Updated: September 7, 2022

My Student Wellbeing Inc.

PRIVACY STATEMENT

My Student Wellbeing Inc. (“My Student Wellbeing”, “we” or “us”) is committed to protecting your privacy and safeguarding your personal information.  The purpose of this privacy statement is to inform you about our privacy practices, including how we collect, use and disclose your personal information.

This privacy statement relates to all of our activities, unless we have provided you with a separate privacy statement for a particular product, service or activity.

Please review this privacy statement carefully.  By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your personal information as set out in this privacy statement, as revised from time to time.

“You” and “Your” refers to the individual accessing this site.

“Practitioner(s)” refers to the independent contractors within our network.

WHAT’S IN THIS PRIVACY POLICY?

Meaning of Personal Information

Your Consent to Collection, Use and Disclosure

Personal Information We Collect

How We Use Your Personal Information

How We Share Your Personal Information

Opting Out of Communications

Retention of Personal Information

Information Security

Accessing and Updating Your Personal Information

International Transfer and Storage of Information

Third Party Websites and Services

Children’s Information

Privacy Statement Updates

Complaints

Contact Us

Meaning of Personal Information

“Personal information” means information about an identifiable individual.  This information may include, but is not limited to, your name, mailing address, e-mail address, university, student status, session history, payment history, address details and telephone number.

Personal information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your personal information with your consent or as permitted or required by law.  How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected.  Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.  If you choose to provide personal information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy statement.

Typically, we will seek your consent at the time your personal information is collected. Where we want to use your personal information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for this new purpose.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below.  However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services. We may be required to retain some information by law and we will advise you of what information, if any, we must retain should you ask. 

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this privacy statement.

Personal Information We Collect

The personal information we collect is generally in one or more of the following categories.

• Products and Services. For individuals who use our products and services, we may collect information from you or from your use of our products or services.
  • Information you submit to us: we collect information that you submit through your use of our products or services, including information you provide in connection with the creation and management of your account for our products or services, such as your name, e-mail address and other contact information and password.
  • Information we automatically collect: we collect log data and usage information relating to your use of our products and services.
• For individuals who visit our website located at www.mystudentwellbeing.ca or any of our related websites (collectively, “our website”), we may collect information from you or from your activities on the site.
  • Like most websites and other Internet services, we may collect certain technical and device information about your use of our website. Such information may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit.
  • We may also use “cookies” or enlist third party services which use cookies to track your preferences and activities on our website. Cookies are small data files transferred to your computer’s hard-drive by a website.  They keep a record of your preferences, making your subsequent visits to the site more efficient. Cookies may store a variety of information, including the number of times that you access a site, your registration information and the number of times that you view a particular page or other item on the site.  The use of cookies is a common practice adopted by most major sites to better serve their users.  Most browsers are designed to accept cookies, but they can be modified to block cookies.  See your browser’s help files for more information.  You should note, however, that without cookies some of our website’s functions may not be available.
• Other Interactions. For individuals who otherwise interact with us, whether in person, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address and other contact information.

We do not collect payment card information.  If you make an online payment for Practitioner Services using a payment card, such as a credit card or debit card, you are connected directly to our online payment processing service provider and your payment card information is collected and processed by that service provider.

How We Use Your Personal Information

We may use your personal information and other information for purposes such as:

• to provide you with our products and services and to support your use of our products and services;
• to contact you relating to our products and services;
• to monitor and improve our products and services, and to develop new products and services;
• to analyze the needs and activities of our customers to help us better serve them;
• to conduct research and analysis related to our business, products and services;
• to respond to inquiries and other requests;
• to collect opinions and comments in regard to our products and services;
• to provide you with information that we think may interest you, including in regards to our products and services; and
• to investigate legal claims.

We may use your personal information and other information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

We do not use the information we collect to provide advertising of third party products and services or targeted advertising of Company products and services across third party websites or service offerings.

How We Share Your Personal Information

We rely on third party services providers to perform a variety of services on our behalf, such practice management providers, payment card processers, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers.

If we provide your information to service providers, then we require that the service providers maintain the confidentiality of your personal information and keep your personal information secure.  We also require that they only use your personal information for the limited purposes for which it is provided.  In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you.  We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.  If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.  In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

Parties With Access

Parties who may access your information include the following and for what purpose:

• Mental Health Practitioner(s) (These people need to meet you to provide you with services)

In order to provide you with services, a mental health practitioner will need to have access to your personal information such as your name, address, contact information, and anything else you upload when you make an account in our system. This information is required to ensure they are providing Practitioner Services to the correct person, to ensure there are no conflict of interests in providing you with Practitioner Services, for billing, for case management purposes, and any other requirements to provide you with Practitioner Services.

• Third-Party Practice Solution (This is how we offer you with a secure platform to attend your sessions, store your information, and for our daily operations)

We use a third-party platform we use to securely store your data in Canada, host secure video sessions, schedule your appointments, store other information, and in other ways to provide you with Services and to facilitate Practitioner Services. Should there be an issue with your account, staff of the third-party platform may need to access your account for troubleshooting and technical support purposes.

• Our Accounting Firm and Lawyers (We need to meet the legal standards of accounting to stay in business, so we make sure it’s done properly with the use of an accountant)

We limit the amount of information we share with our accounting firm, but we may need to show them billing information as we process your payments to your assigned Practitioner. Should there be any legal disputes or claims related to your access of our Services, we may need to share your information for the case. Your information is protected by legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA) and we would only share the bare minimum required for any purpose.

• My Student Wellbeing Administrative Staff (Your practitioner handles your sessions, but we may still need to handle your scheduling, requests for information, billing, and other administrative tasks)

Our staff, will have access to your information to update your information, schedule appointments, to assist your Practitioner with their billing, and for other reasons related to providing you with Services or supporting your Practitioner with Practitioner Services. Your information will only be accessed when it is required to do so for reasons related to your access of our Services and only by people who have signed documentation to protect the privacy of your information. Any staff we work with will be required to sign documentation indicating they will protect your information as per the legal requirements.

• Your Insurance Provider (They have their requirements to reimburse you or cover your session fees)

In order to use your health benefits your insurance provider may require information about your access of your Practitioner Services which may include your name, address, contact information, dates you accessed services, length of your sessions, the name of your Practitioner, the cost of your session(s), or other information as required. Your Practitioner is responsible for billing insurance, where applicable, but My Student Wellbeing may provide administrative support to assist them in billing. We would only provide the insurance provider enough information for them to process your claim.

My Student Wellbeing may check your insurance coverage, such as because you completed a form or because you booked a session with a Practitioner. By providing your insurance information you consent to us collecting and storing that information, submitting the information to the insurance company to confirm your benefits coverage, to respond to you with our findings (if applicable), to store confirmation of coverage in our system, and/or to process insurance claims. You are only allowed to submit insurance information with pertains directly to you. 

 Other Service Providers

As mentioned, we use third-party solutions to handle a variety of our tasks and they may have access to certain information you provide. We carefully select who we work with and aim to pick companies that take your privacy seriously. An example of another service provider would be our email provider.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us, or, if you created an online account when you registered to receive our emails, you may log-in to your account and make changes to your communication preferences.  You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.  Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

When a Practitioner terminates their Agreement with My Student Wellbeing they are required to export their client information, including but not limited to financial records and session history. At that point, as you were the client of that Practitioner, we may delete your account from our database to minimize the amount of user information we have at any given time. We reserve the right to delete your account at any point. You are encouraged to regularly retain copies of your information while you access Services and Practitioner Services, as we will be unable to recover your information once it’s deleted.

Personal Health Information

Personal health information, such as what you share with a Practitioner or any notes a Practitioner creates about you is the responsibility of the Practitioner. My Student Wellbeing believes we do not need to have access to your personal notes or the information you talk about in session and as such, we direct our Practitioners to store, handle, manage, and retain your Personal Health Information off the My Student Wellbeing platform and as per the legislation applicable to their provision of Practitioner Services. The only time My Student Wellbeing would request access to your Personal Health Information, which would be in the possession of your Practitioner, is in the case of a legal matter which requires that information.

You have the right to review and correct the Personal Health Information your Practitioner records about you. Should you want to review your notes, you are directed to contact your Practitioner directly. If you want to learn more about your rights, you can contact the Office of the Privacy Commissioner of Canada or review the information on their website.

Should you provide us with any information deemed Personal Health Information, we will store, use, and disclose that information as per applicable laws. 

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification.  We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

Accessing and Updating Your Personal Information

We will take steps to ensure that your personal information is kept as accurate, complete and up-to-date as reasonably necessary.  We will not routinely update your personal information, unless such a process is necessary.  We expect you, from time to time, to supply us with updates to your personal information, when required.

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law.  You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information.  Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country.  While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

To handle scheduling, video sessions, billing, and other operations, we utilize a third party management software called Jane.app. You can learn more about Jane.app and its security features through visiting their website at jane.app/security-and-trust. We reserve the right to change our third party service providers at any time, which means the storage of your information may change location while you access Services and Practitioner Services. 

Third Party Websites and Services

This privacy statement applies only to our products and services.  This privacy statement does not extend to any websites or products or services provided by third parties.  We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Information

Our products and services are not intended for children under the age of 16, and we do not knowingly collect personal information from children under the age of 16.  Children under the age of 16 should not use our products and services and should not provide us with their personal information.

Other Information We Collect

We may also collect information that is not considered personal information, including, but not limited to feedback from you. By providing us with feedback or other information, you accept that you will not be compensated or recognized for any ideas, products, or services that comes from your submission of information. You accept that we gain full rights over any content or information you share with us and we can use the content or information for our business purposes or share it with third parties. An example of how we may use information you share would be creating and releasing a report which summarizes information students have shared with us about how they feel about My Student Wellbeing or the type of prizes they would be interested in winning. Another example would could be sharing the aggregated information we collect with a student group so they can also understand what type of content students are interested in learning about. We will not share personal information in this way with any third parties and should your name be attached to a submission of non-personal information, we will not include your name or identifying information in anything we share with a third-party. 

Privacy Statement Updates

This privacy statement is current as of the “updated” date which appears at the top of this page.  We may modify this privacy statement from time to time.  When changes are made to this privacy statement they will become immediately effective when published in a revised privacy statement posted on our website unless otherwise noted.  We may also communicate the changes through our services or by other means.  By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this privacy statement, you consent to our collecting, using and disclosing your personal information as set out in the revised privacy statement.

Complaints

If you have any complaints regarding how we handle your information, we would appreciate it if you could contact us and speak with us regarding your concerns. If our response is unsatisfactory or you are not comfortable speaking with us, you can contact the Office of the Privacy Commissioner of Canada.

Contact Us

All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer as follows: