Our Commitment to Privacy

Fulcrum Rehabilitation Services Inc. (“Fulcrum,” “we,” “our,” or “us”) is a Quebec-based Canadian company providing on-site assessment, osteopathic treatment, exercise-based support, and rehabilitation-related services to corporate, institutional, public-sector, and government organizations.

Our services are intended to support musculoskeletal health, functional mobility, recovery, and return to activity in professional and operational environments.

We recognize that confidentiality, professional discretion, and responsible information management are essential to maintaining the trust of our organizational clients, their personnel, and individuals receiving services.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our website, business communications, contractual relationships, and service delivery.

Our privacy practices are guided by applicable Canadian privacy legislation, including Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25, and the Personal Information Protection and Electronic Documents Act (PIPEDA), where applicable. Other federal, provincial, or sector-specific requirements may apply depending on the nature of an engagement.

1. Privacy Officer

Fulcrum designates the following individual as the person responsible for the protection of personal information:

Laurent-Olivier Galarneau, D.O.
Founder & Director
Privacy Officer
Fulcrum Rehabilitation Services Inc.
Email: info@fulcrumrehab.com
Website: www.fulcrumrehab.com

Questions, privacy requests, or complaints may be submitted to this contact.

2. Scope of This Policy

This policy applies to personal information collected or handled through:

• Our website and online contact forms.
• Business inquiries and professional correspondence.
• Procurement, tendering, and contractual discussions.
• Corporate and institutional service arrangements.
• On-site assessments and individual service delivery.
• Administrative and operational communications.

Certain engagements may be governed by additional confidentiality agreements, institutional privacy requirements, or specific contractual provisions.

Where applicable legislation or binding contractual requirements impose additional obligations, those requirements will be considered alongside this policy.

3. Personal Information We May Collect

Fulcrum limits the collection of personal information to what is reasonably necessary for identified and legitimate purposes.

3.1 Business and Professional Information

When organizations or their representatives contact us, we may collect:

• Names and professional titles.
• Business email addresses and telephone numbers.
• Organization names and departments.
• Information concerning service requirements.
• Contractual and procurement correspondence.
• Scheduling, availability, and operational details.

3.2 Information Related to Individual Services

Where Fulcrum is engaged to provide services directly to individuals, additional information may be collected when necessary and authorized.

Depending on the service, this may include relevant health history, musculoskeletal complaints, functional limitations, assessment findings, treatment information, and progress observations.

Health-related information is treated as sensitive personal information and is subject to heightened confidentiality considerations.

We seek to avoid collecting information unrelated to the services being provided.

3.3 Website Information

When visitors access our website, certain technical information may be processed by our website hosting provider or other enabled website services.

This may include browser information, device characteristics, IP addresses, website usage information, and information submitted voluntarily through contact forms.

4. Purposes of Collection and Use

Personal information may be used for the following purposes:

Business and Contractual Activities

To respond to inquiries, evaluate potential collaborations, prepare service proposals, participate in procurement processes, coordinate assignments, and administer contractual relationships.

Service Delivery

To organize and provide agreed-upon services, document relevant assessments and interventions, support continuity of service, and communicate necessary operational information.

Administration and Compliance

To maintain appropriate business records, manage invoices and payments, fulfill applicable legal or contractual obligations, and respond to legitimate requests from authorized parties.

Website Operations

To maintain website functionality, respond to submitted inquiries, and evaluate website performance where analytics tools are enabled.

Fulcrum does not use sensitive health information for unrelated marketing purposes.

5. Consent and Authorization

Fulcrum obtains consent where required by applicable law, taking into account the nature and sensitivity of the information involved.

Consent may be express or implied where legally appropriate. Sensitive health information generally requires more specific consent unless a lawful exception applies.

Individuals will be informed of the relevant purposes for collecting their information and, where required, the parties to whom it may be disclosed.

Consent may be withdrawn, subject to legal, professional, or contractual restrictions and applicable exceptions.

An organization's engagement of Fulcrum does not automatically authorize unrestricted disclosure of an individual's confidential health information to that organization.

6. Confidentiality in Corporate and Institutional Environments

Fulcrum recognizes the importance of maintaining appropriate boundaries between individual service information and organizational reporting.

When services are delivered within a workplace, government facility, or institutional environment, personal information will be handled according to applicable privacy requirements, consent arrangements, and contractual obligations.

Individual clinical or health-related information will not be routinely disclosed to employers, managers, contracting authorities, or other organizational representatives without appropriate authorization or another lawful basis.

Where reporting is required, Fulcrum will seek to limit disclosures to the information reasonably necessary for the authorized purpose.

Depending on the engagement, reports may concern service utilization, operational coordination, or aggregated activity rather than identifiable clinical details.

7. Disclosure to Third Parties

Fulcrum does not sell or rent personal information.

Personal information may be disclosed to authorized service providers, professional advisers, or contractual partners where necessary for legitimate business operations or service delivery, subject to applicable legal safeguards.

Information may also be disclosed when required or authorized by law.

Any disclosure involving sensitive information will be assessed in light of its purpose, necessity, authorization, and applicable confidentiality obligations.

8. Information Security

Fulcrum recognizes its responsibility to implement safeguards appropriate to the sensitivity, amount, distribution, and intended use of personal information.

These safeguards may include access restrictions, secure account credentials, appropriate electronic storage, controlled information sharing, and secure disposal procedures.

Access to personal information is limited to individuals who require it for authorized purposes.

Security arrangements may vary according to the requirements of a particular institutional or contractual engagement.

No electronic communication or storage system can be guaranteed to be completely secure.

9. Retention and Secure Disposal

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, subject to applicable legal, contractual, and professional recordkeeping requirements.

Retention periods may vary depending on whether the information relates to a business inquiry, contractual arrangement, administrative record, or individual service.

Once information is no longer required, it will be securely destroyed or anonymized, as appropriate and in accordance with applicable requirements.

10. Service Providers and Information Outside Quebec

Fulcrum may use external technology or administrative service providers to support website operations, electronic communications, document management, or other business functions.

Depending on the service provider, information may be processed or stored outside Quebec or Canada.

Before communicating personal information outside Quebec, Fulcrum will undertake the assessments and implement the safeguards required by applicable legislation.

Where necessary, contractual arrangements will address confidentiality, permitted uses, access restrictions, and information security responsibilities.

11. Cookies and Website Technologies

Our website is hosted through Squarespace and may use cookies or similar technologies necessary for website functionality, security, and performance.

Additional cookies or analytics technologies may be used depending on the services enabled on the website.

Visitors may manage cookies through their browser settings and any cookie preference controls made available on the website.

Where required by applicable law, consent will be obtained for technologies that collect personal information or enable tracking beyond what is legally permitted without consent.

12. Individual Privacy Rights

Subject to applicable law, individuals may have the right to:

• Request access to personal information held about them.
• Request correction of inaccurate or incomplete information.
• Withdraw consent where legally permitted.
• Request information concerning the collection, use, or disclosure of their information.
• Request applicable forms of data portability.
• Request cessation of dissemination, de-indexing, or other remedies where legal conditions are met.
• Submit a complaint regarding the handling of their personal information.

Requests should be directed to the Privacy Officer.

Fulcrum may need to verify the identity and authority of a requester before providing access to personal information.

Requests will be addressed within applicable legal time limits.

13. Privacy Incidents

Fulcrum will take reasonable measures to reduce the risk of harm and prevent further incidents when it has reason to believe that a confidentiality incident involving personal information has occurred.

Incidents will be assessed and documented in accordance with applicable legal requirements.

Where an incident presents a risk of serious injury or meets another applicable reporting threshold, the relevant authorities and affected individuals will be notified as required by law.

14. Privacy Governance and Accountability

Fulcrum is responsible for establishing and maintaining privacy practices appropriate to the nature and scale of its operations.

These practices address the handling of personal information throughout its lifecycle, including collection, access, use, disclosure, retention, and secure destruction.

The Privacy Officer oversees privacy-related responsibilities, reviews concerns, and coordinates responses to privacy requests and complaints.

Privacy considerations are incorporated into the evaluation of new technologies, service arrangements, and information management processes.

Where required, privacy impact assessments will be completed before implementing relevant systems, services, or transfers of personal information.

15. Complaints and Inquiries

Individuals who have concerns regarding the handling of their personal information are encouraged to contact the Privacy Officer.

Complaints will be reviewed, and reasonable corrective measures will be considered where appropriate.

Individuals may also contact the relevant provincial or federal privacy authority where applicable.

16. Changes to This Policy

Fulcrum may update this Privacy Policy to reflect changes in its operations, applicable legislation, contractual requirements, or information management practices.

The most recent version will be published on our website with its updated revision date.

Where required by law, additional notice will be provided regarding material changes.

17. Contact Information

Fulcrum Rehabilitation Services Inc.
Attention: Privacy Officer
Laurent-Olivier Galarneau, D.O.
Founder & Director

Email: info@fulcrumrehab.com
Website: www.fulcrumrehab.com

For privacy-related inquiries, access requests, corrections, or complaints, please contact the Privacy Officer using the email address above.