Our privacy commitment is based on the ten principles contained in the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”).
Personal Health Information
As a regulated health care practitioner, we also collect “personal health information” which is governed by provincial health privacy legislation Freedom of Information and Protection of Privacy Act (FIPPA) and the Personal Information Protection Act (PIPA). This personal health information is subject to additional safeguards and procedures set out in our Health Information Privacy and Security Policies and Procedures Manual.
If you will be receiving Virtual Care from us, we will ask you to review and sign an additional Consent to Virtual Care document that discloses the risks and conditions for the collection and use of your personal health information to provide Virtual Health Care Services.
Personal Information under PIPEDA is any information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.
Why do we collect Personal Information?
We collect Personal Information in order to provide educational and coaching services to you. In addition, we distribute publications and offer educational opportunities concerning mental health, neurodiversity, healthcare, which we provide as a service to you and others in our community.
The Company collects your information in order to record and support your participation in the activities you select. If you register to download a PDF or resources, sign up for our newsletter, and/or purchase a product from us, we collect your information. We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services.
How do we collect personal information?
We collect personal information only by lawful and fair means, and only collect personal information that is reasonably necessary for the legitimate purposes identified and for which consent has been obtained.
Information You Provide To Us. The Website provides various places for users to provide information. We collect information that users provide by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website.
We use information you provide to us to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.
Information We Collect Through Automatic Tracking Technology
As you navigate through our Website, we may use automatic data collection technologies including Google Analytics to collect certain information about your equipment, browsing actions, and patterns. This will generally include information about your location, your traffic pattern through our Website, and any communications between your computer and our Website. Among other things, we will collect data about the type of computer you use, your Internet connection, your IP address, your operating system, and your browser type.
The information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
Similar to other commercial websites, our Website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and websites visited just before and just after our own, as well as your IP address.
The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as required by law.
All e-mails sent by us will be in compliance with the Canadian Anti-Spam Legislation (“CASL”), including clearly stating who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us. Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
Collection from Third Parties
Sometimes we may obtain information about you from other sources including:
- Government agencies or departments;
- Other health professionals, clinics or practitioners;
- Other third parties who represent that they have the right to disclose the information.
How do we use your information?
We use personal information for purposes of presenting our Website and its contents to you, providing you with information, providing you with offers for products and services, providing you with information about your subscriptions and products, carrying out any contract between you and the Company, administering our business activities, providing customer service, and making available other items and services to our customers and prospective customers.
From time-to-time, we may use the information you provide to us to make you offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information.
From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities.
Disclosure of Information
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action.
We may disclose your personal information to our subsidiaries, affiliates, and service providers for the purpose of providing our services to you.
We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and the Company.
We may provide your information to any successor or assign in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets and/or business.
We may disclose information when legally compelled to do so when we, in good faith, believe that the law requires it, or for the protection of our legal rights, or when compelled by a court or other governmental entity to do so.
We use appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. Such measures will vary depending on the sensitivity, amount, format, nature and storage of the personal information and will involve, as applicable, physical, organizational and electronic security measures, including premises security, restricted file access, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies. In communicating with us, you should be aware that e-mail is not a fully secure medium.
Updating Information and Correcting Errors
Since we use your personal information to provide goods or services to you, it is important that the information be accurate and up-to-date. If any of your information changes, is inaccurate or incomplete, please inform us so that we can make any necessary changes.
Access to Personal Information
We will respond promptly to any request for access to your personal information and will advise you of the cost, if any, prior to the retrieval of such records or information. We will not respond to requests for access to personal information that are frivolous, vexatious or repetitious. In certain circumstances, we may be unable to provide access to some or all of the personal information that we hold about you.
Visitor GDPR Rights
If you are visiting this Website from within the European Union (“EU”) or the UK, you are entitled to certain information and have certain rights under the General Data Protection Regulation of the EU (and corresponding legislation of the UK) which include the following:
- We will retain any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) We decide that the value in retaining the data is outweighed by the costs of retaining it.
- You have the right to request access to your data that we store and the rights to either rectify or erase your personal data.
- You have the right to seek restrictions on the processing of your data.
- You have the right to object to the processing of your data and the right to the portability of your data.
- To the extent that you provided consent to the our processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
For more information about your rights as a website visitor from the EU and the GDPR, please see the European Commission website here - https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en.
Questions, concerns or requests for access
Adrianne Kmet | [email protected]
June 14, 2023