Privacy Policy

Effective Date: Feb. 25, 2026
Last Updated: Feb 25, 2026

This Privacy Policy describes how Thrive 360 (“we,” “us,” or “our”) collects, uses, discloses, and protects personal information through the Thrive 360 mobile application (the “App”).

We comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

1. Accountability

We are responsible for personal information under our control.

Privacy Officer Contact:
Name/Title: Kayla Myshaniuk, Owner
Email: kaylam@thrive360.ca
Mailing Address: 4807 62 St Stettler Alberta Canada, T0C 2L1

2. What Information We May Collect

A. Account Information

• Name

• Email address

• Phone number 

• Date of birth

• Gender

• Login credentials

B. Health & Fitness Information (Sensitive Information)

Because our App is health-focused, we may collect:

• Height, weight, BMI

• Workout logs and activity history

• Step counts

• Calories consumed/burned

• Heart rate data

• Sleep tracking data

• Fitness goals and progress metrics

Health data is considered sensitive personal information under Canadian privacy law and receives enhanced protection.

C. Device & Technical Information

• IP address

• Device type and operating system

• App usage data

• Analytics identifiers

• Crash logs

D. Third-Party Integrations

If you connect services such as:

• Apple Health

• Google Fit

• Wearable fitness devices

We collect only the data you authorize.

3. How We Obtain Consent

Under PIPEDA, we obtain meaningful consent before collecting, using, or disclosing your personal information.

• By creating an account and using the App, you consent to our collection and use of your information as described in this Policy.

• For sensitive health information, we obtain express consent (e.g., in-app permission prompts).

• You may withdraw your consent at any time (subject to legal or contractual restrictions).

To withdraw consent, contact: kaylam@thrive360.ca

4. How We Use Your Information

We use your information to:

• Provide and operate the App

• Track your fitness progress

• Deliver personalized recommendations

• Improve features and performance

• Communicate updates or support responses

• Maintain security and prevent fraud

• Comply with legal obligations

We do not sell personal or health information.

5. Disclosure of Information

We may disclose personal information:

A. Service Providers

To trusted third parties providing:

• Cloud hosting

• Analytics

• Payment processing

• Customer support

These providers are contractually required to protect your information and use it only for authorized purposes.

B. Legal Compliance

Where required by law, regulation, subpoena, or court order.

C. Business Transactions

In connection with a merger, acquisition, or sale of assets, with appropriate safeguards.

6. Cross-Border Data Transfers

Your information may be stored or processed outside of Canada (e.g., cloud hosting providers).

When this occurs:

• Information may be subject to foreign laws

• We use contractual and technical safeguards to ensure comparable protection

You may contact us for more information about cross-border transfers.

7. Data Retention

We retain personal information only as long as necessary to:

• Fulfill identified purposes

• Meet legal requirements

• Resolve disputes

• Enforce agreements

You may request deletion of your account and associated data.

8. Safeguards

We implement appropriate physical, administrative, and technical safeguards, including:

• Encryption in transit (SSL/TLS)

• Secure servers

• Role-based access controls

• Limited employee access

• Regular security monitoring

Despite safeguards, no system can guarantee absolute security.

9. Your Rights Under Canadian Law

You have the right to:

• Request access to your personal information

• Request correction of inaccurate information

• Withdraw consent (subject to limitations)

• File a complaint with our Privacy Officer

• Escalate unresolved complaints to the Office of the Privacy Commissioner of Canada

Office of the Privacy Commissioner of Canada:
Website: https://www.priv.gc.ca

For Quebec residents (Law 25), you may also request:

• Information about automated decision-making

• Data portability (where applicable)

10. Children’s Privacy

The App is not intended for children under 13.
We do not knowingly collect personal information from children without parental consent where required by law.

11. Breach Notification

If a breach of security safeguards poses a real risk of significant harm, we will:

• Notify affected individuals

• Report to the Office of the Privacy Commissioner of Canada

• Maintain breach records as required by law

12. Changes to This Policy

We may update this Privacy Policy periodically.

If material changes occur, we will notify you via:

• In-app notice

• Email notification

• Updated effective date

13. Contact Us

Thrive 360 ltd
Attn: Privacy Officer
4807 62St Stettler Alberta Canada T0C 2L1

Email: kaylam@thrive360.ca