Privacy Policy

Effective October 5, 2026

This Privacy Policy explains how Sulo Systems Inc. ("Sulo Systems," "we," "us") handles information in connection with Willow, our practice-management platform for psychotherapists (the "Service").

1. A note on client health information

Willow is used by therapy Practices to store information about their Clients, which may include clinical/session notes and other sensitive health information. For that data, the Practice is the data controller — it decides what's collected and why, and is responsible for its own obligations under applicable health-privacy and professional-conduct laws (for example, Ontario's Personal Health Information Protection Act or an equivalent law in another jurisdiction). Sulo Systems acts as a service provider/processor on the Practice's behalf: we store and transmit this data to operate the Service, and we don't access, use, or share it except as needed to provide, secure, or support the Service, or as required by law.

2. Information we collect

  • Account information: name, email, and role, for Practice staff and for Clients who use the client portal.
  • Practice data: client records, appointments, session/clinical notes, forms, messages, invoices, and appointment/notification preferences, entered by a Practice or its Clients.
  • Emergency contact details: if a Practice chooses to name an emergency contact, that person's name, relationship, email, and phone number, plus a record of when the Practice agreed to the emergency access procedure.
  • Payment information: handled directly by our payment processor, Stripe — Sulo Systems does not receive or store full card numbers.
  • Usage information: basic technical data (like log-in timestamps and error logs) used to operate and secure the Service.

3. How we use information

We use information to provide the Service (scheduling, messaging, forms, invoicing, video calls), to communicate with users about their account, to process payments, to maintain security and prevent abuse, and to comply with legal obligations. We do not sell personal information, and we do not use client health data for advertising.

This includes sending automated appointment-reminder emails on a Practice's behalf (by default, 24 hours before an appointment). These emails deliberately don't mention the type of session, to stay discreet in an inbox or notification preview. A Practice can turn reminders off entirely, and a Client can independently turn off reminders just for themselves — see Section 9.

4. Who we share information with

We share information with service providers who help us run Willow, under confidentiality obligations, including: Supabase (database and authentication), Vercel (hosting), Stripe (subscription billing, and — for a Practice that connects its own Stripe account — Client invoice payments made directly to that Practice), Resend (transactional email), and Daily.co (video calls for telehealth appointments, for Practices that use that feature). We may also disclose information if required by law or to protect the rights, safety, or property of Sulo Systems or others.

Emergency access. If a Practice has named an emergency contact and the Practitioner has died or is incapacitated, we may give that person access to the Practice's account, including its Client records, but only after verifying their identity and the circumstances under the procedure the Practice agreed to in Settings. We use the emergency contact's details only to verify and communicate with them for this purpose, and we record the change in the Practice's audit log. A Practice can change or remove its emergency contact at any time.

5. Cross-border data storage

Some of the service providers listed in Section 4 store or process information outside Canada. Specifically:

  • Supabase (database and authentication): hosted in Canada.
  • Vercel (hosting): primarily the United States.
  • Stripe (payments): the United States, with international sub-processors as needed to provide the service.
  • Resend (transactional email): the United States.
  • Daily.co (video calls): global infrastructure operated on Amazon Web Services, not limited to a single country.

This means personal information submitted to Willow — including personal health information a Practice stores about its Clients — may be accessed, processed, or stored outside Canada, where it is subject to the laws of that jurisdiction, including potential access by that jurisdiction's courts, law enforcement, or national security authorities under rules that may differ from Canadian law. We select service providers that maintain industry-standard safeguards for cross-border transfers, such as Standard Contractual Clauses or participation in the EU-U.S. Data Privacy Framework, where applicable.

6. Data security

We use industry-standard measures to protect information, including encryption in transit, access controls, and database-level isolation between Practices. No system is perfectly secure, and we can't guarantee absolute security.

7. Data breach notification

If we become aware of a security incident affecting a Practice's data, we'll notify the affected Practice without undue delay, including what we know about the incident and what we're doing about it, so the Practice can meet its own notification obligations as the health information custodian — including, where applicable, notifying its Clients and the Information and Privacy Commissioner of Ontario.

8. Data retention

We retain Practice and Client data for as long as the Practice's account is active, plus a reasonable period afterward, unless a Practice requests earlier deletion or longer retention is required by law or professional record-keeping obligations.

9. Your choices

Practice staff can access and update their account information directly in Willow. Clients with portal access can do the same for their own portal account, including turning appointment-reminder emails on or off from their portal's Notifications tab (independently of their Practice's practice-wide setting). To request access to, correction of, or deletion of personal information, contact your Practice directly (as the data controller for your health information) or reach us at the email below.

10. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we'll provide reasonable notice (for example, by email or an in-app notice) before they take effect.

11. Contact

Questions about this policy? Reach us at sulosystems@gmail.com.

See also our Terms of Service.