Privacy Policy

1. Who We Are

Primal Wellness is a wellness practice operated by Primal Global Consulting S.A., a company incorporated under the laws of the Republic of Panama.

For any questions about how we handle your personal data, contact us at wellness@primalwellness.ca. We respond within 5 business days.

2. Legal Framework

This Privacy Policy is governed by and compliant with:

• Panama Law 81 of 2019 (Personal Data Protection Law), in force since March 29, 2021, and its implementing regulations under Executive Decree No. 285
• The oversight authority is the National Authority for Transparency and Access to Information (ANTAI)

Where our clients are located in other jurisdictions, we also apply reasonable standards consistent with applicable laws in those jurisdictions, including the General Data Protection Regulation (GDPR) for European residents and Canadian privacy legislation (PIPEDA) for Canadian residents.

3. What Data We Collect

3.1 Data You Provide Directly

When you book a session, sign up for our email list, or contact us, we may collect:

• Full name
• Email address
• Phone number or WhatsApp number
• General location or timezone (for scheduling purposes)
• Responses to our pre-session intake form, which may include information about your physical health, areas of tension or injury, stress levels, and wellness goals
• Payment information (processed by Stripe and Acuity Scheduling; we do not store card numbers directly)
• Communications you send us by email or WhatsApp

3.2 Health-Related Data

Our pre-session intake form asks questions about physical health, injuries, and stress. Under Panama Law 81, health data is considered sensitive personal data. We collect this information only for the purpose of providing safe, appropriate, and effective sessions. It is not shared with third parties except as described in Section 6.

Your consent to share this information is obtained at the time of booking and is separate from general consent.

3.3 Data Collected Automatically

When you visit primalwellness.ca, we may collect:

• IP address
• Browser type and version
• Pages visited and time spent
• Referring URL
• Device type

This data is collected through standard web analytics and is used only in aggregate form to understand how the site is used.

4. Why We Collect Your Data

We collect and process your personal data for the following purposes:

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Consent

Where we rely on consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To withdraw consent:

• Email us at wellness@primalwellness.ca
• Use the unsubscribe link in any email we send you
• Send a WhatsApp message requesting removal

We will action your withdrawal request within 5 business days.

Under Panama Law 81, consent for processing sensitive data (including health information) must be express and unequivocal. We obtain this separately at the time you complete our intake form.

6. Who We Share Your Data With

We do not sell your personal data. We do not share it for marketing purposes.

We share your data only with the following third-party service providers, and only to the extent necessary for them to provide their services:

All third-party providers are required to handle your data in accordance with applicable privacy laws. Where data is transferred to the United States, we rely on the contractual safeguards provided by those providers.

We may also disclose your data where required by law, by a court order, or to protect the rights and safety of individuals.

7. International Data Transfers

Primal Wellness is based in Panama. If you are booking from outside Panama, including from Canada, the United States, Europe, or the Caribbean, your data will be transferred to and processed in Panama and in the countries where our service providers operate (primarily the United States).

Under Panama Law 81, international transfers are permitted where you have consented, where the transfer is necessary to fulfill a contract with you, or where the destination country offers an adequate level of protection.

By booking a session or submitting your information through this website, you consent to your data being processed in these jurisdictions.

8. How Long We Keep Your Data

When retention periods expire, data is securely deleted or anonymized.

9. Your Rights

Under Panama Law 81, you have the following rights regarding your personal data:

To exercise any of these rights, contact us at wellness@primalwellness.ca. We will respond within 15 business days. We may ask you to verify your identity before processing your request.

If you are unsatisfied with our response, you have the right to lodge a complaint with ANTAI (National Authority for Transparency and Access to Information), the data protection supervisory authority in Panama.

10. Cookies and Tracking

Our website uses minimal tracking. We do not use advertising cookies or cross-site tracking.

We may use:

• Essential cookies: Required for the website to function (session management, security)
• Analytics: Aggregate, anonymized data on how the site is used

You can control cookies through your browser settings. Disabling cookies may affect some website functionality.

We do not use cookies to build advertising profiles or share data with advertising networks.

11. Data Security

We take reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration.

These measures include:

• HTTPS encryption on all pages of the website
• Secure third-party providers for payment and booking
• Access to personal data limited to Scott Steele as the data controller
• Session recordings stored securely and shared only with the relevant client

No method of transmission over the internet is completely secure. While we take data security seriously, we cannot guarantee absolute security.

12. Children

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that we have collected data from a minor without parental consent, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will update the "Last Updated" date at the top of this page.

For material changes, we will notify active clients by email.