1. Data Controller & Responsible Officer

Name: Éric Duchaîne, N.D. (Certified Naturopath since 1989)
Role: Privacy Officer (Law 25 Compliance)
Direct Contact: info@new-growth.com

2. Medical Disclaimer (Clinical Practice)

The services, consultations, and evaluation tools (including the Mirror of Health) are part of a holistic naturopathic approach to natural health and metabolic support.

Legal Scope: Éric Duchaîne is a Naturopath (N.D.) and not an allopathic medical doctor. Therefore:

• The Mirror of Health is an energetic and metabolic analysis tool (TCM-based) and does not constitute a medical diagnosis under the Medical Act.
• Our recommendations (Vibratory Detox, botanical protocols) aim for health optimization and do not replace prescribed medical treatments.
• Clients are responsible for consulting a physician for any pathological condition and must report any potential medication interactions.

3. Privacy Policy (Law 25 Compliance)

Consent at New Growth is manifest, free, and informed. We apply the highest protection standards for your sensitive health data.

Data Collection & Purpose

We only collect information essential for your therapeutic follow-up:

• Identity: Name, email, and date of birth for metabolic profiling.
• Health Data: Personal history shared during glandular assessments and the "5 Animal Profiles."
• Biometric Data: Photographs of the tongue, the breasts and face (via the Mirror of Health) used exclusively for holistic diagnostic analysis by your therapist.

Security & AI Technology Policy

Your data is stored in a Secure Professional Google Workspace environment.
AI Commitment: While we use algorithmic assistance to analyze clinical signs (glossoscopy), none of your personal data or photos are used to train public AI models. Your privacy remains confined to our private clinical space.

Your Rights

Under Law 25, you have the right to access, rectify, request data portability, and the right to be forgotten. For any request, please contact Éric Duchaîne at the email provided in Section 1.

4. Intellectual Property

All content (Archetype algorithms, Mirror of Health methodology, Vibratory Detox texts) is the exclusive property of Éric Duchaîne. Built upon 35 years of clinical experience, this expertise is legally protected. Any reproduction is strictly prohibited.

5. Sales & Refund Policy

Natural Health Products: For health safety reasons and compliance with Health Canada NPN standards, products with broken seals cannot be returned or exchanged.

Digital Services: The Mirror of Health analysis and access to digital programs are activated upon purchase. They are non-refundable once the analysis is completed or the content has been accessed.