Privacy Policy
Version 2 · Effective date: 10 November 2026
1. Who we are, and who is responsible for your information
Curalia is operated by Tigris Guardians Inc. (“Curalia”, “we”, “us”). Curalia is a technology platform that lets patients in Ontario book and attend virtual (video or voice) minor-ailment consultations with licensed pharmacists at partner pharmacies.
Two sets of rules apply.
- Your visit record belongs to the pharmacy. When you book and attend a visit, the partner pharmacy you choose is the health information custodian of your visit record under Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). Curalia handles that record only on the pharmacy’s behalf and on its instructions, as its agent. Your care is provided by the pharmacy and its pharmacists, who remain responsible for your health record under their professional and college rules.
- Your account belongs to you and is kept by Curalia. Curalia keeps your account (for example your name, sign-in details, saved address, family members and your privacy choices) so that you can use the service with any partner pharmacy. Curalia is responsible for that account information under Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).
2. What we collect
- Account and identity information: your name, date of birth, sex as shown on your health card, the language you use, your email address, and, if you sign in with a text-message code, your mobile phone number. If you sign in with Google or Apple, we receive your name and email address from them.
- Family members: if you book for someone in your care, their name, date of birth, sex as shown on their health card, and your relationship to them. By adding a family member you confirm that you are legally entitled to give us their information and to decide about their care.
- Location and province: to show nearby partner pharmacies and to confirm you are in Ontario at the time of a consultation (you attest to this before each visit). If you allow location access, your approximate position (rounded to about one kilometre on the web) is used to work out your province and is not stored.
- Health-card number and home address, for each visit: when you book, you give your full Ontario health-card number and your home address. The pharmacy needs both: the number to bill OHIP for your visit, and your address because Ontario law requires it on a prescription. Both are kept with that visit, encrypted with a key held in Canada, and the full number can be opened only by the pharmacy that treats you (every time it is opened is logged). Your address is printed on any prescription the treating pharmacy issues. The copy Curalia keeps with the visit, including the full health-card number, is deleted 30 days after the visit is booked; the pharmacy keeps its own record as the law requires. Your full health-card number is never saved to your account: your profile keeps only a masked form of the card (the last 3 digits), and a download of your data shows only those last 3 digits. If you scan your card with your camera, the picture is read on your device and is not sent to us or stored. The pharmacist also checks your physical health card with you on the call.
- Your home address, saved to your account: when you book a visit for yourself, we also save the home address you give to your account, encrypted with the same key held in Canada, so it is filled in for you if you book again soon. It is kept until 30 days after your most recent visit is booked, then deleted; each new booking starts the 30 days again. You can remove it sooner in your profile, and it is deleted if you close your account. An address you give for a family member’s visit is not saved to your account. Only you can see the saved address in the app (every time it is opened is logged).
- Booking and consultation details: the reason for your visit, your answers to the safety questions for your condition, appointment times, the pharmacy and pharmacist you saw, the outcome, any prescription, and any information you choose to share for your consultation (for example current medications and allergies; sharing them is optional, though it helps the pharmacist review your safety).
- Prescription photos you send: if you send a photo of a paper prescription to a pharmacy, we keep the photo, any note you add, and the pharmacy’s progress updates, including the reason if the pharmacy cannot fill it.
- Your family doctor or nurse practitioner: if you give us their details, their name, clinic, phone and fax number (see section 3).
- Shop orders: if you order from a pharmacy’s shop, your name and the items you ordered.
- Waitlist: if Curalia is not yet available in your province and you join the waitlist, your email address, province and language.
- Consent records: your acceptance of our terms, your virtual-care consent and in-province attestation captured each visit, the version and language of the text you were shown, and every change to your privacy and email choices.
- Technical information: device and app data needed to run the service securely (for example sign-in events, notification tokens, and audit logs).
We do not record calls, we do not use analytics or advertising trackers, and we do not keep clinical notes: the pharmacist documents your care in the pharmacy’s own record.
3. Why we collect it
- To let you find a pharmacy, book a consultation, and connect by secure video or voice.
- To let the pharmacy identify you, verify your health card, bill OHIP for your visit, and provide your care.
- To let a pharmacy prepare a prescription you sent by photo. The pharmacy still needs your original paper prescription when you pick it up.
- To notify you about your appointments and orders. Notifications never name your condition or your medication. A notification on your lock screen may say that you have a visit, that a pharmacist is ready for you, the name of the pharmacy, or that an order is ready to pick up.
- To keep the service safe: we keep audit logs of actions taken on records, and of who viewed them, so that access can be reviewed.
- To meet legal obligations, including the obligations the pharmacies have under PHIPA and under Ontario’s pharmacy laws.
Your family doctor or nurse practitioner. If a pharmacist prescribes a medicine for you, Ontario law requires the pharmacist to tell your family doctor or nurse practitioner, if you have one, what was prescribed. This does not depend on your choice. If you have given us their details, the pharmacy uses them; if not, the pharmacist will ask you during the visit.
Choices you control (in your profile, and you can change them at any time):
- Visit summaries for your family doctor: off unless you turn it on. When it is on, the pharmacy may also send your family doctor a short summary of visits where nothing was prescribed. The pharmacy sends it, usually by fax. Visits you book for family members are not included.
- Research use: off unless you turn it on. When it is on, your finished visits may be counted in summaries made only of totals by month, condition and outcome. These summaries never include your name, contact details, or any detail that identifies you, and small groups are hidden. Curalia prepares these totals only where the pharmacy that treated you has authorized it. No summary is being produced at present.
- Occasional email from Curalia: off unless you turn it on. When it is on, Tigris Guardians Inc. may email you health tips and service updates. These emails are never about your visits. Every email has a link to stop them, and you can turn them off in your profile at any time.
We do not sell your data. We do not use your health information for advertising. We do not share your information with data brokers.
4. Where your data lives
Your health records (your bookings, consultation details, prescriptions, prescription photos, health-card numbers and addresses) are stored and processed in Google Cloud’s northamerica-northeast1 region in Montréal, Canada. Backups are kept in the same region.
Video and voice consultations run on Curalia’s own self-hosted media server in Montréal. Your call media never leaves Canada, and calls are not recorded: the platform has no recording feature.
Some of the services in section 5 process limited information outside Canada, mostly in the United States. When that happens, the information may be subject to the laws of that country, and its courts, law enforcement and national security authorities may be able to obtain it. We send these services only what they need, never your health records.
All data is encrypted in transit (TLS for app traffic; DTLS-SRTP for call media) and encrypted at rest (AES-256).
5. Who can see your information
- Your pharmacy: the pharmacists, technicians and owner of the partner pharmacy you book with can see the records they need to care for you, prepare your prescription and submit the claim for your visit. Access is enforced so that pharmacy staff can only see records belonging to their own pharmacy.
- Curalia: the staff tools Curalia uses to run the service do not show health records. A small number of authorized Curalia personnel can reach the underlying systems to operate, support and secure the platform; they may open records only for a recorded support or security reason, and that access is logged.
- Your family doctor or nurse practitioner: when a medicine is prescribed, and otherwise only if you turn on visit summaries (see section 3).
- Our service providers, listed below, only to run the parts of the service they provide.
- No one else, except where the law requires disclosure.
Service providers
| Provider | What it does | What it receives | Where |
|---|---|---|---|
| Google Cloud and Firebase | Hosting, database, file storage, server functions, encryption keys, backups | The health records described above | Montréal, Canada |
| Google (Firebase Authentication and Identity Platform) | Signing in to your account | Your name, email address, phone number, and sign-in events | United States and other countries |
| Google and Apple (Sign in with Google, Sign in with Apple) | Signing in with an account you already have, if you choose to | That you signed in to Curalia; they give us your name and email address | United States and other countries |
| Google (sign-in text messages and reCAPTCHA) | Sending text-message sign-in codes and checking that a sign-in is not automated | Your mobile phone number; your browser and device details | United States and other countries |
| Google, Apple (app verification) | Confirming that requests come from the genuine Curalia app | Device and app details | United States and other countries |
| Google Maps Platform | Maps, finding pharmacies, working out your province, and finding your address as you type it when booking | What you type in the address or pharmacy search, the map area you view, and your approximate position | United States and other countries |
| Apple (location services on iPhone) | Working out your province on an iPhone | Your approximate position | United States and other countries |
| OpenStreetMap | A backup map, used only if the main map cannot load | Your IP address and the map area you view | Outside Canada |
| Firebase Hosting | Serving this website and the web app | Your IP address and browser details | United States and other countries |
| Google Cloud Logging | Technical logs used to keep the service working and secure | Technical events, which can include account identifiers | Google Cloud, which may include locations outside Canada |
| Twilio SendGrid | Sending emails, such as sign-in links, email verification, waitlist news and, if you chose them, occasional emails from Curalia | Your email address and the content of that email (never your health records) | United States |
| Apple Push Notification service and Firebase Cloud Messaging | Delivering notifications to your device | A device token and the text of each notification (see section 3) | United States and other countries |
| Stripe | Subscription payments from partner pharmacies (patients do not pay through Curalia) | Pharmacy billing details only, no patient information | Canada and the United States |
| Google Fonts | The typeface on this website | Your browser’s IP address and browser details | United States and other countries |
6. How long we keep it
| Information | How long Curalia keeps it |
|---|---|
| The record of each visit: who was seen, the condition, the outcome, any prescription, the claim, your consent for that visit, and any notice sent to your family doctor | Kept on behalf of the pharmacy that treated you for 10 years after your last visit to that pharmacy, or until 10 years after a child would turn 18, whichever is longer, as Ontario law requires of the pharmacy. Then deleted. Closing your account does not shorten this |
| Full health-card number and home address given for a visit (the copy kept with that visit) | Deleted 30 days after the visit is booked |
| Home address saved to your account | Deleted 30 days after your most recent visit is booked (each new booking starts the 30 days again), or sooner if you remove it in your profile or close your account |
| Prescription photos | Deleted when the pharmacy finishes with the request (picked up, declined or cancelled), and in any case 14 days after you send it |
| Shop orders | Your name is removed from the order after 1 year, or when you close your account |
| Audit logs (actions taken on records, and who viewed them) | 10 years |
| Waitlist entries | Until you close your account or ask us to remove it. We email you once, when Curalia launches in your province, and never use the address for anything else |
| Your account: profile, family members, saved conditions, privacy and email choices, acceptance of our terms, device tokens | While your account is open. Deleted when you close your account |
| Backups | Deleted information can remain in encrypted backups in Canada for up to 14 weeks before it is erased. We use backups only to recover the service after a failure |
The pharmacist also documents your care in the pharmacy’s own record. The pharmacy keeps that record under Ontario College of Pharmacists record-keeping requirements, and Curalia does not control it.
7. Your rights
- Access and correction: you can download what Curalia holds about you at any time in the app (Profile, then Privacy, then Download my data). To see or correct your visit record, write to the pharmacy that treated you, or write to us and we will pass your request to the pharmacy within two business days. The pharmacy must answer within 30 days, and may take up to 30 more days if it tells you why. For your account information, write to our Privacy Officer; we will answer within 30 days.
- Closing your account: you can close your Curalia account at any time in the app. When you do, we delete the information we hold for our own purposes: your profile, your saved address, your family members, your saved conditions, your privacy and email choices, your device tokens and any waitlist entry. The record of each visit you had belongs to the pharmacy that treated you. Ontario law requires the pharmacy to keep that record for at least 10 years after your last visit, or until 10 years after a child would turn 18. We keep it on the pharmacy’s behalf for that period, only that pharmacy can see it, and it is then deleted. You can ask the pharmacy for a copy of it, or to correct it, at any time.
- Withdraw consent: you may withdraw your consent to virtual care at any time before or during a consultation. Withdrawing does not undo what has already been recorded or done.
- Complaints: you may complain to us, to the pharmacy, to the Information and Privacy Commissioner of Ontario about your visit record, or to the Office of the Privacy Commissioner of Canada about your Curalia account.
8. If you are a pharmacist, technician or pharmacy owner
For pharmacy staff and owners who use Curalia we keep: your name, email address, mobile phone number (for two-step sign-in), professional role, College registration number, the pharmacies you work with and when your access started and ended, the checks made of your registration, and a log of the actions you take on patient records. We use this to control access to patient records, to meet the pharmacies’ and our own legal duties, and to keep an audit trail. Your name and registration number appear on prescriptions you issue and are kept with them. We keep your account while it is open, and the audit trail and prescription details for the periods in section 6. Owners’ subscription payments are handled by Stripe. PIPEDA applies to this information, and the rights in section 7 apply to you.
9. If something goes wrong
If personal health information is lost, stolen, or used or disclosed without authority, we will contain the incident and notify the affected pharmacies at the first reasonable opportunity. The pharmacy will notify you and, where required, the Information and Privacy Commissioner of Ontario, and we will support it in doing so. Where the incident involves account information that Curalia is responsible for and creates a real risk of significant harm, we will notify you ourselves and report to the Office of the Privacy Commissioner of Canada. We maintain a written breach-response protocol.
10. Not for emergencies
Curalia is not for medical emergencies. If your symptoms are severe, call 911 or go to the nearest emergency department.
11. Contact
Privacy Officer, Tigris Guardians Inc.
[corporate mailing address: to be added before this policy is published as final]
Email: contact@tigris-guardians.com
You can write to the Privacy Officer to ask a question, to ask for the information we hold about you, to ask for a correction, or to make a complaint. We will answer within 30 days.
Information and Privacy Commissioner of Ontario: www.ipc.on.ca
Office of the Privacy Commissioner of Canada: www.priv.gc.ca
12. Changes to this policy
If we make material changes, we will post the updated policy here with a new version number and effective date, and the app will ask you to read and accept the new version before you continue.