Version 1.2 · Effective date: March 27, 2026 · Liberation Health, British Columbia, Canada
Who We Are
Liberation Health is a health clinic based in British Columbia, Canada. This Iron Tracker tool ("the App") is provided to our patients to help monitor iron levels and recovery progress. We are committed to protecting your personal health information in compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia's Personal Information Protection Act (PIPA).
Our Privacy Officer
The person responsible for our compliance with PIPA is Matthew Conway, Clinic Director, Liberation Health.
For any privacy-related questions or requests, contact: [email protected]
Your Consent
By using this App, you provide express consent to the collection and use of your personal health information as described in this policy. You may withdraw consent at any time by discontinuing use of the App and contacting us to request deletion of your data. Withdrawal of consent will not affect the care you receive from Liberation Health.
What Information We Collect
When you use this App, we may collect the following:
- Identity information: First name, last name, email address, phone number (optional)
- Health information: Ferritin levels, haemoglobin levels, MCV, iron saturation, infusion dates, symptoms logged, and recovery progress
- Treatment information: Your treatment path (infusion, oral supplements, or monitoring), your assigned doctor, and habit tracking data
- Device-only data: If you upload a photo of your lab requisition, it is stored only on your device in temporary browser storage. It is not transmitted to our server
- Usage data: Basic session information (such as visit count) used to maintain your account and personalize your experience. No analytics or tracking data is collected
How We Use Your Information
Your information is used solely to:
- Display your iron recovery progress within the App
- Generate reports you choose to share with your doctor
- Send appointment or retest reminders to your email address (if you have provided it and opted in)
- Facilitate clinic callbacks at your request (your name, contact information, and relevant lab readings are shared with your care team when you request a callback)
- Allow Liberation Health clinical staff to support your care (only when data is synced)
We do not sell, rent, or share your personal information with third parties for marketing purposes.
Where Your Data Is Stored
Your data is transmitted securely to Liberation Health's database hosted via Supabase (our backend platform, built on PostgreSQL and hosted on AWS infrastructure), using encrypted HTTPS connections. Our Supabase project is configured to store data in a Canadian-region data centre. Row Level Security (RLS) policies ensure each patient can only access their own records. This database is accessed only by Liberation Health clinical staff to support your care and is not shared with any other organization.
A small amount of temporary session data (such as your authentication token) may be held in your browser's session storage while you are actively using the App. This is cleared when you close the browser tab.
Service Providers (Sub-processors)
We use the following third-party service providers to operate the App. Each processes personal information only as necessary to provide their services to us:
- Supabase (backend database, authentication, and API hosting) — stores your account and health data on servers in Canada. Supabase uses PostgreSQL with Row Level Security to isolate patient records
- Amazon Web Services (AWS) (infrastructure provider for Supabase) — provides the Canadian data centre (ca-central-1) where your data resides
- Email delivery service (for retest reminders, when configured) — receives only your email address and reminder content; does not store your health data
- Sentry (error monitoring) — captures application errors to help us identify and fix technical issues. No raw personal health information is transmitted to Sentry. User identifiers are hashed and truncated before transmission. Sentry Replay is configured to mask all on-screen text and block all media, ensuring no patient data is captured in error reports
- Replit (application hosting) — hosts and serves the Iron Tracker web application. Replit may process standard HTTP request metadata (such as IP addresses) as part of serving the App to your browser. No health data is stored by Replit; all patient data resides in Supabase
We do not share your data with any other third parties.
Your Rights Under PIPEDA and PIPA
You have the right to:
- Access the personal information we hold about you (use the "Download my data" button in the App, or contact us)
- Correct inaccurate information (edit your readings and profile directly in the App)
- Withdraw consent at any time by stopping use of the App and requesting deletion of your data — use the “Delete my data” button in Settings or contact us directly. Withdrawal of consent will not affect the care you receive from Liberation Health
- Request deletion of your personal information from our systems (use the "Delete my data" button or contact us)
- Data portability — download a copy of all your data in a portable format at any time
- Know how your information is being used
To exercise any of these rights, contact us at: [email protected]. We will respond within 30 calendar days, as required by BC PIPA. If you are unsatisfied with our response, you have the right to contact the Office of the Information and Privacy Commissioner for BC (OIPC) at www.oipc.bc.ca or 1-800-663-7867.
Email Communications (CASL Compliance)
If you provide your email address, Liberation Health may use it to send you:
- Retest or follow-up reminders (e.g. a 6-week reminder after your infusion)
- Important updates about your care or this App
All email communications comply with Canada's Anti-Spam Legislation (CASL). We will not use your email address for marketing or share it with third parties. Every reminder email includes a clear unsubscribe mechanism. You may also opt out at any time by contacting us at [email protected].
Data Retention
Data on our server is retained for up to 7 years from your last clinical interaction, in accordance with BC health record retention requirements (College of Physicians and Surgeons of BC). After this period, records are permanently deleted from our Supabase database. Deletion of local device data (browser storage) occurs automatically: session data is cleared when you close the browser tab, and temporary snapshots are purged after 30 days. You can request deletion of your data at any time, ahead of the 7-year retention period, using the “Delete my data” option in the App or by contacting us directly — we will remove your data from our servers within 30 days of your request.
Security
We use physical, administrative, and technical safeguards to protect your personal information. Server-side data is encrypted in transit (TLS) and at rest. Staff access is role-based and limited to those directly involved in your care. Admin access is logged for audit purposes. If you have concerns about a data breach, contact us immediately at [email protected].
Cookies and Tracking
This App does not use cookies, advertising trackers, or third-party analytics. Lab requisition files are encrypted with AES-256 and stored on secure servers located in Canada (Supabase Canada Central region). Files are accessible only to the authenticated account holder and are automatically deleted after 1 year in accordance with PIPA.
Children’s Privacy and Minor Accounts
Patients under 19 years of age may use this App with a parent or guardian’s consent. The account creation process includes an age check. If a patient identifies as under 19, they are routed through a guardian consent flow:
- The patient enters their details (name, email, treatment path)
- A consent invitation is sent to the parent or guardian’s email address
- The guardian’s email is used solely to send this one-time consent activation link — it is not used for marketing or shared with third parties
- The patient’s account is not activated until the guardian approves
- If a paid subscription is taken out, the billing account is registered in the guardian’s name
- Guardians do not have access to the patient’s health data through this App — their role is limited to account consent and billing
We do not knowingly provide unsupervised access to patients under 19. If we become aware that a minor has created an account without guardian consent, we will suspend the account promptly and notify the email address on file.
Staff Access
Access to your personal health information is strictly limited to Liberation Health clinical staff directly involved in your care. All staff operate under role-based access controls and confidentiality agreements. Staff access to patient records is logged for accountability.
Use of AI Tools
This App may use artificial intelligence tools to assist with interpreting health data and generating progress summaries. All AI-generated outputs are reviewed by a qualified clinician before being used to inform your care. Liberation Health remains fully accountable for all information recorded in your health record.
Data Breach Notification
In the event of a data breach that poses a real risk of significant harm to you, we will notify affected individuals promptly and report to the BC Office of the Information and Privacy Commissioner (OIPC) as required by law.
Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by email or in-app notice before they take effect. Continued use of the App after receiving that notice constitutes your acceptance of the updated policy.
Version history: v1.0 (March 2026) — Initial policy. v1.1 (March 25, 2026) — Added sub-processors section, data portability rights, CASL compliance, callback data disclosure, device-only storage clarification, age confirmation requirement, and version tracking. v1.2 (March 27, 2026) — Backend migration from Xano to Supabase; updated sub-processors (Supabase/AWS replaces Xano/GCP); added RLS disclosure; server-side deletion now functional via Supabase API. v1.3 (March 31, 2026) — Added Sentry and Replit as sub-processors; expanded Children’s Privacy section to describe guardian consent process; clarified consent withdrawal = deletion request; strengthened data retention wording; survey_responses added to deletion cascade.
Contact Us
Privacy Officer: Matthew Conway, Clinic Director
Liberation Health
Email: [email protected]
British Columbia, Canada
If you are unsatisfied with our response to a privacy concern, you have the right to contact the Office of the Information and Privacy Commissioner for BC (OIPC) at www.oipc.bc.ca or 1-800-663-7867.