Privacy Policy
Effective Date: 2026
Sara White | TransToronto.net
This Privacy Policy outlines the collection, use, retention, protection, and disclosure of personal and sensitive information provided to me (“I,” “me,” “my”) by clients, visitors, or individuals interacting with my professional companionship services (“you,” “client,” “suitor”). By accessing my website, submitting information, booking appointments, or communicating through official channels, you acknowledge and consent to the practices described herein.
This policy applies to all online and offline interactions, including website activity, email correspondence, bookings, verification and screening processes, and in-person engagements. It is designed to reflect my commitment to discretion, confidentiality, and professional integrity.
This Privacy Policy does not guarantee client rights under Canadian privacy law, and certain protections may be forfeited if a client violates boundaries or is deemed a security threat. In such cases, any included provider-client discretion agreement is null and void, and information may be disclosed to authorities or used for legal action as necessary.
1. Information Collected
I collect only the information necessary to provide safe, professional, and high-quality companionship services. This includes:
a) Personal Information
• Legal name or verified alias
• Date of birth and age verification
• Email address and phone number
• General identifying details voluntarily shared
b) Verification & Screening Information
• Government-issued identification (passport, driver’s license, photo ID)
• References or background information provided voluntarily
• Screening forms and completed pre-screening questionnaires
**c) Technical Data
• Technical data collection (IP addresses, browser type, operating system, website analytics, cookies) is not collected by me personally. Any data collected automatically by the website host is outside my control and considered a third-party matter.**
d) Communication Content
• Emails, messages, and booking inquiries
• Any information shared during official communications or booking procedures.
2. How Information Is Collected
Information is collected through:
• Direct submission via booking forms (Regular or First-Time)
• Email correspondence to secure, encrypted addresses
• Verification and screening protocol for first-time clients
• Analytics tools for operational purposes
• Third-party services only as necessary for operations (e.g., payment processors, hosting platforms)
I do not solicit unnecessary or unrelated information beyond what is essential for service provision or safety.
3. Purpose of Information Use
Collected information is used exclusively for professional service operations:
• Identity verification and screening for first-time clients
• Booking confirmations, scheduling, and service management
• Risk assessment and safety protocols
• Client communication regarding appointments, deposits, and inquiries
• Documentation of transactions, deposits, or cancellations
Information is never used for advertising, unsolicited marketing, or third-party distribution without explicit consent.
4. Legal Basis for Processing
Under PIPEDA (informational reference only):
• Collection and processing are based on explicit client consent.
• Implied consent is established through inquiries, submissions, and bookings.
• Legal obligations may require disclosure in limited circumstances (e.g., law enforcement, court orders, or risk mitigation for serious incidents).
5. Consent
• Providing information, submitting forms, or completing bookings constitutes consent.
• Clients may withdraw consent, with the understanding that service provision may be affected or halted if necessary information cannot be retained.
• Continued interaction with services or website constitutes ongoing consent to this Privacy Policy.
6. Data Storage & Security
All personal, verification, and screening information is stored securely:
• Encrypted email systems and password-protected databases
• Limited access only to authorized personnel (myself)
• Backup protocols and safeguards to prevent unauthorized access, loss, or data breaches
• Physical documents, when necessary, are stored securely and destroyed once operationally unnecessary
While all reasonable measures are taken, absolute security cannot be guaranteed, consistent with industry standards.
7. Data Retention
• Verification and screening records are retained for first-time and repeat client management.
• Booking history, deposit confirmations, and transactional records are retained for operational purposes.
• Inactive or unnecessary data is periodically anonymized or securely deleted.
• Clients may request deletion of their data, subject to operational and safety constraints.
8. Data Sharing & Disclosure
• Personal information is never sold, rented, or shared for commercial purposes.
• Disclosure occurs only under exceptional circumstances:
• Compliance with lawful requests (court orders, subpoenas, legal investigations)
• Protection of personal safety for clients or myself (threats, harassment, non-consensual conduct)
• Third-party service providers (e.g., payment processors, hosting) who are bound by confidentiality agreements
No casual disclosure of information occurs under any circumstances.
9. Discretion & Confidentiality
Discretion is foundational:
• All client interactions, communications, and engagements are strictly private.
• No identifying information, meeting details, or communications will be shared.
• Discretion extends beyond the engagement duration, applying indefinitely.
• Violation of confidentiality or security protocols by a client can result in immediate termination and legal action. In such cases, the provider-client discretion agreement is null and void.
10. Client Responsibilities
Clients must maintain privacy and respect security protocols:
• No recording (audio, video, or photography) of any appointment
• No sharing of identifying information, communications, or engagement details
• Adherence to agreed-upon conduct, boundaries, and hygiene expectations
Compliance ensures mutual trust, safety, and professionalism.
11. Cookies & Website Tracking
• Minimal cookies for functionality and security are handled by website host; I do not collect cookies personally.
• No behavioral tracking or profiling is performed for marketing purposes.
• Users may manage cookies through browser settings, noting that some website functionality may be affected.
12. Third-Party Services
• Some operational tools and services may involve third parties, such as payment platforms, email systems, and website hosting.
• Third parties are expected to comply with their own privacy and security policies
• No third party has access to client data outside operational necessity
13. Data Breach Response
• In the event of a breach, clients will be notified promptly through official channels.
• Immediate steps will be taken to contain, assess, and mitigate the breach.
• Clients are encouraged to report any suspected security concerns immediately.
14. Rights of Individuals
Clients do not have statutory privacy rights in this context due to the nature of the business.
Clients retain only the right to request deletion of personal information or corrections to basic identifying information (e.g., name changes). Data access rights are not provided.
Requests should be submitted via official email or contact channels and will be addressed in a reasonable timeframe.
15. Limitation of Liability
• No system is infallible; while safeguards are in place, I cannot guarantee absolute security.
• I am not liable for breaches or unauthorized access outside reasonable control.
16. Changes to Privacy Policy
• This Privacy Policy may be updated without prior notice.
• Updated versions take effect immediately upon posting on the website.
• Continued use of services constitutes agreement to the updated terms.
17. Contact Information
For all privacy inquiries, deletion requests, or corrections to basic information only, please contact:
Email: info@transtoronto.net
Website: transtoronto.net
All requests will be handled promptly, professionally, and confidentially.