Privacy Policy

Who we are

Our website address is:

What personal data we collect and why we collect it


When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: After approval of your comment, your profile picture is visible to the public in the context of your comment.


If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms


If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.


Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

1 General

  • 1.1 The registered SMAHOO Change Clinic (2009/02/11) now also operating its domain and has of (2022-04-30) will be branded and trading as “SMAHOO Change Clinic & Mind Spa Experience” with its registered address at 4501 37 Street NW, Ste. C205, Calgary, Alberta, T2L 2J5, CANADA (“SMAHOOMobileMindSPA”, “we”, “us” or “our”) is managing and operating the website “” and future mobile application “smahooMobile MindSPA”; “smahooMobile LifeSKILLs Café 2.0”; and “smahooMobile RElapseREScue” for Android and IOS smart phones and tablet applications powered by,, and (collectively referred to as the “smahooMOBILE MindSPA 2.0 APP”) through which it will facilitate the end-users membership subscription for Mental Health and Behavioural Change wellness remote and virtual TeleHealth counselling, coaching, relapse prevention planning and recovery continuum of care supportive services delivery, the managing the sale and delivery of various LIVE and On-Demand digital multimedia packaging as Products (“Products”) to end-users as customers, members and clients, of the hybrid LIVE supervised clinical, virtual Multimedia Self-Help and Self-Care Edu-Therapy service delivery of your (“User” or “Users” or “you” or “your”) logged in membership level benefits and/or mobile application usage once made available for download and on the go mobile service access and delivery.
  • 1.2 This privacy policy (“Privacy Policy”), together with the Terms governs your use of the smahooMOBILE MindSPA APP and describes our policies and procedures on the collection, use, disclosure, processing, transfer, and storage of the information provided to us by you. By using, browsing, accessing, or purchasing from the smahooMOBILEMindSPA APP you agree to be bound by the terms of this Privacy Policy and consent to the collection, storage, possession, dealing, handling, sharing, disclosure or transfer of your information in accordance with the terms of the Privacy Policy. We shall not use the User’s information in any manner except as provided under this Privacy Policy. Capitalized terms used if not defined shall have the same meaning as ascribed to them under the Terms.
  • 1.3 This document is an electronic record and is governed by the provisions under the Canadian Digital Charter Implementation Act, 2020 and rules made thereunder as may be applicable, and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures.
  • 1.4 This Privacy Policy sets out the type of information collected from the Users, including the nature of the Sensitive Personal Data or Information (defined hereinafter), the purpose, means, and modes of usage of such information, and how and to whom we shall disclose or transfer such information. You may at any time withdraw your consent for the collection and use of your information including Personal Information (defined hereinafter) or Sensitive Personal Data or Information. However, please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding service for which you have withdrawn your consent. It is hereby clarified that your decision to withdraw your consent will not affect the processing of Personal Information based on your previous consent prior to the withdrawal.
  • 1.5 Please take a moment to familiarize yourself with our Privacy Policy. If you do not agree with any provisions of the Terms or this Privacy Policy, we advise you to not use any future smahooMOBILE MindSPA APP or access the online version and services via, or

2 Types of information collected

  • 2.1 You may be asked to provide your information anytime you visit, access, use, or browse the smahooMOBILE MindSPA APP. We may share information and use it consistent with the provisions of this Privacy Policy. We may also combine it with other information to provide and improve our products, services, content, and advertising.
  • 2.2 You agree to provide information, which shall be true, correct, up to date, and accurate. You may access, amend, alter or require the deletion of your information partially or fully by contacting us at
  • 2.3 smahooMOBILE MindSPA APP is not directed towards minors. We do not knowingly collect Personal Information from any User who is under 18 (Eighteen) years. If we are made aware that we have collected the Personal Information of a person below the age of 18 (Eighteen) years, we will take steps to delete the information within a reasonable time frame. If a parent or guardian becomes aware that his or her child has provided his/ her information on the smahooMOBILE MindSPA APP without their consent, he or she shall contact us for the deletion of such information. In the event, wherein contravention to the Privacy Policy and Terms, a person below the age of 18 (Eighteen) uses the services, we shall not be held liable or responsible for any damage or injury suffered by such person.
  • 2.4 We may collect a variety of information from you, including your name, password, mailing address, phone number, email address, and contact preferences, including any other usage and interaction details with us or our affiliates. We may collect such information which when combined with other pieces of information available with us could reasonably allow you to be identified (“Personal Information”). Personal Information shall include but is not limited to your full name, personal contact numbers, residential address, email address, gender, or date of birth.
  • 2.5 We may also collect, receive, process, or store certain sensitive personal data or information consisting of, but not limited to:
    • 2.5.1 Password
    • 2.5.2 Financial information such as bank account or credit card or debit card or other payment instrument details;
    • 2.5.3 Goods and Services Tax Identification Number;
    • 2.5.4 Physical, physiological, and mental health conditions;
    • 2.5.5 Any detail relating to the above Personal Information categories as provided to us for providing service; and
    • 2.5.6 Any of the information received under the above Personal Information categories by us for processing, stored, or processed under lawful contract or otherwise.

3 Use of information collected

  • 3.1 We may collect, use or process your information including Personal Information and Sensitive Personal Data or Information for the following purposes:.
    • 3.1.1 For creating and giving you access to your registered account on the smahooMOBILE MindSPA  APP.
    • 3.1.2 To develop, deliver, process and improve our Products, services, and content in order to personalize and improve your experience.
    • 3.1.3 To inform you about our Products, services, offers, updates, and upcoming events, including providing you the information in relation to order confirmations, invoices, technical notices, security alerts.
    • 3.1.4 For internal analysis and research purposes such as auditing, data analysis and research to improve Our Products, services, and customer communications.
    • 3.1.5 To meet any legal or regulatory requirement or comply with a request from any governmental or judicial authority.
    • 3.1.6 To resolve any request, dispute, grievance or complaint raised by you in relation to your use of the smahooMOBILE MindSPA APP.
    • 3.1.7 To detect or monitor any fraudulent or illegal activity on the smahooMOBILE MindSPA APP.

4Disclosure of information collected

  • 4.1 We may from time to time be required to disclose the information collected from you to our trusted third-party service providers who assist us in order to facilitate the provision of services and purchase of Products on the smahooMOBILE MindSPA APP. For instance, we may share your information with third-party payment gateway provider to process transactions on the smahooMOBILE MindSPA APP. By using the smahooMOBILE MindSPA APP, you consent to any such disclosure of your information with third-party service providers. We ensure that such third-party service providers are bound by reasonable confidentiality obligations and/ or use, maintain and follow generally accepted industry and security standards with respect to such information.
  • 4.2 We may also disclose your information when such disclosure is requisitioned under any law or judicial decree or when we, in our sole discretion, deem it necessary in order to protect our rights or the rights of other Users, to prevent harm to persons or property, to fight fraud and credit risk.
  • 4.3 We may also disclose or transfer your information to any third party as a part of reorganization or a sale of the assets, division or transfer of a part or whole of us. We shall ensure that third-party to which we transfer or sell our assets will have appropriate confidentiality and security measures, at least as protective as those described in this Privacy Policy, to handle your Personal Information. You will have the opportunity to opt-out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.
  • 4.4 A third-party payment gateway provider may be required to collect certain financial information from you including, but not restricted to, your credit/debit card number or your bank account details (collectively referred to as “Financial Information”). All Financial Information collected from the you by such third-party payment gateway providers will be used only for billing and payment processes. The Financial Information collected from you is transacted through secure digital APPs of approved payment gateways which are under encryption, thereby complying with reasonably expected technology standards. The verification of the Financial Information shall be accomplished only by you through a process of authentication in which we shall have no role to play and hence, we shall bear no liability in relation to the same. We shall neither be liable nor responsible for any actions or inactions of third-party payment gateway providers or any breach of conditions, representations, and warranties given by them. We shall also not be obligated to mediate or resolve any dispute or disagreement between you and such third-party payment service providers.
  • 4.5 While we make our best efforts to ensure that your information including Personal Information, Financial Information, and Sensitive Personal Information or Data is duly protected by undertaking security measures prescribed under applicable laws, you are strongly advised to exercise reasonable discretion while providing Personal Information or Financial Information while using the services given that the Internet is susceptible to security breaches.
  • 4.6 Your information may also be transferred, stored or processed in any country other than the one where you access the smahooMOBILE MindSPA APP. For purposes of sharing or disclosing data in accordance with the Privacy Policy, we reserve the right to transfer your information outside of your country. By using the smahooMOBILE MindSPA APP, you consent to such transfer of your information outside of your country and also within our affiliates, subsidiaries, and partners whose personnel and subcontractors, provided they have agreed to ensure the same level of data protection as prescribed under this Privacy Policy and the data protection laws of India. The information may be transferred in the event it is necessary for the performance of the services, operation of the smahooMOBILE MindSPA APP, and provision of Products as agreed upon between us and the third party.


  • 5.1 The security of your Personal Information is important to us. We have implemented security policies, rules, and technical measures, as required under applicable law including firewalls, transport layer security, and other physical and electronic security measures to protect the Personal Information that it has under its control from unauthorized access, improper use, or disclosure, unauthorized modification, and unlawful destruction or accidental loss. When you submit your information on the smahooMOBILE MindSPA APP, your information is protected through our security systems. Please note that we use international and industry-recognized standards such as per applicable laws, rules, and regulations..
  • 5.2 Your information is contained within secured networks and is only accessible by a limited number of authorized persons who have access rights to such systems or otherwise require such information for the purposes provided in this Privacy Policy. These authorized persons are also under an obligation to keep such information confidential.
  • 5.3 Although we make our best possible efforts to transmit and store all the information provided by you in a secure operating environment that is not open to the public, you understand and acknowledge that there is no such thing as complete security and we do not guarantee that there will be no unintended disclosures of any information and potential security breaches. You agree not to hold us responsible for any breach of security or for any action of any third parties that receive your Personal Information or events that are beyond our reasonable control including, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, etc.

6Cookies policy

  • 6.1 Due to the communications standards on the Internet, when you visits, access or browse the smahooMOBILE MindSPA APP, we automatically receive the uniform resource locator of the site from which such you visit, access or browse the smahooMOBILE MindSPA APP, details of the website you visit on leaving the smahooMOBILE MindSPA APP, the internet protocol (“IP”) address of each User’s computer operating system, type of web browser the User is using, email patterns, and the name of the User’s internet service provider. This information is used solely to analyze overall User trends and to help us improve our services. Please note that the link between the User’s IP address and the User’s personally identifiable information is not shared with third parties without such User’s permission or except when required by law or to provide or facilitate the User with the services. Notwithstanding the above, the User acknowledges that we reserve the right to share some of the aggregate findings, including the personal information provided by the Users in an unidentifiable, aggregate form, and not the specific data with advertisers, sponsors, investors, strategic partners, and others in order to help grow the business. The amount of information sent to us depends on the settings of the web browser used by the User to access the smahooMOBILE MindSPA APPs. The User may refer to the browser used if the User wishes to learn what information is provided to us.
  • 6.2 The smahooMOBILE MindSPA APP uses temporary cookies to store certain data. We do not store Personal Information in the cookies. Information collected by us, by any means whatsoever, that does not personally identify the User as an individual (such as patterns of utilization described above) is exclusively owned by us and may be used by us and third-party service providers for technical administration of the smahooMOBILE MindSPA APPs, user administration, research, development, and other purposes.
  • 6.3 You understand that you may set or amend your web browsers to delete or disable cookies. If you choose to disable cookies on your computer or mobile telecommunication device, it may impair, degrade or restrict access to certain areas of the smahooMOBILE MindSPA APP.
  • 6.4 We may allow other companies or entities to serve advertisements to you. These companies or entities include third-party advertisement servers, advertisement agencies, advertisement technology vendors, and research firms. We may target some advertisements to you that fit a certain general profile. We do not use Personal Information to target advertisements to you. In the course of serving advertisements or optimizing the services to its Users, we may allow authorized third parties to place or recognize a unique cookie on the Users browser.
  • 6.5 You agree and understand that we do not exercise control over third-party websites displayed as search results or links on the smahooMOBILE MindSPA APP. These other sites may place their own cookies or other files on the Users’ computers, collect data or solicit personal information from the Users, over which we have no control and shall not be held responsible or liable. We do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of such websites, the websites’ provider, or the information on the website.
  • 6.6 We may keep records of telephone calls received from and make to Users for the purpose of administration of services, research, and development, training, business intelligence, business development, or User administration. We may share such telephone records with third parties when required by law or when required to provide or facilitate the User with the services.
  • 6.7 You consent to our reproduction/publishing of all testimonials and reviews given by you on the smahooMOBILE MindSPA APP in relation to the services or the Products. You agree that we may edit the testimonials and reviews provided by you and reproduce/publish such edited or paraphrased versions of the testimonials and reviews on the smahooMOBILE MindSPA APP. If the User has any concerns with the reproduction/publication of any testimonial or review provided by you, the User may contact us at

7Opt-out policy

  • 7.1 The third-party service providers with whom we may share information provided by you are not permitted to market their own services or send promotional e-mails or engage in promotional communication with you. We provide you with the opportunity to opt-out of receiving non-essential, promotional, or marketing-related communication from itself or its partners.
  • 7.2 If you wish to remove your contact information from all our mailing lists and newsletters, you can click on the “unsubscribe” link or follow the instructions in each e-mail message. Alternatively, you can contact us at . We reserve the right to limit membership based on the availability of contact information. All Users will be notified by email prior to any actions taken.

8Retention of information

  • 8.1 We will retain your information and any data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted under the applicable law.


  • 9.1 We reserve the right to amend this Privacy Policy at any time. The Privacy Policy, as and when modified, shall be updated on the smahooMOBILE MindSPA APP. We encourage you to review this Privacy Policy whenever you visit our website at to understand how your Personal Information is used.

10Grievance redressal

  • 10.1 In case, you have any questions, grievances, or complaints about this Privacy Policy, or the smahooMOBILE MindSPA APP, you may contact our grievance officer on the below-mentioned details:

Name: Shirvington Hannays
Designation: Clinical Director
Email Address:

11Governing law

  • 11.1 The terms of this Privacy Policy shall be governed and construed in accordance with the laws of India. Any dispute regarding or arising out of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts in Canada.


  • 12.1 Whenever possible, each section of this Privacy Policy shall be interpreted in a manner so as to be valid under applicable law. However, in the event any provision is held to be prohibited or invalid, such provision shall be ineffective only to the extent of such prohibition or invalidity, without invalidating the remainder of such provision or other remaining provisions of this Privacy Policy.