Effective Date: July 8, 2025

Welcome to WholePath Wellness Ltd. (“Company”, “we”, “us”, or “our”). We operate the website www.camealsinclair.com (“Website” or “Service”). We are committed to protecting your personal information and your right to privacy.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website. Please read this policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Website.

1. INTERPRETATION AND DEFINITIONS

Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The definitions below shall have the same meaning regardless of whether they appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.

• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.

• Business (under the CCPA) refers to the Company as the legal entity that collects Consumers’ Personal Information and determines the purposes and means of processing that data, or on behalf of which such data is collected, and that conducts business in the State of California.

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to WholePath Wellness Ltd., operating the website www.camealsinclair.com. For the purposes of the GDPR, the Company is the Data Controller.

• Consumer (under the CCPA) means a natural person who is a California resident, including those temporarily outside the USA.

• Cookies are small text files placed on Your device by a website to collect standard Internet log information and visitor behavior information, including browsing history, preferences, and session data.

• Country refers to Canada.

• Data Controller (under the GDPR) refers to the Company as the legal person who determines the purposes and means of processing Personal Data.

• Device means any internet-connected device such as a computer, smartphone, or tablet that can access the Service.

• Do Not Track (DNT) is a preference You can set in Your web browser to inform websites that You do not want to be tracked. We honour DNT signals where required by applicable law.

• Personal Data is any information that relates to an identified or identifiable individual.

  • Under the GDPR, this includes information such as name, identification number, location data, online identifier, or factors specific to an individual’s identity.

  • Under the CCPA, it includes information that identifies, relates to, describes, or could reasonably be linked directly or indirectly with a Consumer.

• Sale (under the CCPA) refers to the sale, rental, release, disclosure, or transfer of a Consumer’s Personal Information to another business or third party for monetary or other valuable consideration. We do not sell personal information.

• Service refers to the Website and all associated services offered by the Company.

• Service Provider means any individual or company that processes data on behalf of the Company. These include third parties that provide hosting, analytics, marketing, and other services. Under GDPR, Service Providers are known as Data Processors.

• Third-party Social Media Service refers to any external social network or platform (e.g., Facebook, Google, YouTube) that may be used to register, log in, or otherwise integrate with our Service.

• Usage Data refers to data collected automatically when using the Service, such as IP address, browser type, device information, time spent on pages, and interactions with the Service.

• Website refers to the official site of WholePath Wellness Ltd., accessible at https://www.camealsinclair.com.

• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  • Under GDPR, You may be referred to as the Data Subject or the User, as You are the individual using the Service.

2. COLLECTING AND USING YOUR PERSONAL DATA

TYPES OF DATA COLLECTED

Personal Data

While using our Service, we may ask You to provide certain personally identifiable information, including but not limited to:

• Name

• Email address

• Phone number

• Mailing address

• Billing information (where applicable)

Usage Data

Usage Data is collected automatically when using the Service and may include:

• Your device’s Internet Protocol (IP) address

• Browser type

• Browser version

• Pages visited

• Time and date of visit

• Time spent on pages

• Unique device identifiers

Information from Third-Party Social Media Services

We may allow you to create an account and log in through the following social media services:

• Google

• Facebook

• YouTube

• Instagram

  If You decide to register or grant us access, we may collect personal data already associated with your social media account.

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies may include:

• Cookies or browser cookies

• Web beacons

• Pixels

  You can set your browser to refuse all cookies or to indicate when a cookie is being sent.

You can set your browser to refuse all cookies or to indicate when a cookie is being sent.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

• Necessary / Essential CookiesType: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality CookiesType: Persistent Cookies Administered by Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

3. USE OF YOUR PERSONAL DATA

We use the collected data for various purposes, including:

• To provide and maintain our Service

• To manage Your Account

• To contact You with newsletters, updates, and promotional content

• To the performance of a purchase contract for products, services or items

• To analyze usage and improve user experience

• To manage Your requests

• To detect, prevent, and address technical issues

• To fulfill legal obligations

We may share your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to advertise on third party websites to You after You visited our Service, for payment processing, to contact You.

• For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

4. RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We may retain and use Your data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

5. TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your province, country, or other governmental jurisdiction where data protection laws may differ.

By submitting your data, you agree to this transfer, including transfers to servers in Canada, the United States, and other countries as required for operations.

6. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose Your Personal Data:

• To Service Providers: To perform business-related functions (e.g., hosting, data analysis, email delivery).

• For Legal Reasons: If required by law or in response to valid legal requests.

• Business Transfers: If the Company is involved in a merger, acquisition, or asset sale.

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

7. DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA

Third-party vendors we use may process your data for:

• Hosting and backend infrastructure (e.g., Systeme.io, Jane App, Calendly)

• Email marketing (e.g., ConvertKit, Systeme.io)

• Analytics (e.g., Google Analytics)

• Video and media services (e.g., YouTube, Vimeo)

Each third-party provider’s privacy policy governs their use of your personal data.

• Google Their Privacy & Terms web page: https://policies.google.com/privacy

• ConvertKit Their Privacy Policy can be viewed at https://convertkit.com/privacy

Systeme.io

We use Systeme.io as a third-party platform to power parts of our website services, including but not limited to email marketing, landing pages, sales funnels, and online course delivery. By interacting with these features (such as subscribing to a newsletter, downloading a resource, or purchasing a course), your Personal Data may be processed and stored on Systeme.io's secure servers.

Systeme.io acts as a Service Provider (as defined under the GDPR and CCPA), meaning it processes your information solely on our behalf and in accordance with our instructions. Systeme.io implements industry-standard security measures and is compliant with international data protection standards, including the General Data Protection Regulation (GDPR).

Your data submitted via forms or other opt-ins hosted on Systeme.io may include:

• Name

• Email address

• IP address

• Any responses to questions on opt-in or checkout forms

We use this data for purposes such as email communication, delivering digital products, providing services, and improving our offerings. By using these features, you consent to this processing under the applicable privacy laws.

You can read Systeme.io’s privacy policy here: https://systeme.io/privacy-policy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy

• PayPal Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

8. GDPR PRIVACY (FOR EEA AND UK USERS)

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

If you are from the European Economic Area (EEA) or the UK, you have the following rights:

• Right to access, update or delete your data

  • You can access, update or delete aspects of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You.

• Right to rectification

  • You have the right to have any incomplete or inaccurate information We hold about You corrected

• Right to object

  • This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Right to data portability

  • We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Right to withdraw consent

  • You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

To exercise any of these rights, contact us at info@camealsinclair.com.

Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

9. YOUTUBE AND DATA CONTROLLER

Our site may use embedded content from YouTube. YouTube may collect user data in accordance with Google’s privacy policies. We are not responsible for the privacy practices of YouTube. To learn more, see Google’s Privacy Policy.

10. CCPA PRIVACY (FOR CALIFORNIA RESIDENTS)

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

• The right to notice

  • You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.

• The right to access / the right to request

  • The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.

• The right to say no to the sale of Personal Data

  • You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.

• The right to know about Your Personal Data

  • You have the right to request and obtain from the Company information regarding the disclosure of the following:

    • The categories of Personal Data collected

    • The sources from which the Personal Data was collected

    • The business or commercial purpose for collecting or selling the Personal Data

    • Categories of third parties with whom We share Personal Data

    • The specific pieces of Personal Data we collected about You

• The right to delete Personal Data

  • You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

• The right not to be discriminated against

  • You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:

    • Denying goods or services to You

    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

    • Providing a different level or quality of goods or services to You

    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us or visit our “Do Not Sell My Personal Information” section or web page.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.

If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

• From Our “Cookie Consent” notice banner

• Or from Our “CCPA Opt-out” notice banner

• Or from Our “Do Not Sell My Personal Information” notice banner

• Or from Our “Do Not Sell My Personal Information” link

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

• “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

"Do not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light Law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

11. CHILDREN'S PRIVACY

Our Service is not intended for individuals under the age of 13. We do not knowingly collect data from children. If you believe we have inadvertently collected such data, please contact us immediately.

12. SECURITY OF YOUR PERSONAL DATA

We employ commercially reasonable safeguards to protect your data, including secure servers, encryption, and access controls. However, no method of transmission or storage is 100% secure.

13. LINKS TO OTHER WEBSITES

Our Service may contain links to other websites. We are not responsible for the content or privacy practices of such sites. We encourage users to read the privacy policies of any third-party site.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. We will notify You of any changes by posting the new policy on this page and updating the “Effective Date” at the top.

15. CONTACT US

If you have any questions or concerns about this Privacy Policy, contact us at:

WholePath Wellness Ltd.

Email: info@camealsinclair.com