New Light Ibogaine Inc. (“New Light Ibogaine”, “we”, “us”, “our”) and its affiliated entities deliver premier psychedelic therapies utilizing ibogaine and 5-MeO-DMT.
This Privacy Notice outlines our protocols regarding the gathering, retention, utilization, and sharing of personal data pertaining to identifiable individuals who:
- browse or navigate our website (“Site Visitors”) available at https://newlightibogaine.com/ (the “Site”);
- enroll in our mailing list (“Subscribers”);
- communicate with us via email, text messaging, or other digital communications through the Site or regarding our clinical offerings (“Prospective Patients”); or
- access our secure patient portal (“Medical Patients”) hosted at https://newlightibogaine.com/ (the “Portal”).
Please review this document thoroughly to ensure you comprehend and accept our practices.
You are under no legal obligation to submit personal data to us, and doing so (or refraining from doing so) is completely voluntary. Should you prefer not to share your data or have it processed by us or our third-party service providers (detailed below), simply refrain from accessing our Site or utilizing our Portal. Additionally, you may unsubscribe from our mailing lists at any time by utilizing the opt-out link in the footer of our emails.
If you have questions, inquiries, or complaints regarding how we handle your personal data, please reach out to us at:
- GDPR Matters: info@newlightibogaine.com
- Non-GDPR Jurisdictions: info@info@newlightibogaine.com
1. Our Role in Data Processing
In this Notice, “personal information” refers to any data that identifies, relates to, describes, or can reasonably be linked—directly or indirectly—to a specific individual. It excludes aggregated or anonymized data that cannot reasonably be associated with a specific person.
Global privacy legislation—such as the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”)—distinguishes between two main entities in data handling:
- A Data Controller (designated as a “Business” under CCPA/CPRA) determines why and how personal information is processed.
- A Data Processor (designated as a “Service Provider” under CCPA/CPRA) processes personal information strictly on behalf of, and following instructions from, the controller or business.
New Light Ibogaine Inc., registered at 700-275 Lansdowne St., Kamloops, BC, V2C 6H6, Canada, acts as the “Data Controller” for personal data pertaining to our Site Visitors, Subscribers, Prospective Patients, and Medical Patients (as described in Section 2).
2. Personal Information Collected and Purposes of Processing
The categories of data we collect, our purposes for handling it, and the corresponding legal grounds under the GDPR are detailed below.
1. Site Visitors
Categories of Personal Information Collected:
- Internet and electronic network activity details, including:
- Usage metrics
- IP address
- Device type and browser configuration
- Operating system
- Pages viewed and duration
- Referral URLs
- Visit length
- Approximate regional location
Purposes of Processing:
- To operate, maintain, and optimize our digital platform
- To evaluate user interaction and engagement trends
- To maintain security standards and prevent fraudulent activity or abuse
- To troubleshoot technical issues
Legal Grounds:
- Legitimate interests (maintaining website operation, analytics, and cybersecurity)
- Consent (where required for tracking technologies and cookies)
2. Subscribers
Categories of Personal Information Collected:
- Identifiers and contact details, such as:
- Full name
- Email address
Purposes of Processing:
- To distribute newsletters, insights, and updates
- To manage email distribution lists
- To convey pertinent details regarding our care options
Legal Grounds:
- Consent (which may be revoked at any point)
3. Prospective Patients and Medical Patients
Categories of Personal Information Collected:
- Contact and identity information (e.g., name, email address, phone number)
- Demographic and biographical details (e.g., sex, age, date of birth, race/ethnicity, religion, marital status, educational background)
- Financial details (e.g., payment details and billing records)
- Health and medical background
Sensitive Personal Information: Under the CCPA/CPRA, we collect specific details classified as Sensitive Personal Information, including:
- Health records and medical details
- Racial or ethnic background
- Religious affiliations
- Financial credentials with required access details
Certain elements of this data may also qualify as special category data under the GDPR.
Purposes of Processing:
- To evaluate treatment suitability and correspond with prospective clients
- To deliver medical care, therapeutic services, and clinical treatment
- To manage records and fulfill legal, clinical, and regulatory mandates
- To handle billing processes and account administration
- To protect the vital interests of patients when necessary
Legal Grounds:
- Performance of a contract
- Compliance with legal obligations
- Legitimate interests (operational management and clinical administration)
- Explicit consent, where mandatory
Where we handle medical or special category data, we do so in accordance with relevant laws, including where processing is required for medical diagnosis, healthcare provision, compliance with legal obligations, or establishing/defending legal claims, and with explicit consent where necessary.
Handling Sensitive Personal Information: We handle and disclose Sensitive Personal Information strictly to provide services, meet regulatory demands, and fulfill other legal purposes.
3. Sharing of Personal Information
We share personal details with third parties exclusively when necessary to deliver our services, fulfill legal obligations, or safeguard our rights. We do not sell personal information, nor do we share it for cross-context behavioral advertising.
- Service Providers and Contractors: We share details with trusted third-party providers performing functions on our behalf—such as web hosting, data storage, technical analytics, payment processing, and communications management. These providers are bound by contract to process data solely to perform these tasks and in compliance with privacy laws.
- Clinical and Professional Partners: Where relevant, data may be shared with professional advisors and, for clinical care, with healthcare professionals, laboratories, or partner facilities involved in your treatment plan. Such exchanges are strictly confined to what is necessary for care delivery.
- Regulatory and Legal Bodies: We may disclose personal data to courts, government bodies, law enforcement, or legal representatives when required or authorized by law, such as to satisfy legal mandates or defend legal claims.
- Corporate Transactions: Personal details may be transferred during a corporate merger, acquisition, restructuring, or asset sale, provided the acquiring party agrees to respect the terms of this Notice.
- Safety and Protection: Data may be shared if we believe it is necessary to protect the rights, safety, or property of our organisation, our patients, or the public, including fraud prevention.
- International Data Transfers: Personal data is maintained on secured servers in Canada and may be processed in Canada or other locations where our service partners operate.
When cross-border transfers occur, we implement measures to ensure compliance with applicable data protection laws so that your information remains safeguarded. For transfers originating from the EU or EEA, appropriate mechanisms (such as European Commission Adequacy Decisions or Standard Contractual Clauses) are utilized. Details regarding these safeguards are available upon request.
4. Cookies and Tracking Technologies
We utilize cookies and tracking tools for site performance, analytics, and user experience customization. We may share aggregated, non-identifiable summaries with providers for operational purposes.
Cookies are small data files sent to your browser and returned upon subsequent visits. We use both temporary “Session Cookies” (deleted upon closing your browser) and “Persistent Cookies” (stored for longer periods).
Our Site restricts cookie deployment until you provide your explicit consent.
5. Google Analytics
When interacting with our Website, we may log interaction data—such as IP address (processed by Google), device configuration, browser type, operating system, pages viewed, duration, referral source, and general location.
We leverage Google Analytics to evaluate site navigation patterns and generate user reports. Google Analytics uses persistent cookies to collect standard web log metrics and user behavior. This information is transmitted to Google LLC.
Google’s use of this data is governed by the Google Analytics Terms of Use and Google’s Privacy Policy. Data gathered via Google Analytics may be stored and processed outside your local jurisdiction.
6. Data Accuracy
New Light Ibogaine takes reasonable measures to ensure personal data under our control is accurate, complete, and current. Should we identify inaccurate details, we will correct or update them promptly.
You may request updates to your information at any time by reaching out:
- GDPR Inquiries: info@newlightibogaine.com
- Non-GDPR Inquiries: info@newlightibogaine.com
7. Consent Management
Where processing relies on consent, New Light Ibogaine will obtain your approval prior to collecting or using your data, as mandated by applicable law.
Under the GDPR, our legal grounds for processing relying on consent are Article 6(1)(a) and Article 9(2)(a) for Special Category data. For healthcare operations, processing may also be based on Article 9(2)(h) (necessary for healthcare provision under professional secrecy standards).
You can revoke your consent at any time by contacting:
- GDPR Inquiries: info@newlightibogaine.com
- Non-GDPR Inquiries: info@newlightibogaine.com
Revoking consent does not affect the lawfulness of processing carried out prior to the revocation.
8. Data Retention and Destruction
New Light Ibogaine retains personal information only as long as necessary to fulfill the operational purpose for which it was gathered, or to comply with legal, regulatory, or contractual mandates.
Once processing purposes are fulfilled and retention periods expire, data is securely destroyed or anonymized. In limited instances, data may be retained longer strictly for public interest archiving, scientific research, or statistical analysis under appropriate safeguards.
9. Security Measures and Safeguards
New Light Ibogaine employs administrative, physical, and technical safeguards tailored to the sensitivity of the data to protect against unauthorized access, loss, misuse, disclosure, or alteration.
Safeguards include:
- Physical Measures: Secured filing cabinets, restricted access rooms, and physical security.
- Organizational Measures: Need-to-know access controls, workforce privacy training, confidentiality agreements, and operational policies.
- Technical Measures: Strong password protocols, active network monitoring, encryption standards, and security audits.
10. Your Privacy Rights
Right to Object: Where New Light Ibogaine processes data based on legitimate interests rather than consent, you hold the right to object based on your specific situation. We will halt processing unless compelling legitimate grounds override your rights or processing is required for legal claims.
Depending on your jurisdiction, you may hold the following rights:
European Union / EEA Residents (under GDPR):
- Withdraw Consent: Revoke consent for processing activities at any time.
- Restrict Processing: Limit how we process your information in specific circumstances.
- Access and Verification: Request confirmation of data held and verify its accuracy or request corrections.
- Erasure (“Right to Be Forgotten”): Request deletion of your personal data, subject to legal limits.
- Data Portability: Receive a structured, machine-readable copy of your data or request direct transfer to another entity.
- Lodge a Complaint: Submit a complaint to your local Data Protection Authority. (We encourage contacting our Chief Privacy Officer first to address concerns directly).
California Residents (under CCPA/CPRA):
- Right to Know: Request disclosures regarding categories and specific pieces of data collected, used, or shared.
- Right to Delete: Request removal of personal information, subject to statutory exemptions.
- Right to Limit Sensitive Data: Restrict the use of Sensitive Personal Information to essential service delivery.
- Right to Opt-Out: Request that your data not be sold or shared (note: New Light Ibogaine does not sell or share data for behavioral advertising).
- Non-Discrimination: Exercise your privacy rights free from discriminatory treatment.
11. Exercising Your Privacy Rights
To submit a request, please contact us using the details provided below. Requests must include sufficient information to allow us to verify your identity (or authorized representative status) and understand your request clearly.
New Light Ibogaine will respond within 30 days of receipt. If an extension is required due to request complexity, we may extend the timeline by an additional 30 days, notifying you within the initial period.
12. Contact Information
To exercise your privacy rights or inquire about our data handling protocols, contact our Data Protection Officer at:
- GDPR Requests: info@newlightibogaine.com
- Non-GDPR Requests: info@newlightibogaine.com
13. Updates to this Notice
We may update this Privacy Notice periodically to reflect operational, legal, or regulatory changes. Significant updates will be communicated through site notices or direct electronic communications prior to taking effect. We recommend reviewing this page periodically.
