PRIVACY POLICY

Last Revised: November 18, 2020

Introduction

Psymood Technologies Inc. (“PsyMood”, “We”, or “Us” and terms of similar meaning), respects your (“Your”) privacy and is committed to protecting it through PsyMood’s compliance with this privacy policy (the “Privacy Policy”). This means PsyMood does not transfer, distribute, disclose, rent or sell any of Your Personal Information to third parties except as provided for in this Privacy Policy or as specifically consented by You.

PsyMood has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Personal Health Information Act (“PHIPA”), and other relevant privacy laws.

By accepting this Privacy Policy in registration for the PsyMood Services and/or by visiting and using website and platform (the “Platform”), you (“You”) expressly consent to our collection, use and disclosure of Your Personal Information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service available at https://www.psymood.com/terms-of-use. Undefined capitalized terms used in this Privacy Policy have the meanings given to them in our Terms of Service.

Scope

This Privacy Policy applies to all Personal Information, including Personal Health Information, collected, used or disclosed by PsyMood from users of PsyMood’s Services (“Clients”), including You. “Personal Information” is any information in any form that identifies or can identify an individual or could be combined other information to identify You, and includes Personal Health Information.

This Privacy Policy also applies to information that is about You, but individually does not identify You, as described below.

Information We Collect

a. Personal Information

Personal Information that PsyMood collects includes, but is not limited to:

  • Registration Information: You need to create an account before You can use the Services. When You register for an account, we collect Your first and last name, username, password and email address.
  • Service Information: Information that You provide to us in using our Services, including information and records that You provide to our Specialists during Wellness Sessions, including medical or health history, health status and laboratory testing results, diagnostic images, and other health related information (“Session Information”);
  • Billing and payment information, including credit card information and bank account details;
  • Any other Personal Information that You may provide when You use the Services, or when You contact PsyMood with questions and/or inquiries;
  • Technical support records;
  • Service requests and inquiries; and
  • Any information that PsyMood collects from You that is intended to improve and personalize PsyMood’s Services.

b. Non-specific Personal Information

PsyMood collects non-specific Personal Information (“NPI”) about Clients when they interact with the Services. For instance, NPI may include, but is not limited to, device information, IP address, geo-location information, browser name, type of computer or device, and technical information about a Client’s means of connecting to the Services, such as operating system, Internet service provider utilized, and mobile network information.

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any other Client. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

Definitions

To better understand this Privacy Policy, below are some basic definitions to use when reading and interpreting it.

  • Collection: the act of gathering, acquiring, recording, or obtaining Personal Information from any source, including third parties, by any means.
  • Consent: voluntary agreement to the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of PsyMood. Implied consent is consent that can reasonably be inferred from the circumstances or from an individual’s action or inaction.
  • Disclosure: making Personal Information available to a third party for that party’s own use.
  • Personal Health Information: information that relates to the physical or mental care of individual, including information that consists of such individual’s health care.
  • Transfer: making Personal Information available to a third party for processing, storage or otherwise, solely to be used on behalf of PsyMood.
  • Use: the treatment, handling and management of Personal Information by and within PsyMood.

Principles

PsyMood’s Privacy Policy is organized along the ten privacy principles of PIPEDA.

Principle #1 – Accountability

PsyMood is responsible for the Personal Information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and privacy legislation.

Accountability for PsyMood’s compliance with the provisions of PsyMood’s Privacy Policy rests with the Privacy Office within PsyMood, which has designated one or more persons to be accountable for compliance with this Privacy Policy. We may delegate to other individuals within PsyMood to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Clients have a designated avenue to answer their privacy-related inquiries.

PsyMood will make known, upon request, the title of the person or persons designated to oversee PsyMood’s compliance with this Privacy Policy.

PsyMood is responsible for Personal Information in its possession or custody, including information that has been transferred to a third party for processing. PsyMood shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

PsyMood shall implement policies and practices to give effect to these principles, including:

  • Implementing procedures to protect Personal Information;
  • Establishing procedures to receive and respond to complaints and inquiries;
  • Training staff and communicating to staff information about the organization’s policies and practices; and
  • Developing information to explain the organization’s policies and procedures.

Principle #2 – Identifying Purposes

Personal Information

PsyMood collects Personal Information for the following purposes:

  • to provide Services to our Clients, including Wellness Sessions conducted by our Specialists;
  • to establish and maintain responsible commercial relations and to communicate with You in order to provide Services;
  • to permit PsyMood’s third party payment provider(s) to provide payment services;
  • to respond to any correspondence, You may direct to PsyMood;
  • to understand PsyMood’s Clients’ needs and preferences;
  • to enforce PsyMood’s Terms of Service and other legal agreements;
  • to provide You with service or administrative messages;
  • to direct advertisements about our company and our products and services that may be of interest to You;
  • to meet legal and regulatory requirements;
  • to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
  • to improve the Services; and
  • for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

Non-specific Personal Information

PsyMood uses NPI in an ongoing effort to better understand and serve the Clients of PsyMood’s Services, including to provide the Services and to improve the content and functionality of the Services.

For instance, PsyMood uses NPI to monitor traffic and to collect statistical data.

PsyMood also conducts research on PsyMood’s Client behaviour and demographics based on Personal Information and the NPI that PsyMood has collected. This research will be compiled and analyzed on an aggregated basis and this aggregated data does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

No NPI by itself, or together with aggregated Personal Information (which, as explained below, is treated as NPI under this Privacy Policy), can be tracked to a specific individual’s Personal Information.

Specific Uses of NPI by PsyMood:

  • To monitor traffic, provide the Services, and conduct internal research on PsyMood’s Clients’ to better understand and serve them, including Clients’ size, usage patterns, demographics, interests and behaviors.
  • The NPI collected by PsyMood will not be shared with third parties, except as expressly indicated in this Privacy Policy, or with PsyMood’s Affiliates (as defined below), business partners and other third parties to describe PsyMood’s Services and for other lawful purposes.
  • PsyMood may use and store information about Your location if You give PsyMood permission to do so. PsyMood uses this data to provide features of the Service, to improve the Service and customise the Service. You can enable or disable location services when You use our Service at any time by way of Your device settings.

Principle #3 – Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below.

In certain circumstances, PsyMood may collect, use or disclose Personal Information without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it.

impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual’s life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available.

Where appropriate, PsyMood will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when PsyMood wants to use information for a purpose other than those identified above).

In obtaining consent, PsyMood will use reasonable efforts to ensure that a Client is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by PsyMood may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, PsyMood shall take into account the sensitivity of the Personal Information and the reasonable expectations of its customers and employees.

PsyMood will seek consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. In certain circumstances, Your consent may be implied by Your actions. For example, providing us Personal Information to create an account or input into our document builder service is implied consent to use such information to provide You the associated services.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, however, withdrawing consent may result in our inability to provide You with certain Services. In order to withdraw consent, You must provide notice to PsyMood in writing.

Principle #4 – Limiting Collection

PsyMood will limit the collection of Personal Information to that which is necessary for the purposes identified by PsyMood. PsyMood will collect information by fair and lawful means. PsyMood collects Personal Information from our Clients for the purposes described under Principle #2.

Principle #5 – Limiting Use, Disclosure and Retention

Unless required by law, or in connection with a business transaction, PsyMood will not use, disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining Your consent, where such consent may not reasonably be implied.

PsyMood and our Specialists collect and use Your Personal Information that is provided by You during Wellness Sessions or uploaded to the Platform to complete and update online profiles, which may include Your Personal Health Information. Neither PsyMood nor our Specialists will use such Personal Information for any other purpose than providing and facilitating the provision of Wellness Services. Should a Specialist collect further Personal Information, aside from Session Information, directly from You during a Wellness Session, it will seek consent directly from You as appropriate.

We may also transfer Your Personal Information to third party suppliers, underlying technology licensors, contractors and agents, (“Affiliates”) who are contracted by PsyMood to assist it in providing services to You. For example, we may transfer Your billing information to our payment processor. Our Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy.

Our servers are located in Canada and in general Your Personal Information will remain in Canada. However, Affiliates may be located outside of Canada and certain of Your Personal Information may be collected, used, disclosed, stored and processed in such jurisdictions for the purposes described in this Privacy Policy. PsyMood takes reasonable contractual or other measures to protect Your Personal Information while processed or handled by such Affiliates. If Your Personal Information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries. For greater certainty, Your Personal Health Information and other Session Information will not be stored outside of Canada.

In the event Your Personal Information is disclosed to a third party pursuant to a business transaction (including a potential sale or financing), PsyMood will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only PsyMood’s and our Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about our Clients. All such employees will be required as a condition of employment to contractually respect the confidentiality of Your Personal Information.

PsyMood will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by PsyMood.

Principle #6 – Accuracy

To the extent that PsyMood directly collects Personal Information from Clients, as opposed to Clients disclosing Personal Information to PsyMood in using the Services or registering for an account, it will make reasonable efforts to ensure that such Personal Information is accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

PsyMood will update Personal Information about Clients as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle #7 – Safeguards

PsyMood will protect Personal Information by security safeguards appropriate to the sensitivity of the information.

PsyMood will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.

We take administrative, technical and physical measures to safeguard Your Personal Information against unauthorized access, unauthorized disclosure, theft and misuse. This includes the implementation of encryption protocols with respect to the transmission of data, limiting access of employees to, and the use of, Your Personal Information through the use of passwords and graduated levels of clearance. We do not publish all of our security measures online because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which Your Personal Information is stored and archived are secure and in a controlled environment with limited access. We educate our employees with respect to their obligations to protect Your Personal Information.

PsyMood makes its employees aware of the importance of maintaining the confidentiality of Personal Information. All of PsyMood’s employees with access to Personal Information will be required as a condition of employment to contractually respect the confidentiality of Personal Information.

PsyMood will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorized access to Your Personal Information and no website is completely secure. We cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.

PsyMood’s privacy practices are intended to comply with applicable privacy laws, including, without limitation PIPEDA and PHIPA. We will maintain the privacy of Your personal information as required by those privacy laws.

Principle #8 – Openness

PsyMood shall make readily available to Clients specific information about its policies and practices relating to the management of Personal Information.

PsyMood will make information about its policies and practices easy to understand, including:

  • The title and address of the person(s) accountable for PsyMood’s compliance with the policy and to whom inquiries or complaints can be forwarded;
  • The means of gaining access to Personal Information held by PsyMood; and
  • A description of the type of Personal Information held by PsyMood, including a general account of its use.

PsyMood will make this Privacy Policy available online at https://www.psymood.com/privacy-policy. On request, a copy of this Privacy Policy will be provided by mail.

Principle #9 – Individual Access

Upon request, PsyMood will provide information to a Client regarding the existence, use and disclosure of his or her Personal Information. PsyMood will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A Client may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, PsyMood may not be able to provide access to all the Personal Information it holds about a Client. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. PsyMood will provide the reasons for denying access upon request.

Principle #10 – Challenging Compliance

An individual may address a challenge concerning compliance with this Privacy Policy to PsyMood’s Privacy Officer.

PsyMood will maintain procedures for addressing and responding to all inquiries or complaints from Clients about PsyMood’s handling of Personal Information. PsyMood shall investigate all complaints. A Client shall direct all inquiries or complaints involving PsyMood’s handling of Personal Information or compliance with this policy or with PIPEDA to PsyMood’s Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If PsyMood finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact our Privacy Office as follows:

E-mail: hello@psymood.com

Mail: 325 Front Street West Suite 300

Toronto, ON M5V 2Y1

Cookies & opt-out

PsyMood uses cookies to enhance Clients’ experiences. Clients’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them. Cookies help PsyMood accurately understand how many consumers are visiting the Platform, how often Clients visit the Platform, what Content Clients are most interested in, and how they prefer to interact with content on the Platform. For example, a cookie will allow PsyMood to remember certain things like Your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), Your login information, the time and duration of Your visits, how You navigated through PsyMood’s content and where You exited the Platform. To save You the time of re-entering Your login information every time You come back to the Platform, PsyMood may link information contained in a cookie to Your email address. PsyMood does not use cookies to retrieve information from Your device that PsyMood did not originally send in a cookie.

Examples of Cookies we use include:

  • Session Cookies, which are used to operate the Services.
  • Preference Cookies, which are used to remember Your preferences and various settings.
  • Security Cookies, which are used for security purposes.

PsyMood uses Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor use of the Services. The data is shared with other Google services. Google Analytics uses cookies to track information about traffic and visitors and sends such information: (i) to Google servers in the United States and (ii) to PsyMood. Google Analytics does not identify any individual users or associate Your IP address with any other data held by Google. PsyMood uses such information in the aggregate to compile statistical reports about the activity on the Services as well as to benchmark the Services to other third parties who also use Google Analytics. In addition, Google may use the collected data to contextualise and personalise the ads of its own advertising network. This information is used by PsyMood to improve the Services and their functionality. Google’s privacy policy can be found here: policies.google.com/privacy.

You may disable cookies using Your browser’s settings. Please consult Your browser’s help function for information on how to disable cookies.

You may opt-out of Google Analytics by clicking here: tools.google.com/dlpage/gaoptout?hl=en

Note that if You disable cookies, certain features of PsyMood’s Services may not function to their fullest potential.

Minors

We do not knowingly allow individuals under the age 15 to create their own Accounts. Individuals under the age of 15 may access the Platform or receive Wellness Services at the discretion of Specialist using their parent or legal guardian’s Account and in the presence of that parent or legal guardian.

General

PsyMood reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on https://www.psymood.com/privacy-policy.

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