SABI MIND INC - Privacy Policy

Last Updated: April 2026  |  Version 2.0  |  Next Review: April 2027

1.  Overview

This Privacy Policy establishes rules governing the collection, use, and disclosure of personal information by SABI Mind Inc. (the "Company") in the course of its business — including through its website, digital intake forms, and support programs such as the Beyond The Call EXOMIND™ Support Initiative.

This Policy is designed to comply with:

•       Personal Information Protection and Electronic Documents Act (Canada) — PIPEDA

•       Personal Information Protection Act (Alberta) — PIPA

•       Applicable Canadian Anti-Spam Legislation (CASL)

This Policy applies to all individuals whose personal information the Company collects, uses, or discloses, including clients, program applicants, website visitors, and contractors.

If you are a patient receiving clinical services, a separate Privacy Charter governing health information applies and is available at our website footer.

We reserve the right to update this Policy from time to time. The current version will always be posted at www.sabimind.com/privacy-policy. Where required by law, we will notify you of material changes.

2.  What Is Personal Information?

"Personal information" means information about an identifiable individual. It does not include a person's name, title, business address, or telephone number in their capacity as an employee of an organization.

The Company has designated a Privacy Officer accountable for the operation of this Policy. Privacy concerns, questions, and compliance issues should be directed to:

Privacy Officer — hello@sabimind.com

3.  Personal Information We Collect

For general business and website operations, the Company collects:

•       Name, address, and email address

•       Phone number

•       Preferences, comments, and inquiries submitted through our website

•       IP address and browsing data collected via website analytics (see Section 8)

For individuals applying to support programs such as the Beyond The Call EXOMIND™ Support Initiative, we may also collect the following sensitive personal information:

•       Occupational and employment information (role, employment status, years of service)

•       Self-reported symptom information (e.g., mood, anxiety, burnout, sleep, trauma-related symptoms)

•       Treatment and care history (e.g., prior counselling, medication, psychiatry, peer support)

•       Safety screening responses (e.g., medical device status, pregnancy, neurological conditions, seizure history)

•       First responder background and service history

•       Self-reported barriers to accessing care, including financial barriers

•       Goals, motivations, and voluntary free-text responses

All information provided through program application forms is self-reported and voluntary. Optional fields will not affect eligibility if left blank.

4.  Why We Collect Your Information

For general business operations, information is collected to:

•       Manage our business operations, including client relationships and transactions

•       Meet legal and regulatory requirements

•       Inform you about our products and services, where you have given consent

•       Deliver, develop, and improve our products and services

•       Conduct market research

•       Send commercial electronic messages where we have implied or express consent under CASL

For support program applications, health-related and sensitive personal information is collected exclusively to:

•       Assess your suitability for program support — not for clinical intake, diagnosis, or treatment

•       Determine whether the therapy described in the program may be appropriate for your situation

•       Identify access barriers and prioritize equitable program support

•       Administer and improve the program

Important: Submitting a program application — including any health-related information — does not establish a patient-provider relationship, does not constitute a clinical intake, and is not used for diagnosis, treatment, prescription, or medical record-keeping. The Beyond The Call EXOMIND™ Support Initiative is an access support program only. Any treatment you may access through the program will be provided by independent licensed practitioners. SABI Mind Inc. and Beyond The Call are not responsible for clinical decisions, treatment outcomes, or adverse effects.

5.  Disclosure of Personal Information

We disclose personal information only as required or authorized by law, or as described in this Policy.

General Disclosures

We may disclose general personal information to:

•       Third-party service providers retained to assist in operating our business (e.g., website hosting, analytics, email)

•       Subsidiaries and affiliates of SABI Mind Inc., for purposes consistent with this Policy

•       Parties involved in a contemplated business transaction (e.g., merger or acquisition), subject to confidentiality obligations

•       Authorities as required or authorized by law

Program Application Data — Restricted Disclosure

Sensitive personal information collected through support program application forms is subject to stricter rules:

•       Accessible only to authorized internal staff directly involved in reviewing and administering the program, on a need-to-know basis

•       Not shared with your employer, union, insurer, or any external clinical provider without your separate written consent

•       Not sold, shared with third parties for commercial purposes, or used for advertising

6.  Consent

We ask for your consent before collecting, using, or disclosing personal information, except where collection without consent is authorized or required by law. For sensitive personal information collected through program application forms, we require express consent.

You may withdraw consent at any time, unless the information is necessary to fulfil legal or reasonable business obligations. Withdrawal of consent may limit our ability to administer your application or provide certain services.

We will not send commercial electronic messages without express or implied consent as permitted under CASL. You may unsubscribe at any time using the link at the bottom of our emails.

7.  Retention and Secure Destruction

Personal information is retained only as long as necessary for the purposes for which it was collected, or as required by law. Records are rendered non-identifying or securely destroyed once no longer needed — paper records are shredded; electronic records are permanently deleted.

For support program applications, the following retention schedule applies:

Record Type

Retention Period

Applications — not accepted

Securely destroyed within 90 days of decision

Accepted participant records

Program duration + one (1) year, then securely destroyed

8.  Cookies and Website Tracking

When you visit our website, we may receive data including your IP address, page requested, and referring website. We use Google Analytics and similar tracking technologies to count return visits, report aggregate website usage statistics, and understand which features users engage with most.

Cookies are small data files stored on your device. They do not personally identify you unless you have separately provided personal information. You may disable cookies through your browser settings; however, some site features may not function as intended without them.

9.  How to Access or Correct Your Information

Upon written request, we will inform you of the existence, use, and disclosure of your personal information and provide access to it, subject to limitations permitted by applicable law. To make a request, contact our Privacy Officer in writing or by email. You may be required to verify your identity.

We respond to access requests within thirty (30) days of receipt, or as permitted under applicable legislation. A reasonable fee may apply to complex requests.

You may request correction of inaccurate or incomplete personal information by submitting a written request with supporting documentation. Corrected information will be transmitted to relevant third parties where appropriate.

We will only refuse access in circumstances permitted by law, and will explain the reason upon request.

10.  Security and Breach Notification

We protect personal information using security safeguards appropriate to its sensitivity. We will notify the Office of the Information and Privacy Commissioner of Alberta, and affected individuals where required, without delay in the event of a security breach that creates a real risk of significant harm.

Safety Notice: This Privacy Policy and any digital forms operated by SABI Mind are not monitored for crisis or emergency disclosures and are not a substitute for emergency services. If you or someone you know is in immediate distress, contact emergency services (911), Crisis Services Canada (1-833-456-4566), or Text HOME to 741741.

11.  Challenging Compliance

Inquiries or complaints about compliance with this Policy should be directed in writing to our Privacy Officer at hello@sabimind.com.

If you are unsatisfied with our response, you may have recourse under applicable privacy legislation by contacting:

•       Federal Privacy Commissioner of Canada — www.priv.gc.ca

•       Office of the Information and Privacy Commissioner of Alberta — www.oipc.ab.ca

12.  Contact

Privacy Officer, SABI Mind Inc.

Email: hello@sabimind.com

Web: www.sabimind.com/privacy-policy

SABI Mind Inc.  |  Privacy Policy v2.0  |  April 2026  |  Next Review: April 2027