These Terms of Use and Privacy Notice (“Terms”) govern your access to and use of the website located at mywellnesswithin.ca (“the Website”), owned and operated by Mirco Occupational Therapy Professional Corporation, carrying on business as Wellness Within (“Wellness Within”, “we”, “us”, or “our”).

This document also serves as the written public statement of information practices required of health information custodians under the Personal Health Information Protection Act, 2004 (PHIPA), s. 16, in connection with the Virtual OT Psychoeducation Sessions offered by Celia Mirco, Registered Occupational Therapist.

By accessing or using this Website, you agree to be bound by these Terms. If you do not agree, please do not use this Website.

Wellness Within is a trade name of Mirco Occupational Therapy Professional Corporation, a professional corporation incorporated under the laws of Ontario, Canada. The Corporation is directed by Celia Mirco, a Registered Occupational Therapist in good standing with the College of Occupational Therapists of Ontario (COTO) and a Registered Psychotherapist.

The Website provides information about two legally and clinically distinct service streams:

• The Wellness Within Experience — a five-day restorative wellness retreat facilitated by Celia Mirco in her capacity as a wellness retreat facilitator. This is not a regulated health service and is not governed by COTO standards. General liability insurance applies. Personal information collected in connection with the retreat is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA).

• Virtual OT Psychoeducation Sessions — three individual occupational therapy psychoeducation sessions delivered by Celia Mirco in her regulated capacity as a Registered Occupational Therapist, governed by COTO standards and the Occupational Therapy Act, 1991 (Ontario). Personal health information collected in connection with these sessions is governed by the Personal Health Information Protection Act, 2004 (PHIPA).

While these two service streams are legally and clinically distinct, Wellness Within applies PHIPA standards to all personal information collected from clients and prospective clients in connection with all of its services. This reflects the Corporation’s commitment to the highest standard of privacy protection regardless of which service stream you are engaging with. PIPEDA continues to apply as the governing federal legislation for commercial activity, and the rights and complaint processes under both PHIPA and PIPEDA remain available to all individuals.

The content on this Website is for informational and promotional purposes only. Nothing on this Website constitutes medical advice, occupational therapy assessment or treatment, psychotherapy, or any other regulated health service.

Accessing this Website does not establish a therapeutic or clinical relationship between you and Celia Mirco or Wellness Within. A clinical relationship under COTO standards, where applicable, is established only upon execution of a signed Virtual OT Psychoeducation Series — Consent & Service Agreement, and following the informed consent process required under the Health Care Consent Act, 1996 and COTO’s Standard for Consent (2023).

If you are experiencing a medical or mental health emergency, please contact emergency services (911) or a crisis line immediately. Do not rely on this Website for emergency support.

This section constitutes Wellness Within’s Statement of Information Practices under PHIPA, s. 16, in connection with the Virtual OT Psychoeducation Sessions.

Celia Mirco, Registered Occupational Therapist, operating through Mirco Occupational Therapy Professional Corporation, is the health information custodian for personal health information collected in connection with the Virtual OT Psychoeducation Sessions. As custodian, Celia Mirco is accountable for the protection of personal health information under PHIPA.

In connection with the Virtual OT Psychoeducation Sessions, we may collect the following categories of personal health information as defined under PHIPA, s. 4:

• Identifying information (name, date of birth, contact details)

• Physical and mental health history relevant to the provision of OT psychoeducation services

• Information about current medications, supplements, and health providers

• Information shared during sessions regarding occupational functioning, emotional wellbeing, and self-care

• Clinical notes and records generated during or following sessions

We collect only the information necessary to provide the services. Personal health information is not collected through this Website directly. It is collected through the Virtual OT Consent & Service Agreement and during the sessions themselves.

Personal health information collected in connection with the Virtual OT Sessions is collected, used, and disclosed for the following purposes:

• To assess your suitability for and deliver the Virtual OT Psychoeducation Sessions

• To support your occupational functioning, self-care planning, and wellbeing within the scope of the sessions

• To maintain clinical records in accordance with COTO record-keeping standards

• To issue OT receipts for extended health benefit purposes, where requested

• To fulfil our duty to report obligations under applicable Ontario law, where required

• To respond to requests for access to or correction of your health records

We will not use or disclose your personal health information for any purpose other than providing care to you, except where required or permitted by PHIPA or applicable law.

The collection, use, and disclosure of your personal health information in connection with the Virtual OT Sessions requires your knowledgeable consent under PHIPA and COTO’s Standard for Consent (2023). Consent is obtained through the Virtual OT Psychoeducation Series — Consent & Service Agreement, which you will be asked to sign before Session 1 commences.

You have the right to withdraw your consent to the collection, use, or disclosure of your personal health information at any time. Withdrawal of consent cannot be applied retroactively to information already collected, used, or disclosed. Withdrawal may affect our ability to continue providing services to you.

As an individual whose personal health information is held by Wellness Within in connection with the Virtual OT Sessions, you have the following rights under PHIPA:

• The right to be informed of the reasons for the collection, use, and disclosure of your personal health information

• The right to access your personal health information held by us, subject to limited exceptions under PHIPA

• The right to request correction of your personal health information if you believe it is inaccurate or incomplete

• The right to withdraw consent to the collection, use, or disclosure of your personal health information

• The right to be notified if your personal health information is stolen, lost, or accessed without authorization

• The right to make a complaint to the Information and Privacy Commissioner of Ontario (IPC) if you believe your rights under PHIPA have been violated

To exercise any of these rights, please contact us using the information in Section 12.

To request access to or correction of your personal health information, please submit a written request to info@mywellnesswithin.ca. We will respond within 30 days of receiving your request, as required by PHIPA. In limited circumstances we may require an extension of up to an additional 30 days, in which case we will notify you of the extension and the reason for it.

We may decline to provide access in limited circumstances permitted by PHIPA, including where disclosure would create a risk of harm to you or another person, or where the information is subject to legal privilege. If we decline your request, we will advise you of the reason to the extent permitted by law and inform you of your right to make a complaint to the IPC.

We maintain administrative, technical, and physical safeguards to protect your personal health information against theft, loss, unauthorized use, disclosure, modification, or destruction, in accordance with PHIPA.

If we become aware that your personal health information has been stolen, lost, or accessed without authorization, we will notify you as soon as reasonably possible, in accordance with our obligations under PHIPA.

If you have a concern about how Wellness Within has handled your personal health information in connection with the Virtual OT Sessions, you may contact us directly at info@mywellnesswithin.ca. If your concern is not resolved to your satisfaction, you have the right to make a complaint to the Information and Privacy Commissioner of Ontario:

Information and Privacy Commissioner of Ontario (IPC)

Website: www.ipc.on.ca

Phone: 416-326-3333 · Toll-free: 1-800-387-0073

2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W 1A8

Wellness Within applies PHIPA standards to all personal information collected from clients and prospective clients in connection with all of its services — including the pre-registration questionnaire, retreat registration, payment processing, and website communications — regardless of whether that information technically meets the statutory definition of personal health information under PHIPA. This approach reflects a commitment to the strongest available privacy standard and ensures consistent protection for all individuals who share information with Wellness Within. Where PIPEDA applies as the governing federal legislation for commercial activity, PHIPA standards satisfy and exceed PIPEDA requirements.

All personal information is collected, used, stored, and disclosed in accordance with the principles set out in Sections 4 and 5 of these Terms, which govern both clinical and non-clinical information. The rights described in Section 4.5, the access and correction process in Section 4.6, the breach notification obligation in Section 4.7, and the complaint process in Section 4.8 apply to all personal information held by Wellness Within, not only to personal health information collected in connection with the Virtual OT Sessions.

• Registration information (name, date of birth, email address, phone number, mailing address)

• Pre-registration questionnaire responses, including intentions, goals, logistical preferences, and any health-related information provided voluntarily for safety and planning purposes

• Payment information (processed securely; credit card details are not stored by Wellness Within)

• Communications you send to us by email or through the Website

• Website usage data collected through analytics tools, as described in Section 5.4

We collect and use your personal information to:

• Process your retreat registration and payments

• Communicate with you about the retreat, including logistics, documents, and pre-retreat preparation

• Support participant safety and appropriate facilitation during the retreat

• Issue receipts and documentation

• Comply with applicable legal obligations

We do not sell, rent, or share your personal information with third parties for commercial purposes. We may share information with third-party service providers engaged to support the delivery of the retreat (such as the retreat venue, Terra Nostra Garden Hotel), subject to appropriate confidentiality obligations consistent with PHIPA standards. We will not disclose your personal information beyond these purposes without your express consent, except where required by law.

The rights described in Section 4.5 apply to all personal information held by Wellness Within, including information collected through the pre-registration questionnaire and retreat registration process. You have the right to access and request correction of any personal information we hold about you, to withdraw consent to its use, and to be notified in the event of a breach. To exercise any of these rights, please contact us at info@mywellnesswithin.ca. We will respond within 30 days.

If you have a concern about our handling of your personal information, you may contact us directly at info@mywellnesswithin.ca. If your concern is not resolved, you may make a complaint to the Information and Privacy Commissioner of Ontario (IPC) at www.ipc.on.ca or to the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca, depending on the nature of the information and the circumstances of your concern. Both regulators are available as recourse options.

This Website is built on the GoDaddy Websites + Marketing platform and uses third-party analytics tools, which may include Google Analytics, to collect aggregated, anonymized data about how visitors use the Website. This data may include pages visited, time spent on the site, geographic region, and device type. It does not include your name or contact details unless you have submitted them through a form.

In accordance with applicable Canadian privacy law and GoDaddy’s own requirements, a cookie consent banner is displayed when you first visit this Website. Analytics tracking tools will only activate if you select Accept. If you select Decline or close the banner, no behavioral tracking data will be collected.

Third-party analytics providers, including Google, have their own privacy policies governing how they handle data collected through their tools. We encourage you to review those policies independently.

You may withdraw your consent to analytics tracking at any time by clearing your browser cookies and declining the consent banner on your next visit.

Celia Mirco is a Registered Occupational Therapist in good standing with the College of Occupational Therapists of Ontario (COTO). Her professional conduct in connection with the Virtual OT Psychoeducation Sessions is governed by COTO’s Standards of Practice (2023), Code of Ethics (2020), the Occupational Therapy Act, 1991, and the Regulated Health Professions Act, 1991.

The COTO Standards applicable to these services are publicly available at www.coto.org. You have the right to contact COTO directly with any concerns about the professional conduct of Celia Mirco:

College of Occupational Therapists of Ontario (COTO)

Website: www.coto.org

Phone: 416-214-1177 · Toll-free: 1-800-890-6570

Email: practice@coto.org

Registration for The Wellness Within Experience is initiated through this Website. Completion of the pre-registration questionnaire and payment of the deposit constitutes an expression of interest only. Your space is confirmed upon receipt of your deposit and execution of the Participant Waiver & Release Agreement.

Fees for The Wellness Within Experience and the Virtual OT Psychoeducation Sessions are disclosed to participants prior to the commencement of services. Fees are agreed upon before services start, in accordance with COTO Standard for Consent (2023), s. 2.7.

Retreat fees are payable by e-transfer to info@mywellnesswithin.ca. Credit card payments can be accommodated on request; an additional 3% processing fee applies. Full payment details are set out in the Welcome Package provided at registration.

The $500 CAD deposit is fully refundable upon written request to info@mywellnesswithin.ca on or before July 30, 2026 (midnight EST). After that date the deposit is non-refundable. The remaining balance is due September 1, 2026. Payments made after the deposit are non-refundable except at the sole discretion of the Facilitator.

Transfer of a registration to another eligible participant may be possible under conditions described in the Participant Waiver & Release Agreement. Wellness Within reserves the right to cancel, postpone, or modify the retreat in circumstances beyond its reasonable control, including natural disaster, volcanic activity, public health emergency, or government travel advisories. In such circumstances, reasonable efforts will be made to offer an alternative date or partial credit.

OT receipts are issued exclusively for the Virtual OT Psychoeducation Sessions, delivered by Celia Mirco in her capacity as a Registered Occupational Therapist. These sessions may be partially reimbursable through extended health benefit plans that cover Occupational Therapy services.

No OT receipt is issued for the Wellness Within Experience retreat. The retreat is a wellness facilitation service, not a regulated OT clinical service, and is not claimable against extended health benefit plans as an OT service. Participants are responsible for confirming their own eligibility with their insurer.

All content on this Website — including text, images, logos, graphics, design, and copy — is the property of Mirco Occupational Therapy Professional Corporation or its content licensors and is protected by applicable Canadian copyright and intellectual property law.

You may access and view the Website for personal, non-commercial purposes. You may not copy, reproduce, republish, distribute, or use any content from this Website for commercial purposes without prior written permission. Requests may be directed to info@mywellnesswithin.ca.

To the fullest extent permitted by applicable law, Wellness Within, Mirco Occupational Therapy Professional Corporation, and their respective directors, employees, contractors, and representatives shall not be liable for any direct, indirect, incidental, consequential, or special damages arising from your use of or inability to use this Website, errors or inaccuracies in Website content, or any decision made in reliance on content published on this Website.

Nothing in these Terms limits liability for gross negligence, willful misconduct, or any liability that cannot be excluded by law, including any professional liability obligations arising from Celia Mirco’s practice as a Registered Occupational Therapist under COTO standards or the Regulated Health Professions Act, 1991.

These Terms are governed by and construed in accordance with the laws of the Province of Ontario, Canada, and the federal laws of Canada applicable therein. Any dispute arising under these Terms shall be subject to the non-exclusive jurisdiction of the courts of the Province of Ontario.

Participants acknowledge that the retreat program takes place in Portugal, and that certain claims arising from events on Portuguese soil may be subject to Portuguese civil law and applicable European Union regulations. Nothing in these Terms is intended to waive the application of mandatory provisions of Portuguese or EU law where such provisions cannot be excluded by contract.

We reserve the right to update or modify these Terms at any time. The effective date of the most recent version is indicated at the top of this document. Your continued use of the Website following any modification constitutes your acceptance of the revised Terms.

Where any change to these Terms affects how we collect, use, or disclose personal information — whether or not it constitutes personal health information under PHIPA — we will take reasonable steps to notify affected individuals.

Under PHIPA, health information custodians are required to designate a contact person responsible for responding to privacy inquiries and access requests. Celia Mirco is the designated privacy contact for Mirco Occupational Therapy Professional Corporation.

Questions about these Terms, your personal information or personal health information, access or correction requests, or any aspect of our information practices may be directed to:

Celia Mirco — Privacy Contact & Director

Mirco Occupational Therapy Professional Corporation / Wellness Within

Email: info@mywellnesswithin.ca

Phone: 705-715-8808

Website: mywellnesswithin.ca