ADELE WELLNESS, INC.
PRIVACY POLICY
Last updated: May 28th, 2026

Adele Wellness, Inc., an Ontario corporation (“Adele Wellness”, “we”, “us”, or “our”), respects
your privacy and is committed to protecting the personal information it collects through the
website located at adeletevlin.com (the “Website”). This Privacy Policy explains what personal
information we collect, how we use and disclose it, and the choices available to you. It is
incorporated into and forms part of our Website Terms of Use.
1. SCOPE OF THIS POLICY
(a) This Privacy Policy applies to personal information that we collect through the Website
and through related communications with you, including our newsletter, our text message
program, and the free resources we make available. It is intended to meet our obligations
under the Personal Information Protection and Electronic Documents Act (Canada) and
other applicable privacy laws.
(b) In this Privacy Policy, “personal information” means information about an identifiable
individual, as that term is understood under applicable privacy law. It does not include
information that has been aggregated or anonymized so that it can no longer be associated
with you.
(c) When you purchase or enrol in a paid program, product, or service, or use a separate
platform or website (such as identityascensionmethod.com or a checkout provider),
additional or different privacy terms may apply. You should review the privacy notices
provided at the point of purchase or on those platforms.
2. PERSONAL INFORMATION WE COLLECT
(a) Information you provide. We collect personal information that you choose to provide,
which may include your name, email address, telephone number, mailing address, billing
information, the contents of messages and inquiries you send us, your responses to
surveys or intake forms, and any testimonials, reviews, or other materials you submit.
(b) Payment information. If you make a purchase, your payment is processed by our third-
party checkout and payment provider, ThriveCart and its integrated payment processors.
We do not collect or store complete payment card numbers. We may receive limited
transaction information, such as confirmation of payment and the last digits of a card.
(c) Information collected automatically. When you visit the Website, we and our service
providers may automatically collect information about your device and your use of the
Website, including your IP address, browser type, device identifiers, pages viewed, links
clicked, and the dates and times of your visits. We collect this information using cookies
and similar technologies, and through analytics tools such as [Google Analytics].

(d) Information from third parties. We may receive personal information about you from
third parties, such as social media platforms when you interact with our content, our
service providers, and people who refer you to us.
3. HOW WE USE PERSONAL INFORMATION
We use personal information for the following purposes:
(a) to operate, maintain, and improve the Website and the free resources;
(b) to respond to your inquiries and provide customer support;
(c) to administer your newsletter subscription and to send you newsletters, updates, and
marketing communications where you have consented to receive them;
(d) to operate our text message program where you have opted in;
(e) to facilitate your purchase or enrolment in our programs, products, and services,
including by directing you to the relevant checkout or platform;
(f) to personalize your experience and the content and offers we present to you;
(g) to understand how the Website is used and to measure the effectiveness of our content
and marketing, including through analytics;
(h) to protect the security and integrity of the Website and to detect and prevent fraud and
misuse;
(i) to comply with our legal and regulatory obligations; and
(j) for any other purpose for which you provide consent.
4. CONSENT
(a) We collect, use, and disclose your personal information with your consent, except where
otherwise permitted or required by law. Depending on the circumstances, your consent
may be express, for example when you subscribe to our newsletter or opt in to our text
message program, or implied, for example when you provide information in the course of
an inquiry.
(b) You may withdraw your consent at any time, subject to legal and contractual restrictions
and reasonable notice, by contacting our Privacy Officer using the details in Section 15.
If you withdraw your consent, we may be unable to provide certain features or services to
you.
(c) Our commercial electronic messages are also governed by Canada’s anti-spam
legislation. Every commercial electronic message we send includes an unsubscribe
mechanism, and you may opt out of our text message program at any time by replying
STOP.
5. COOKIES AND SIMILAR TECHNOLOGIES

(a) A cookie is a small data file stored on your device. We use cookies and similar
technologies to operate the Website, remember your preferences, understand how the
Website is used, and support our marketing.
(b) We may use analytics and advertising technologies provided by third parties, including
[INSERT ANALYTICS PROVIDER] and [INSERT ADVERTISING OR PIXEL
PROVIDER, e.g., Meta Pixel], which may collect information about your use of the
Website over time and across other websites.
(c) You can set your browser to refuse some or all cookies, or to alert you when cookies are
being used. If you disable cookies, some parts of the Website may not function as
intended.
6. WHEN AND WITH WHOM WE SHARE PERSONAL INFORMATION
(a) Service providers. We share personal information with third-party service providers that
perform services on our behalf, under contracts that require them to protect the
information and use it only for the purposes we specify. These currently include
ThriveCart (checkout and payment processing) and GoHighLevel (customer relationship
management, email and text message delivery, and marketing automation), and may
include [INSERT OTHER PROVIDERS, e.g., email delivery, web hosting, analytics,
advertising, scheduling, and webinar or course-hosting platforms].
(b) Legal and protective disclosures. We may disclose personal information: (i) to comply
with applicable law or legal process; (ii) to respond to lawful requests by public
authorities; (iii) to enforce our Terms of Use or other agreements; (iv) to protect the
rights, property, or safety of Adele Wellness, our users, or others; and (v) where
otherwise permitted or required by law.
(c) Business transfers. If we are involved in a merger, acquisition, financing,
reorganization, or sale of assets, personal information may be transferred as part of that
transaction, subject to the recipient’s commitment to protect it consistent with this
Privacy Policy.
(d) We do not sell or rent your personal information.
7. STORAGE AND TRANSFER OUTSIDE CANADA
Some of our service providers, including ThriveCart and GoHighLevel, are located in the United
States, and your personal information may be stored and processed in the United States or in
other countries outside Canada. While your information is in another country, it is subject to the
laws of that country and may be accessible to courts, law enforcement, and other authorities in
that country under those laws. By using the Website and providing personal information to us,
you acknowledge and consent to this transfer, storage, and processing. You may contact our
Privacy Officer for more information about our practices in this regard.
8. RETENTION
We retain personal information only for as long as necessary to fulfil the purposes for which it
was collected, to maintain our business records, and to comply with our legal obligations.

[INSERT RETENTION PERIODS OR CRITERIA, IF AVAILABLE]. When personal
information is no longer required, we take reasonable steps to securely destroy, erase, or
anonymize it.
9. SAFEGUARDS
We maintain reasonable physical, technical, and administrative safeguards designed to protect
personal information against loss, theft, and unauthorized access, use, or disclosure, appropriate
to the sensitivity of the information. No method of transmission over the internet or of electronic
storage is completely secure, and we cannot guarantee absolute security. You provide personal
information to us at your own risk.
10. YOUR RIGHTS: ACCESS, CORRECTION, AND CHOICES
(a) Subject to certain exceptions under applicable law, you have the right to request access to
the personal information we hold about you and to request that we correct information
that is inaccurate or incomplete.
(b) You may also unsubscribe from our marketing communications, opt out of our text
message program, and withdraw your consent as described in Section 4.
(c) To make a request, contact our Privacy Officer using the details in Section 15. We may
need to verify your identity before responding, and we will respond within the time
required by applicable law.
11. CHILDREN
The Website is intended for adults and is not directed to children. We do not knowingly collect
personal information from children. If you believe that a child has provided us with personal
information, please contact our Privacy Officer and we will take reasonable steps to delete it.
12. THIRD-PARTY WEBSITES
The Website may contain links to third-party websites and platforms that we do not control. This
Privacy Policy does not apply to those websites, and we are not responsible for their privacy
practices. We encourage you to review the privacy policy of any third-party website you visit.
13. RESIDENTS OF OTHER JURISDICTIONS
If you are located in the European Economic Area, the United Kingdom, or a jurisdiction such as
California that grants residents specific privacy rights, additional rights may apply to you,
including rights of access, deletion, portability, and objection. If you wish to exercise any such
right, please contact our Privacy Officer and we will respond as required by applicable law.
[DRAFTING NOTE: if Adele Wellness actively markets to or routinely serves individuals
in the EU, UK, or California, this Policy should be supplemented with the specific
disclosures those laws require, including legal bases for processing and a description of
data-subject rights and request procedures.]
14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will post the updated
policy on the Website and revise the “Last updated” date above. Your continued use of the
Website after an updated Privacy Policy is posted constitutes your acknowledgement of the
updated policy.
15. CONTACT US AND PRIVACY OFFICER
If you have any question, concern, or request regarding this Privacy Policy or your personal
information, please contact our Privacy Officer:
Privacy Officer: [INSERT NAME]
Adele Wellness, Inc.
5700 - 100 King Street West, Toronto, Ontario M5X 1C7
Email: [INSERT PRIVACY CONTACT EMAIL, e.g., support@adeletevlin.com]
If you are not satisfied with our response, you may have the right to make a complaint to the
Office of the Privacy Commissioner of Canada.