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Privacy Policies

Platform Privacy Policy 

This Privacy Policy was last updated on January 6, 2021.

General Information

We respect the privacy of everyone who accesses the MindBeacon Platform. We recognize the need for appropriate protections and management of Personal Information (as defined below in this Policy). This Privacy Policy explains what information we collect, how we use that information, and how it is disclosed.

The website https://platform.mindbeacon.io is owned by MindBeacon Software Inc., and the MindBeacon application is licensed to and operated by MindBeacon Health Inc. (MindBeacon Health Inc. and MindBeacon Software Inc. collectively referred to as “MindBeacon”).

You must be at least sixteen (16) years old to use the MindBeacon Platform or any MindBeacon service. By using the MindBeacon Platform, you represent and warrant to MindBeacon that you are at least sixteen (16) years old. Parental consent may be required in some provinces if you are under the age of eighteen (18).

Application

This Privacy Policy applies to the Personal Information that is collected, used, and disclosed by MindBeacon when you register and use the MindBeacon Platform at https://platform.mindbeacon.io and any and all sub-domains of such website, as well as the kinds of information we collect when you use our services through the MindBeacon Platform or when contacting us. By providing us with your Personal Information, you agree to be bound by the terms and conditions of this Privacy Policy.

The privacy practices related to the MindBeacon website https://mindbeacon.com and any and all sub-domains of such website (the “Site”) are set out in a specific notice available on the Site.  Please see the Site Privacy Policy

What is “Personal Information”?

For purposes of this Policy, the term “Personal Information” means information about an identifiable individual that is provided through the MindBeacon Platform such as contact information, name, address, phone number or email address, gender, date of birth, and personal health information, including information relating to physical or mental health, health history, medical records, prescriptions, payment for health care provided, and health card number.

Any data that has been collected in which personal identifiers have been removed, such that the information could not reasonably be used to identify the individual, is not considered Personal Information.

Consent

By using the MindBeacon Platform and application, you agree to the terms of this Privacy Policy and acknowledge that we may collect, use and disclose your Personal Information in accordance with the terms hereof. By creating an account to save information, and/or by submitting information for screening purposes and/or an assessment, you consent to the Terms of Use and Privacy Policy as applicable to each and all of those actions.

MindBeacon will collect, use and disclose your Personal Information without your consent only in limited circumstances and as permitted or required by law or regulatory requirement. For example, Personal Information may be used or disclosed without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual. In certain limited circumstances, we may be called upon to release your Personal Information in response to a court order, subpoena, search warrant, law or regulation. We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive, and that disclosure is necessary to comply with applicable law.

Except in limited circumstances as permitted by applicable law, we will obtain your consent before collecting, using or disclosing your Personal Information for new purposes unrelated to the purposes described in this Privacy Policy.

In certain cases, you may choose not to provide us with some or all of your Personal Information. However, should you choose not to provide necessary Personal Information to us, that decision may impact your ability to interact with us or for us to provide you with certain services. For example, we require that you provide us with current emergency contact information, and we cannot provide any services without emergency contact information.

You may withdraw your consent at any time by notice to us in writing. Please contact our Privacy Officer listed below to find out how.

What Personal Information does MindBeacon Collect?

We may collect Personal Information about you for the purpose of administration and providing services through the MindBeacon Platform, including, without limitation, information such as:

  1. Your name;
  2. Your contact information, emergency contact information, date of birth;
  3. Demographic information (gender, ethnicity, place of birth, education, health, family and lifestyle information, etc.);
  4. The services you will and have received through the MindBeacon Platform, dates, etc.;
  5. Responses to your screening and/or online assessment;
  6. Your assessment report;
  7. Secure messaging or email communications between you and a regulated healthcare professional involved in your care;
  8. Any information that you send to us through email or the MindBeacon Platform;
  9. Notes and records of assessment and information relating to your assessment for suitability for services through the MindBeacon Platform, and notes and records relating to your progress through the MindBeacon Therapist Guided Program and/or MindBeacon’s Live Therapy;
  10. Outcome data from self-report measures; and
  11. Your responses to requests for information and/or treatment questions at follow-up intervals three (3) and six (6) months after you have completed the course.
How is this Personal Information Used?

We will use your Personal Information for the purposes for which it was collected as outlined above, and as required or permitted by applicable law.  Specifically, we will use your Personal Information to:

  1. Deliver and administer services to you through the MindBeacon Platform, including assessments, the Therapist Guided Program, and Live Therapy;
  2. Communicate with you, including setting up an assessment phone call, enabling communications with your therapist, to provide you with information about possible services and treatments, and to provide other reminders, prompts and feedback about your progress through the Therapist Guided Program and/or Live Therapy; and/or
  3. Provide you with ongoing service and support and to help us better understand your needs.

Your Personal Information may be de-identified and/or aggregated, and thereafter used for the purposes of improving and developing new assessment processes or other related product or service offerings, research, including academic and non-academic research, AI and other types of analytics, quality assurance, performance reporting, customer reports,  promotion and advertisement, and business development.

What Personal Information does MindBeacon Share?

We may share your Personal Information with third parties as follows:

MindBeacon Therapists: Your Personal Information may be shared with another MindBeacon therapist and/or any one or more clinical supervisors or clinical consultant of any MindBeacon therapist, if sharing such information is necessary to provide you with services through the MindBeacon  Platform.

Consulting Professionals: Your Personal Information may be shared by your MindBeacon therapist with a MindBeacon consulting regulated healthcare professional for the purpose of quality assurance and otherwise in accordance with applicable laws.

Insurance Providers: In circumstances where you are completing therapy as part of a return to work plan established by an insurance company, we may share your Personal Information with those involved in your care, including the insurance company. This disclosure may include information regarding your assessment results, progress and discharge from the MindBeacon Therapist Guided Program or Live Therapy.

Payors: If your use of services through the MindBeacon Platform is paid for by your employer or a third-party insurance provider, we may disclose certain information in order to assist us with arranging payment for your enrollment. This information includes your name and insurance plan information. We will not disclose to your employer or a third-party insurance provider, any correspondence between you and your MindBeacon therapist, any of your assessment information, progress or discharge reports, or any summaries of such information.

Hospitals: In circumstances in which you have been referred to us through a hospital or other health care provider that remains involved in your care on an ongoing basis, or if you are referred to such provider after concluding the MindBeacon Therapist Guided Program or Live Therapy, we may share your Personal Information with such provider. This disclosure may include information regarding your assessment results, progress and discharge from the MindBeacon Therapist Guided Program or Live Therapy.

Employees and Agents: We may provide your Personal Information to our employees and those of our affiliates and our respective agents and those third parties that require such information in order to help us provide services to our clients and administer our business.

Service Providers: We have relationships with agents and third-party service providers that help us provide services to you including, but not limited to, administering our business, and designing, maintaining and improving the MindBeacon Platform and our systems and computer security.

We also use third parties to analyze aggregate data collected on the MindBeacon Platform for research purposes in accordance with applicable law. To the extent we allow a third-party service provider to access to your Personal Information for the purposes outlined herein, they will only be permitted to collect it or use it for purposes consistent with this Privacy Policy and applicable law.

We use payment processing service providers that are hosted and operated in the United States, and laws in the United States and other jurisdictions may differ from the laws where you reside.

For information about the manner in which our service providers treat Personal Information, please contact us as set out in the “Questions about this Privacy Policy” section of the Privacy Policy.

Legal Disclosure: We and our service providers may disclose your Personal Information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.

The Personal Information you provide to us through the MindBeacon Platform will not be otherwise disclosed to a third party without your consent, except as required or permitted by applicable law. 

Confidentiality

The MindBeacon Platform is strictly confidential. That means that the information you share with us is known only to you, a regulated healthcare professional involved in your care and his/her supervisor. Neither MindBeacon nor any member of a regulated health profession working with MindBeacon will release any information about you to anyone without your written permission, except as set forth in this Privacy Policy or as required or permitted by applicable law or regulatory requirement.

Please note that we have the following legal obligations to release confidential information:

  1. Harm to self: If a regulated healthcare professional involved in your care has reason to believe that you are in danger of physically harming yourself in ways that may be life-threatening, s/he will have to make a referral to a hospital and/or contact a family member, close other, or another person such as a police officer who may be able to help protect you. There may be other emergency health care related circumstances where disclosure is reasonably necessary for the protection of your health, in which case your regulated healthcare professional will disclose Personal Information to other healthcare professionals as long as you have not expressly prohibited him/her from doing so.
  2. Harm to others: If a regulated healthcare professional involved in your care has reason to believe that you are seriously threatening physical violence against another person, or if you have a history of physically violent behaviour, and if s/he believes that you are an actual threat to the safety of another person, s/he is required to take some action (such as contacting the police, notifying the other person, seeking hospitalization, or some combination of these actions) to ensure that the other person is protected.
  3.  Abuse/Neglect: 
    1. If a regulated healthcare professional involved in your care has reason to believe that a child under the age of sixteen (16) is being abused or neglected, s/he is legally obligated to report this situation to the appropriate child protection authority (e.g., the Children’s Aid Society).
    2. If a regulated healthcare professional involved in your care suspects or is informed of unlawful conduct that resulted in harm or risk of harm to a resident of a Long Term Care Facility or Retirement Home, or that a resident is being harmed or is at risk of being harmed in any way (e.g., sexual or physical abuse, neglect, misappropriation of resident’s funds), s/he may be required to contact the applicable Ministry or Regulatory Authority and report all relevant information.

    4. Sexual Abuse: If you have been sexually abused by a member of a regulated health profession, this information must be reported to the appropriate regulatory body if you share the information with a regulated healthcare professional involved in your care.
  1.  
  2. 5. Court Order: A regulated healthcare professional involved in your care and your clinical record can be subpoenaed by a court order. Your regulated healthcare professional can be required to testify and give information obtained during sessions. Without a court order, this information would never be provided voluntarily without your direct request or consent.
  3.  
  4. 6. Quality Control:
    1. On occasion, a regulated healthcare professional involved in your care may be randomly selected to participate in a Peer Assisted Review by his/her regulatory college (for example, the College of Psychologists of Ontario). As part of this process, your file may be potentially reviewed by a member of the regulatory college. Regulatory colleges have confidentiality policies in place to protect your information.
    2. A regulated healthcare professional involved in your care may be supervised in his/her clinical work by a more senior professional. You will be informed of any such supervisory arrangement. That supervisor may access your clinical file for the purposes of quality control.

Exceptions to confidentiality are rare. If disclosure of Personal Information is required, your regulated healthcare professional will release only the information required to be released to comply with our obligations in accordance with this Privacy Policy and applicable law.

Other Information/Logging

We may collect and use information about how you interact with the MindBeacon Platform, including Internet Protocol addresses, Internet domain names and operating system used to access the MindBeacon Platform, the time spent on each page and the time and date of each visit. This information is used for, among other things, auditing and tracking purposes, to improve the content of the MindBeacon Platform, and to create a better experience for users of the MindBeacon Platform.

Sale of Business

We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of MindBeacon or as part of a corporate reorganization or other change in corporate control.

Links and Referrals to Third Parties

We may provide links to third party websites or refer you to external resources for your convenience and information. If you access those links or contact those external resources, you will leave the MindBeacon Platform and you will be dealing with an external third party, not with MindBeacon. MindBeacon does not control those sites, external resources or their privacy practices, which may differ from this Privacy Policy. Please review the privacy policies of each web site that you visit and of each external organization that we may refer you to. MindBeacon is not responsible for any information provided or advice given by any such external resource or third party website, even if MindBeacon provided a link to such website or referred you to such external resource.

Our Security Measures

We are committed to protecting the security of your Personal Information. We have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your Personal Information. We apply security safeguards appropriate to the sensitivity of the Personal Information, such as retaining information in secure facilities and making Personal Information accessible only to authorized employees on a need-to-know basis. We have clearly defined internal policies and practices.

Although we will make commercially reasonable efforts to protect Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. This risk is heightened if you are using unsecured/public Wi-Fi.

Retention

We retain your Personal Information only for as long as is necessary for the purpose for which it was collected in accordance with the laws, ethics and standards applicable to members of the College of Psychologists of Ontario or such other applicable regulatory body in jurisdictions in which we operate. When your Personal Information is no longer required or required to be maintained, it will be destroyed or de-identified in accordance with applicable laws.

If you create an account for the MindBeacon Therapist Guided Program but do not submit your answers to the screening or the online assessment questionnaire within seven (7) days from the date upon which you create your account, then we will automatically delete your answers. The information you provide to create a MindBeacon account will be deleted if you do not use the MindBeacon Platform within thirty (30) days of creating an account.

Your record will be maintained, as required, in accordance with the laws and standards set out by the College of Psychologists of Ontario or any other applicable regulatory body governing the provision of services as a clinician.

Your Personal Information (including personal health information) will be maintained and stored in Canada, except as otherwise set out in this Privacy Policy.

Verification

We will engage in periodic assessments to verify that our privacy practices continue to comply with this Privacy Policy.

Access

Except in the limited circumstances established by law, individuals may obtain access to their Personal Information.  Individuals may also request us to correct their Personal Information where they believe it to be out of date or otherwise inaccurate.  Requests for access or correction must be made in writing and should be addressed to our Privacy Officer (please see the contact details set forth below). We may decide to share your Personal Information with you through a healthcare provider, where appropriate.

We will assist you if you inform us that you need assistance in preparing a request concerning Personal Information. Administrative charges may apply.

Updates to this Privacy Policy

In order to ensure that this Privacy Policy is kept up to date, we may change this Privacy Policy from time to time. Notice of changes to the Privacy Policy will be posted on the Site and will be effective thirty (30) days following notice of the changes on the MindBeacon Platform. If you access or choose to continue to use the MindBeacon Platform after the effective date of the change, you are deemed to have automatically accepted the change.  

Questions about this Privacy Policy

BY SUBMITTING PERSONAL INFORMATION AND PERSONAL HEALTH INFORMATION THROUGH THE MINDBEACON PLATFORM, OR THE MINDBEACON APPLICATION, YOU SIGNIFY YOUR ACCEPTANCE OF THE TERMS OF THIS PRIVACY POLICY. BY USING THE MINDBEACON PLATFORM, OR THE MINDBEACON APPLICATION, YOU ALSO ACCEPT THE TERMS OF USE POSTED ON THE MINDBEACON PLATFORM, AND THE MINDBEACON APPLICATION.

You can update your account through the MindBeacon website, or by contacting our Privacy Officer.

If you have any questions about this Privacy Policy or the handling of your Personal Information, please contact the MindBeacon Privacy Officer.

Privacy Officer
privacyofficer@mindbeacon.com
MindBeacon Health Inc.
175 Bloor St East, Suite 801 North Tower
Toronto, ON, M4W 3R8
1-877-252-6707

If you have any concerns about MindBeacon’s privacy practices or for more information on your privacy rights, you can contact:

OntarioOffice of the Information and Privacy Commissioner 1-800-387-0073

AlbertaOffice of the Information and Privacy Commissioner 1-888-878-4044

British Columbia - Office of the Information and Privacy Commissioner 250-387-5629

Manitoba - Ombudsman 1-800-665-0531

New Brunswick - Office of the Integrity Commissioner 1-877-755-2811

Newfoundland and Labrador - Office of the Information and Privacy Commissioner 1-877-729-6309

Northwest TerritoriesInformation and Privacy Commissioner 1-888-270-3318

Nova ScotiaOffice of the Information and Privacy Commissioner 1-866-243-1564

Nunavut - Information and Privacy Commissioner 1-888-521-7088

Prince Edward Island - Office of the Information and Privacy Commissioner 902-368-4099

Quebec - Commission d’accès à l’information 418-528-7741

Saskatchewan - Office of the Information and Privacy Commissioner 1-877-748-2298

Yukon - Information and Privacy Commissioner 1-800-661-0408

Federal - Office of the Privacy Commissioner 1-800-282-1376