffic and usage patterns through anonymized and aggregated data.
- To coordinate referrals or care with other healthcare providers, with your express consent.
We do not use your personal health information for marketing purposes. We will not send you marketing communications unless you have provided express consent to receive them.
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7. WHO WE SHARE YOUR INFORMATION WITH
We respect the confidentiality of your personal information and personal health information. We will only share your information in the following circumstances:
Jane App (EMR and Practice Management): We use Jane App, a Canadian-based electronic medical records and practice management platform, to manage appointments, clinical records, billing, and client communications. Jane App stores data on servers located in Canada and maintains security standards consistent with Canadian privacy legislation.
Payment Processors: If you make a payment by credit card or other electronic means, your payment information is processed by a secure third-party payment processor. We do not store your full credit card details on our systems.
Within the Circle of Care: We may share your personal health information with other healthcare providers involved in your care (such as your family physician, psychiatrist, or other treating professionals) as permitted under PHIPA, where implied consent applies within the circle of care. We will inform you of any such disclosures.
With Your Express Consent: We may share your information with third parties outside the circle of care (such as insurance companies, lawyers, employers, or family members) only with your express written or verbal consent.
Website Hosting and Technology Providers: Our website is hosted by a third-party website platform. These providers may have access to technical data (such as IP addresses) but do not have access to your personal health information.
Legal and Regulatory Requirements: We may disclose your information without your consent where required or permitted by law, including:
- To comply with a court order, subpoena, or other legal process.
- To report suspected child abuse or neglect as required under the Child, Youth and Family Services Act, 2017.
- To prevent or reduce a significant risk of serious bodily harm to you or another person.
- To comply with reporting obligations to the CRPO or other regulatory bodies.
- To respond to a request from the Information and Privacy Commissioner of Ontario.
Professional Advisors: We may share information with our own legal, accounting, or professional advisors as necessary for the operation of our practice, subject to confidentiality obligations.
We do not sell, rent, or trade your personal information or personal health information to any third party.
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8. CONSENT
Under PHIPA, we require your consent to collect, use, and disclose your personal health information. Consent may be express or implied, depending on the circumstances:
Implied Consent: When you provide personal health information to us for the purpose of receiving therapy, your consent to collect, use, and disclose that information within the circle of care for the purpose of providing healthcare is implied.
Express Consent: We will obtain your express consent (verbal or written) before:
- Sharing your personal health information with anyone outside the circle of care.
- Using your information for purposes other than providing healthcare.
- Disclosing your information to insurance companies, lawyers, employers, family members, or other third parties.
Withdrawal of Consent: You have the right to withdraw your consent at any time by notifying us in writing or verbally. Please be aware that withdrawing consent may affect our ability to provide you with therapy services. Withdrawal of consent does not apply retroactively and is subject to legal and professional obligations (for example, we are required to retain clinical records for a minimum period as described in Section 9).
Exceptions to Consent: In certain limited circumstances, we may collect, use, or disclose your personal health information without your consent, as permitted or required by law. These exceptions include situations involving imminent risk of serious harm, mandatory reporting obligations, court orders, and other circumstances outlined in PHIPA.
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9. HOW LONG WE KEEP YOUR INFORMATION
We retain your personal information and personal health information in accordance with the requirements of PHIPA, the College of Registered Psychotherapists of Ontario (CRPO), and other applicable legislation.
Clinical Records: As required by CRPO standards, clinical records are retained for a minimum of 10 years from the date of the last interaction with the client, or for 10 years from the client's 18th birthday, whichever is later.
Financial Records: Billing and payment records are retained for a minimum of 7 years in accordance with Canada Revenue Agency requirements.
Website and Communication Records: Non-clinical communications (such as website contact form submissions and general email correspondence) are retained only as long as necessary to fulfill the purpose for which they were collected, and are securely deleted when no longer needed.
Destruction of Records: When the retention period has expired and records are no longer needed, they will be securely destroyed. Paper records will be shredded, and electronic records will be permanently deleted using secure methods that prevent recovery. A record of destroyed files (including client name or identifier and date of destruction) will be maintained.
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10. HOW WE PROTECT YOUR INFORMATION
We take the security of your personal information and personal health information very seriously. We have implemented the following safeguards:
Administrative Safeguards:
- Access to personal health information is restricted to authorized individuals only (Sherriden Brown, Registered Psychotherapist, and any authorized agents).
- Privacy and confidentiality policies and procedures are in place and reviewed regularly.
- Ongoing professional development and training on privacy and security best practices.
- Informed consent processes are followed for all new clients.
Technical Safeguards:
- Electronic records are stored in Jane App, a secure Canadian-based EMR system that uses encryption for data in transit and at rest.
- Password-protected access to all electronic systems containing personal health information.
- Secure, encrypted email communications where possible.
- Regular software updates and security patches applied to all systems.
- Use of secure virtual therapy platforms for telehealth sessions.
Physical Safeguards:
- Paper records, if any, are stored in locked filing cabinets in a secured office.
- Office premises are secured with appropriate physical access controls.
- Paper records containing personal health information are securely shredded when no longer needed.
Despite our best efforts, no method of electronic storage or transmission over the internet is completely secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a privacy breach, we will follow the notification procedures described in Section 14.
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11. YOUR RIGHTS AS A CLIENT
Under PHIPA and PIPEDA, you have the following rights regarding your personal information and personal health information:
Right of Access: You have the right to request access to your personal health information held by us. You may request copies of your clinical records. We will respond to access requests within 30 days of receiving the request. A reasonable fee may be charged for providing copies.
Right to Correction: If you believe that your personal health information is inaccurate or incomplete, you have the right to request a correction. If we agree that the information is inaccurate or incomplete, we will correct the record. If we do not agree with the requested correction, you have the right to attach a statement of disagreement to your file, which will be included whenever the disputed information is disclosed.
Right to Withdraw Consent: You may withdraw your consent to the collection, use, or disclosure of your personal health information at any time, subject to legal and professional obligations. We will inform you of the consequences of withdrawing consent.
Right to Be Informed: You have the right to know how your personal health information is being collected, used, and disclosed.
Right to Complain: You have the right to file a complaint with us or with the Information and Privacy Commissioner of Ontario if you believe your privacy rights have been violated (see Section 21).
Limitations on Access: In certain circumstances, access to your records may be limited or denied, as permitted under PHIPA. These include situations where:
- Disclosure could result in a risk of serious harm to you or another person.
- The information is subject to legal privilege.
- The records contain quality of care information or raw data from psychological tests and assessments.
- Disclosure is prohibited by court order or other legal process.
If access is denied, we will provide you with written reasons and inform you of your right to file a complaint with the Information and Privacy Commissioner of Ontario.
How to Make a Request: To request access to, correction of, or information about your personal health information, please contact us using the details in Section 20. We may require you to submit your request in writing and to verify your identity before processing the request.
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12. COOKIES AND TRACKING TECHNOLOGIES
Our website (www.mygrowthcounselling.ca) may use cookies and similar tracking technologies to improve your browsing experience and to analyze how our website is used.
What Are Cookies: Cookies are small text files placed on your device by a website. They help the website remember your preferences and understand how you interact with the site.
Types of Cookies We May Use:
Essential Cookies: These cookies are necessary for the basic functioning of our website, such as enabling page navigation and access to secure areas. The website cannot function properly without these cookies.
Analytics Cookies: We may use analytics tools (such as Google Analytics or similar services) to collect anonymized, aggregated data about how visitors use our website, including pages visited, time spent on the site, and referring websites. This data helps us improve our website and understand visitor behavior. Analytics cookies do not collect personal health information.
Third-Party Cookies: Our website may contain embedded content or links to third-party services (such as social media platforms or video hosting services) that may set their own cookies. We do not control these third-party cookies.
Managing Cookies: You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling cookies may affect the functionality of our website.
Do Not Track: Some browsers offer a "Do Not Track" setting. We respect your browser's Do Not Track preferences where technically feasible.
We do not use cookies or tracking technologies to collect personal health information. Website analytics data is used solely for the purpose of improving our website and is not linked to your clinical records or therapy services.
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13. WEBSITE ACCESSIBILITY (USERWAY)
My Growth Counselling is committed to ensuring that our website is accessible to all visitors, including individuals with disabilities. To support this commitment, our website uses the Accessibility by UserWay widget.
What Is UserWay: UserWay is a third-party accessibility tool that provides a range of features designed to make websites more accessible and to assist with compliance with accessibility standards, including the Web Content Accessibility Guidelines (WCAG 2.1), the Accessibility for Ontarians with Disabilities Act (AODA), and other applicable accessibility standards.
Features of the UserWay Accessibility Widget: The UserWay widget appears as a floating icon on our website and provides visitors with tools to customize their browsing experience, including:
- Screen Reader: Provides auditory feedback for on-screen content, reading aloud text, descriptions, and navigational elements.
- Contrast Adjustments: Includes options to invert colors, apply dark mode, and adjust smart contrast for improved readability and visual comfort.
- Bigger Text: Allows users to increase text size for enhanced readability, with multiple levels of adjustment.
- Text Spacing: Customizes the spacing between lines of text with light, moderate, and other options to improve readability.
- Dyslexia-Friendly Font: Offers specialized font choices designed to improve readability for users with dyslexia, featuring distinct letter shapes and spacing.
- Legible Fonts: Provides alternative fonts for easier reading.
- Highlight Links: Visually emphasizes hyperlinks to help users quickly identify clickable elements.
- Big Cursor: Enlarges the cursor for better visibility.
- Reading Mask: Applies a semi-transparent mask around the cursor to help focus on specific content.
- Reading Guide: Provides a horizontal guide to help users follow lines of text.
- Hide Images: Removes visual elements from the page for a simplified, text-focused view.
- Tooltips: Displays alt text descriptions when hovering over images, offering insights into image content and purpose.
- Keyboard Navigation Enhancements: Improves navigation for users who rely on keyboard-only input.
- Dictionary: Offers definitions for words on the page to support understanding of content.
Privacy and UserWay: UserWay does not collect any personal information from visitors interacting with the widget. The accessibility widget is designed to enhance your browsing experience without compromising your privacy. For more information, you may review UserWay's own privacy policy at userway.org.
If you experience any accessibility issues on our website or require assistance, please contact us using the details in Section 20.
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14. PRIVACY BREACH NOTIFICATION
A privacy breach occurs when personal health information is collected, used, disclosed, retained, or disposed of in a manner that does not comply with PHIPA.
In the Event of a Breach: If a privacy breach occurs involving your personal health information, we will take the following steps:
1. Containment: We will immediately take steps to contain the breach, including securing the affected records and preventing further unauthorized access.
2. Investigation: We will investigate the breach to determine the cause, scope, and severity, including what information was affected, who was affected, and how the breach occurred.
3. Notification to Affected Individuals: We will notify you as soon as reasonably possible if your personal health information has been or may have been compromised. The notification will include a description of the breach, the type of information involved, the steps we have taken to address the breach, and recommendations for steps you can take to protect yourself.
4. Notification to the Information and Privacy Commissioner of Ontario: In serious situations, we will notify the Information and Privacy Commissioner of Ontario as required by PHIPA.
5. Notification to the CRPO: Where applicable, we will notify the College of Registered Psychotherapists of Ontario of the breach.
6. Remediation: We will take appropriate steps to prevent similar breaches from occurring in the future, including reviewing and updating our security measures and policies.
7. Record-Keeping: We will maintain a record of all privacy breaches and report them to the Information and Privacy Commissioner of Ontario in an annual report as required by PHIPA.
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15. COMPLIANCE WITH ONTARIO AND CANADIAN PRIVACY LAWS (PHIPA AND PIPEDA)
This Privacy Policy is designed to comply with the following legislation:
Personal Health Information Protection Act, 2004 (PHIPA): PHIPA is Ontario's health privacy legislation that governs how health information custodians collect, use, disclose, retain, and dispose of personal health information. As a Registered Psychotherapist in Ontario, Sherriden Brown is a Health Information Custodian under PHIPA and is required to comply with all provisions of this Act.
Under PHIPA, your personal health information includes any information that identifies you and relates to your physical or mental health, your healthcare history, the healthcare services you have received, payments or eligibility for healthcare, and your Ontario health card number.
PHIPA provides you with specific rights, including the right to access your records, request corrections, be informed about how your information is used, and file complaints with the Information and Privacy Commissioner of Ontario. These rights are described in detail in Section 11 of this policy.
Personal Information Protection and Electronic Documents Act (PIPEDA): PIPEDA is Canada's federal privacy law that governs the collection, use, and disclosure of personal information in the course of commercial activities. While PHIPA generally takes precedence for the collection, use, and disclosure of personal health information within Ontario (as PHIPA has been deemed substantially similar to PIPEDA), PIPEDA may also apply in certain circumstances, such as when personal information that is not health information is collected in the course of commercial activities, or when information crosses provincial or national borders.
Psychotherapy Act, 2007 and Regulated Health Professions Act, 1991: My Growth Counselling operates in accordance with the professional standards set by the College of Registered Psychotherapists of Ontario (CRPO) under these Acts, including all requirements related to privacy, confidentiality, record-keeping, and professional conduct.
Accessibility for Ontarians with Disabilities Act, 2005 (AODA): We are committed to complying with AODA requirements and ensuring our services and website are accessible to all individuals.
Canada's Anti-Spam Legislation (CASL): We comply with CASL by only sending electronic commercial messages with your express consent. You may withdraw your consent to receive such communications at any time.
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16. CHILDREN AND MINORS
Where therapy services are provided to a minor (under 18 years of age), we will collect personal health information with the consent of the minor's parent or legal guardian, or from the minor directly where the minor has the capacity to consent, in accordance with PHIPA. Clinical records for minors are retained for a minimum of 10 years from the client's 18th birthday.
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17. THIRD-PARTY LINKS
Our website may contain links to third-party websites, such as the Jane App booking platform, social media profiles, or other external resources. These third-party websites have their own privacy policies and practices. My Growth Counselling is not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party website you visit.
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18. SOCIAL MEDIA
My Growth Counselling may maintain a presence on social media platforms (such as Instagram, Facebook, or LinkedIn). Please be aware that:
- Any information you post or share on social media is public and is not protected by therapist-client confidentiality.
- We will never disclose your identity as a client or any personal health information on social media.
- We will not accept friend or connection requests from current or former clients on personal social media accounts to protect your privacy and maintain appropriate therapeutic boundaries.
- If you choose to interact with our social media pages (such as liking, commenting, or sharing), you do so at your own discretion. We recommend that clients consider the privacy implications of engaging publicly with a therapist's social media.
- Social media platforms have their own privacy policies. We are not responsible for how these platforms collect, use, or disclose your information.
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19. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, legal requirements, or for other operational reasons.
When we make changes, we will update the "Last Updated" date at the top of this policy. If we make significant changes to how we collect, use, or disclose your personal health information, we will take reasonable steps to notify you, which may include:
- Posting a notice on our website.
- Informing you directly via email or during a therapy session.
- Providing you with an updated copy of this policy.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
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20. HOW TO CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal information and personal health information, please contact us:
Privacy Officer / Health Information Custodian:
Sherriden Brown, Registered Psychotherapist
My Growth Counselling
92 Lakeshore Road East
Mississauga, Ontario L5G 4S2
Canada
Phone: (289) 276-7423
Email: sherriden@mygrowthcounselling.ca
Website: www.mygrowthcounselling.ca
We will acknowledge receipt of your inquiry and respond within 30 days.
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21. HOW TO FILE A COMPLAINT
If you believe that your privacy rights have been violated, or if you are not satisfied with how we have handled your personal health information, you have the right to:
1. Contact Us Directly: Please bring your concern to our attention first by contacting Sherriden Brown at the details provided in Section 20. We will investigate your concern and respond to you within 30 days.
2. File a Complaint with the Information and Privacy Commissioner of Ontario:
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone: 1-800-387-0073
Website: www.ipc.on.ca
3. File a Complaint with the College of Registered Psychotherapists of Ontario (CRPO):
College of Registered Psychotherapists of Ontario
375 University Avenue, Suite 800
Toronto, Ontario M5G 2J5
Phone: 416-479-4330 / 1-844-712-1364
Email: info@crpo.ca
Website: www.crpo.ca
4. File a Complaint with the Office of the Privacy Commissioner of Canada (if PIPEDA applies):
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Phone: 1-800-282-1376
Website: www.priv.gc.ca
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DISCLAIMER
This Privacy Policy is provided for informational purposes and is intended to describe our privacy practices in plain language. It does not constitute legal advice. While we make every effort to ensure compliance with applicable privacy legislation, we recommend that you seek independent legal advice if you have specific legal questions about your privacy rights.
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Thank you for trusting My Growth Counselling with your care. Protecting your privacy is a fundamental part of the safe and supportive therapeutic relationship we strive to provide.
Sherriden Brown
Registered Psychotherapist
My Growth Counselling
www.mygrowthcounselling.ca
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(c) 2026 My Growth Counselling. All Rights Reserved.