Legal
Privacy Policy
Last Revised: June 25, 2026
Welcome to the HairGain®-Clinic Privacy Policy. Your privacy is important to us, and we are committed to protecting your personal information and personal health information.
This Privacy Policy explains how HairGain®-Clinic collects, uses, discloses, stores, and protects information collected from you through our website, online intake forms, virtual care platform, email communications, telephone communications, text messages, pharmacy coordination, and other related services.
For the purposes of this Privacy Policy, “HairGain®-Clinic,” “we,” “us,” or “our” refers to HairGain®-Clinic and its authorized representatives, healthcare professionals, staff, agents, service providers, and affiliated pharmacy-service partners, where applicable.
The most recent version of this Privacy Policy will be made available on the HairGain®-Clinic website. We may update this Privacy Policy periodically to reflect changes in applicable laws, our practices, our technology, or the services offered through the HairGain®-Clinic platform. We encourage you to review this Privacy Policy regularly.
HairGain®-Clinic is committed to safeguarding your privacy and handling your information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act, applicable provincial privacy laws, and applicable health-information privacy legislation.
1. Definitions
- Assessment : An evaluation of your hair-loss concerns, medical history, treatment request, photographs, or other submitted information by an Authorized Healthcare Professional through the HairGain®-Clinic platform.
- Applicable Law : All laws, regulations, professional standards, and regulatory requirements that apply to HairGain®-Clinic, Authorized Healthcare Professionals, pharmacy-service providers, and users.
- Authorized Healthcare Professional : A licensed physician, nurse practitioner, pharmacist, pharmacy technician, or other regulated healthcare professional involved in providing healthcare, prescribing, dispensing, counselling, or support services through or in connection with HairGain®-Clinic.
- Authorized Non-Practitioner Personnel : Administrative staff, patient-support staff, pharmacy staff, technology-support personnel, and other authorized individuals who assist with the operation of HairGain®-Clinic but do not provide medical diagnosis or treatment.
- Content : General health, hair-loss, medication, or wellness-related information made available on the HairGain®-Clinic website or platform. Content is provided for general informational purposes only and should not be treated as personalized medical advice unless specifically provided to you by an Authorized Healthcare Professional.
- HairGain®-Clinic Platform : The website, software, applications, forms, patient portals, communications systems, payment tools, prescription-related systems, and other technologies owned, operated, or used by HairGain®-Clinic to provide remote healthcare services and related support.
- Personal Health Information or PHI : Identifiable health-related information about an individual, including medical history, medications, allergies, symptoms, diagnoses, treatment plans, prescriptions, photographs submitted for assessment, pharmacy information, and insurance or coverage-related information.
- Personal Identifying Information or PII : Information that identifies or may identify an individual, including name, address, email address, phone number, date of birth, sex, payment details, and other identifying information.
- Personal Information : Includes both Personal Identifying Information and Personal Health Information.
- User : An individual who accesses, registers with, communicates with, or receives services through HairGain®-Clinic.
2. How HairGain®-Clinic Collects and Uses Information
HairGain®-Clinic collects Personal Information to provide virtual healthcare services related to hair loss, hair thinning, alopecia, and related hair-health concerns.
The information we collect may vary depending on the services requested, the province or territory where you reside, the Authorized Healthcare Professional involved, and applicable legal or professional requirements.
3. Healthcare Services
Authorized Healthcare Professionals may collect Personal Information that you provide through the HairGain®-Clinic Platform, including but not limited to:
- Your name, email address, phone number, mailing address, date of birth, and sex.
- Your medical history, medication history, allergies, family history, and relevant health conditions.
- Your hair-loss history, symptoms, duration of hair loss, scalp concerns, prior treatments, and treatment goals.
- Photographs of your scalp, hairline, crown, or other areas relevant to the assessment.
- Information about pregnancy, breastfeeding, fertility plans, hormonal history, or other health considerations where clinically relevant.
- Insurance, pharmacy, payment, and shipping information where applicable.
- Emergency contact information, if requested or provided.
This information may be collected through online intake forms, questionnaires, asynchronous messaging, telephone calls, video consultations, email, text message, or other approved communication methods.
Authorized Healthcare Professionals may use this information to assess whether virtual care is appropriate, determine whether treatment may be suitable, issue or decline prescriptions, provide counselling, create clinical notes, coordinate pharmacy services, and support follow-up care.
Audio or video portions of assessments are not routinely recorded unless you are clearly informed and consent is obtained where required.
In the event of a healthcare emergency or serious safety concern, Authorized Healthcare Professionals may contact your emergency contact or appropriate emergency services if necessary. It is your responsibility to inform your emergency contact that you have provided their information to HairGain®-Clinic and to obtain their consent where required.
4. Pharmacy Services and Prescription Fulfilment
If a prescription is issued through HairGain®-Clinic, your Personal Information may be shared with a licensed pharmacy for dispensing, compounding where appropriate, medication counselling, refill coordination, insurance support, payment processing, and shipping.
Information shared with a pharmacy may include your name, date of birth, contact information, mailing address, prescription details, allergies, medical history relevant to the prescription, payment information, and shipping information.
You may choose to use a pharmacy affiliated with or recommended by HairGain®-Clinic, or you may request that your prescription be sent to a pharmacy of your choice, where permitted by law and professional standards.
If medication is shipped to you, relevant information may be shared with shipping carriers or delivery-service providers for the purpose of completing delivery.
5. Payments, Insurance, and Third-Party Payers
HairGain®-Clinic may collect and use payment information to process consultation fees, product fees, prescription-related fees, shipping charges, or other service fees.
If you authorize an insurer, employer plan, third-party payer, or other benefits provider to pay for or reimburse any portion of your services or medication, you consent to HairGain®-Clinic, the dispensing pharmacy, or applicable service providers disclosing the information reasonably necessary to process, verify, or support coverage, payment, or reimbursement.
You are responsible for ensuring that any information submitted to a third-party payer is accurate and that you understand how that third party may collect, use, disclose, and retain your information.
6. Third-Party Service Providers
HairGain®-Clinic may use third-party service providers to support the operation of the HairGain®-Clinic Platform and related services.
These service providers may assist with:
- Website hosting and platform functionality.
- Secure data storage.
- Payment processing.
- Email, text-message, and telephone communications.
- Online forms and patient intake.
- Scheduling and appointment management.
- Prescription transmission and pharmacy coordination.
- Shipping and delivery.
- Customer support.
- Analytics, quality improvement, and security monitoring.
- Marketing communications, where permitted.
We require third-party service providers to use Personal Information only for the purposes for which they are engaged and to protect Personal Information using appropriate contractual, administrative, technical, and physical safeguards.
7. Other Services
HairGain®-Clinic may provide or coordinate additional healthcare-related services to support care delivery. These may include prescription transmission, pharmacy follow-up, refill support, treatment reminders, medication-delivery coordination, patient-support communications, review of submitted documents, or coordination of laboratory testing where clinically appropriate.
All personnel involved in providing or supporting these services are expected to follow applicable privacy and confidentiality obligations.
8. Additional Information Collection and Use
HairGain®-Clinic may collect, use, and disclose Personal Information for purposes including:
- Creating, managing, and verifying user accounts.
- Facilitating virtual healthcare assessments.
- Determining treatment eligibility.
- Supporting prescription issuance, pharmacy dispensing, and medication delivery.
- Processing payments, refunds, and related transactions.
- Providing patient support and responding to inquiries.
- Sending appointment reminders, treatment reminders, prescription updates, refill reminders, and delivery updates.
- Improving the HairGain®-Clinic Platform, services, and patient experience.
- Monitoring safety, compliance, fraud prevention, and security.
- Managing quality assurance and internal training.
- Collecting feedback and service reviews, where permitted.
- Communicating information about HairGain®-Clinic services, programs, or updates, where permitted by law and with consent where required.
- Complying with legal, regulatory, professional, and reporting obligations.
9. Personal Information Storage
Personal Information may be stored at HairGain®-Clinic offices, with authorized healthcare or pharmacy providers, or through secure service-provider systems and data centres.
Where possible, HairGain®-Clinic aims to use service providers that store and process information in Canada or North America. However, some service providers may process or store information outside your province or outside Canada. If information is stored or processed outside Canada, it may be subject to the laws of that jurisdiction.
By using the HairGain®-Clinic Platform, you consent to the storage, processing, and handling of your Personal Information as described in this Privacy Policy.
10. Retention and Deletion of Information
HairGain®-Clinic retains Personal Information only as long as necessary for the purposes described in this Privacy Policy or as required by law, professional standards, regulatory requirements, pharmacy obligations, healthcare-record retention rules, tax requirements, billing requirements, and dispute-resolution purposes.
Medical records, prescription records, pharmacy records, and other healthcare records may be subject to mandatory retention periods that vary by province or territory and by professional regulatory requirements.
You may request access to, correction of, or deletion of certain Personal Information. However, some information may not be deleted immediately if HairGain®-Clinic, an Authorized Healthcare Professional, or a pharmacy is legally or professionally required to retain it.
11. Account Deletion
You may request deletion of your HairGain®-Clinic account or certain Personal Information by contacting:
We will review and respond to your request within a reasonable time and in accordance with applicable law. In many cases, we aim to respond within 30 days. If additional time is required, we will advise you.
Account deletion does not necessarily result in deletion of medical records, pharmacy records, billing records, prescription records, or other records that must be retained under applicable law or professional standards.
12. Accessing and Correcting Information
HairGain®-Clinic strives to keep your Personal Information accurate, complete, and up to date.
You may request access to your Personal Information or request correction of inaccurate or incomplete information by contacting:
Certain information may be updated directly through your HairGain®-Clinic account if that functionality is available.
Information created by Authorized Healthcare Professionals, such as clinical notes, assessments, diagnoses, prescriptions, or professional opinions, may be corrected or amended only in accordance with applicable law and professional standards.
We may ask you to verify your identity before providing access to or making changes to your Personal Information.
If you have concerns about our privacy practices, you may contact HairGain®-Clinic first so we can try to address your concern. You may also contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy authority.
13. Medical Record Retention
HairGain®-Clinic and the Authorized Healthcare Professionals involved in your care retain medical records in accordance with applicable law, professional standards, and regulatory obligations.
Minimum retention periods may vary depending on your province or territory, the type of healthcare provider involved, and the nature of the record.
During the applicable retention period, you may request access to your medical records, subject to legal and professional limitations.
14. Disclosure of Information
HairGain®-Clinic does not disclose Personal Information except as described in this Privacy Policy, with your consent, or where permitted or required by law.
Personal Information may be disclosed in the following circumstances:
- To Authorized Healthcare Professionals involved in your care.
- To pharmacy providers involved in prescription fulfilment, counselling, compounding, dispensing, refill coordination, or delivery.
- To third-party service providers supporting the operation of HairGain®-Clinic.
- To payment processors, insurers, or third-party payers where required to process payment or coverage.
- To shipping carriers or delivery providers where required to deliver medication or related products.
- To regulatory bodies, professional colleges, insurers, legal authorities, or government agencies where required or permitted by law.
- To emergency contacts or emergency services where necessary for urgent safety reasons.
- In connection with a business transaction, such as a merger, acquisition, financing, restructuring, or sale of all or part of HairGain®-Clinic, provided appropriate safeguards are used.
- To investigate fraud, security incidents, unauthorized activity, or violations of our terms.
- To comply with court orders, subpoenas, legal proceedings, regulatory requests, or other legal obligations.
15. Pharmacy Network and Delivery
If you choose to have a prescription dispensed and delivered through a pharmacy connected with HairGain®-Clinic, your Personal Information may be shared with the pharmacy and delivery providers as necessary to process, prepare, dispense, and ship your medication.
This may include disclosure of your name, address, contact information, prescription details, delivery preferences, and other information required for safe and lawful dispensing and delivery.
Where provincial pharmacy systems or reporting requirements apply, information may also be disclosed as required by law or pharmacy regulation.
16. Laboratory Testing and Diagnostic Information
In some cases, an Authorized Healthcare Professional may recommend laboratory testing, diagnostic testing, or additional medical information before prescribing or continuing treatment.
If laboratory testing or diagnostic services are arranged or reviewed through HairGain®-Clinic, you consent to the collection, use, and disclosure of relevant Personal Information to and from laboratories, diagnostic providers, healthcare professionals, and other parties involved in your care.
You are responsible for understanding any insurance or coverage-related obligations related to laboratory or diagnostic services.
17. Consent for Collection, Use, and Disclosure
HairGain®-Clinic collects, uses, and discloses Personal Information with your consent, except where collection, use, or disclosure without consent is permitted or required by law.
Consent may be express or implied, and may be provided orally, electronically, in writing, through your use of the HairGain®-Clinic Platform, or through your submission of information.
You may withdraw consent at any time by contacting:
Withdrawal of consent may limit or prevent HairGain®-Clinic from providing services to you. For example, if you withdraw consent for the use of your medical history, photographs, pharmacy information, or contact information, we may not be able to complete an assessment, issue a prescription, coordinate pharmacy services, or provide follow-up care.
Withdrawal of consent does not affect information already collected, used, or disclosed before withdrawal, and does not override legal or professional obligations to retain records.
18. Accountability
HairGain®-Clinic is responsible for Personal Information under its control and has implemented policies and procedures intended to protect Personal Information.
Authorized Healthcare Professionals and pharmacy providers may have their own legal and professional obligations regarding the Personal Information and medical records they create, collect, use, or disclose.
HairGain®-Clinic personnel and service providers are expected to protect the confidentiality and security of Personal Information and to access Personal Information only where necessary for authorized purposes.
19. Safeguarding Information
HairGain®-Clinic uses reasonable administrative, technical, and physical safeguards to protect Personal Information against unauthorized access, use, disclosure, alteration, loss, theft, and destruction.
Safeguards may include:
- Access controls.
- Password protection.
- Encryption where appropriate.
- Secure data-storage practices.
- Staff confidentiality obligations.
- Privacy and security training.
- Limited access based on role and need.
- Secure disposal practices.
- Monitoring and security review.
- Contractual safeguards with service providers.
- Despite these measures, no method of electronic communication, internet transmission, or electronic storage is completely secure. HairGain®-Clinic cannot guarantee absolute security of Personal Information.
If we become aware of a privacy breach involving your Personal Information, we will take steps required by applicable law, which may include containment, investigation, notification, and remediation.
20. Cookies, Analytics, and De-Identified Data
HairGain®-Clinic may use cookies, pixels, analytics tools, and similar technologies to support website functionality, improve user experience, measure website performance, understand how users interact with our services, and support marketing where permitted.
Cookies may collect information such as device type, browser type, IP address, pages visited, time spent on the website, referral source, and interactions with website features.
You may be able to disable cookies through your browser settings. However, some website functions may not operate properly if cookies are disabled.
HairGain®-Clinic may use de-identified or aggregated information for internal analytics, quality improvement, compliance monitoring, research, planning, and service improvement. De-identified information will not be used to identify you.
21. Marketing Communications
HairGain®-Clinic may send you service-related communications, including appointment reminders, prescription updates, treatment reminders, refill reminders, payment notices, and delivery updates.
Where permitted by law and with consent where required, HairGain®-Clinic may also send information about services, educational content, promotions, or updates that may be relevant to hair-loss treatment or related services.
You may unsubscribe from marketing communications at any time. However, even if you unsubscribe from marketing communications, we may still send transactional or service-related communications necessary to provide healthcare, pharmacy, billing, safety, or account-related services.
22. Links to Third-Party Websites
The HairGain®-Clinic website or communications may contain links to third-party websites, platforms, pharmacies, payment processors, laboratories, delivery providers, educational resources, or other external services.
HairGain®-Clinic is not responsible for the privacy practices, content, security, or policies of third-party websites or services. Accessing third-party websites or services is at your own risk.
We encourage you to review the privacy policies of any third-party websites or services you use.
23. Children and Minors
HairGain®-Clinic services are intended for individuals who are legally able to consent to healthcare services or who have appropriate parental or guardian involvement where required by law.
If you are a parent or guardian and believe that a minor has provided Personal Information to HairGain®-Clinic without appropriate consent, please contact us at:
24. Changes to This Privacy Policy
HairGain®-Clinic may update this Privacy Policy from time to time to reflect changes in our services, privacy practices, legal obligations, technology, or operational requirements.
When we update this Privacy Policy, we will revise the “Last Revised” date above. Continued use of the HairGain®-Clinic Platform after changes are posted means you accept the updated Privacy Policy.
25. Contact
For questions, concerns, privacy inquiries, account-deletion requests, access requests, correction requests, or medical-record requests, please contact HairGain®-Clinic at:
HairGain®-Clinic will review and respond to privacy-related requests in accordance with applicable law.
Last revised: June 25, 2026
HairGain®-Clinic