INTRODUCTION

 
Myndplan is committed to ensuring the privacy of any information that you provide us. Our success depends on you being able to trust that this site is secure. Please read the following so that you understand our privacy policies and procedures. This is essential for you to make an informed decision about using them.

We designed Myndplan to take mental health education to the next level and beyond. In doing so, we have created something that defies current definitions. It has many things in common with a self-help book, such as brief screening tools and lots of information. However, it can also monitor your choices and respond to them, keep track of your information for you, use that information along with information from other people to improve its ability to predict things, and countless other things which a self-help book cannot do. While we believe these are all helpful things for you as a consumer, they require us to keep a record of your activity, your personal beliefs and your preferences.

By visiting the Myndplan.com website and domain name, and hence any of the associated pages, content, or applications offered by Myndplan, or by using any of our Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy.

In the following, please understand that the terms “the company”, “we”, “us” “our” or other similar terms refer to Myndplan inc., which is the name of the parent company and who are the provider of Myndplan.com and related Services. The terms “you”, “your” or similar refer to you, who are a user of our Services.

By accepting this Privacy Policy during the registration process, or by visiting and/or using the Sites or any of our Services, you (a) expressly consent to our collection, use, and disclosure of your Personal Information in accordance with this Privacy Policy, and (b) expressly acknowledge that you have read and understood our PHIPA and HIPAA notices, which provide important information specific to this service about how we may use and disclose health information about you. Our PHIPA and HIPAA notices are included as part of this course.

When you read this Privacy Policy, you will notice that we constantly refer to the terms “using” and “processing” information. These terms refer to a wide variety of actions. To give you some specific examples, they can mean inserting cookies on your computer, or carrying out statistical or other analysis on your information. Actually, the terms are very open and refer to using or handling information in any way. This includes, without limitation, gathering, transferring, evaluating, changing, deleting, combining, storing, and disclosing information within our organization. It also includes using your personal information to respond to user / applicant inquiries and provide the requested products and services. This is very different in comparison to what happens when you read a self-help book, for example. When you read a self-help book, it is not paying any attention to what you are doing. It does not watch your behaviour and record your actions. It does not record any information, never mind analyze it or use it in any way. In short, you do not have to worry about your privacy when you read a book, but when you are using an app or website it is very important to understand the limits of your privacy.

Please note that this policy only applies to Myndplan and does not address the policies or procedures of any other companies or sites that we do not own or control, or to individuals who are not our employees.

WHAT DOES THIS PRIVACY POLICY COVER?

 
Non-personal information includes things like what pages you visit on our site, or what services you use or may potentially use. Your identity cannot be determined from this information. For this reason, most people are not too concerned about giving away non-personal information, as it seems unlikely that its use could bring about any harm.

Personal Identifying Information includes things like your name, email address, and other information that could be used to identify you. We gather Personal Identifying Information from the moment that you first access our Sites or use our Services.

Sensitive Information or Personal Health Information can affect your privacy or welfare. Personal Health Information (PHI) is an example of Sensitive Information specific to your physical or mental health. It can include information about your past, present, or future physical or mental health, or information about your health care or payment for health care. Our questionnaires and self-monitor tools can request Sensitive Information. Your self-report information expressing your feelings, or describing your opinions and behaviouzrs is also something that most of us consider personal and confidential. We recognize that protecting Personal Health Information that is received, created, maintained, or transmitted by us is critical to our Services.

This Privacy Policy describes how we protect your privacy as a visitor to, or general user of our Sites and Services. You have additional rights under federal and provincial or state laws with respect to the access to, use, and disclosure of PHI. In Ontario, your personal health information is protected by the Personal Health Information Protection Act (PHIPA). In the United States, personal health information is protected under the Health Insurance Portability and Accountability Act (HIPAA). For a more complete description of your rights with respect to PHI, please refer to our PHIPA and HIPAA Notice, which provide important information to you about how we may use and disclose your PHI. Our PHIPA and HIPAA Notice is available at: mindplan.me/phi/.

WHAT PERSONAL INFORMATION DO WE COLLECT?

 
We collect personal information when you choose to provide it, beginning when you first access our Sites or use any of our Services. This may be prompted by a request on our part, e.g., through a registration process, when filling out questionnaires, or when completing various monitors. Sometimes personal information is given in connection with your inquiries, e.g., when you identify yourself in order to ask for specific information. The information we gather from customers enables us to personalize and improve our Services.

Sometimes we may use or add to the personal information we have about you with information obtained from third parties. For example, we may use third party information to confirm contact or financial information, to verify eligibility, or to better understand your interests by associating demographic information with the information you have provided.

We collect the following types of information from our customers:

Personal Information You Provide to Us

 


We receive and store any information you enter on our Sites or provide to us in several ways. Personal Information that we collect may include things like your full name, mobile phone number, credit card and/or other payment information (if applicable), your email address and the email address of your contacts, home and business postal addresses, IP address, browser information, username, password, certain health information (e.g., weight, insurance information), and any other information or data that you provide when using our Sites and/or our Services. You can choose not to provide us with certain information, but that may limit our ability to provide you access to many of our features. We use the Personal Information you provide for such purposes as answering questions and communicating with you about our products and services, including updates and new features. It is usually required in order to complete financial transactions, such as when you pay for some of our Services. If you are working with a counsellor or therapist using our Sites, they are often required by their own standards of practice to have this information to meet their record keeping requirements.

PLEASE NOTE: By using some of the Services, you consent to, and authorize us to disclose your information to the other users of the Sites and Services. The users, including but not limited to Site administrators, Clinicians, and your fellow support group members (if you are in a Myndplan support group) will have access to a range of Personal Information such as your name and picture, linking you to your diagnosis and reason for program participation. Keep in mind also that discussion group members may be acquaintances, in the event that other users of the Sites are from your community or workplace or connected to you in any way.

We take great efforts in protecting your privacy, however, we cannot control, and expressly disclaim any responsibility for, whether or how users will subsequently use or disclose posted or previously disclosed information. If you do not consent to the disclosure of this information, you should not access or use the Sites or the Services. We do our best to inform all users of our Sites as to the Rules of Confidentiality that typically operate in clinical settings. These rules involve a variety of expectations that people desire when discussing anything that is personal. However, we cannot legally bind anyone using the Sites to observe these rules.

The Services include the ability for users to share Personal Information, including information regarding your medical, and in particular, your mental health condition. Any information you choose to provide or upload to the group Sites, including Personal Information about your mental health, will be visible to your group, as well as Clinicians, Site administrators, and other Site users. Because your information can be viewed by the other users of the Sites, you should provide only the information you feel comfortable disclosing.

Some of our Services may include an opportunity to exchange messages. This is not mandatory, but if you choose to participate, you should share only as much information as you feel comfortable sharing using this format.


Personal Information Collected Automatically

 
We receive and store many types of information whenever you interact with our Sites and / or use our Services. We automatically receive and record information on our server logs from your browser, including your IP address, and the page you requested. In addition, we often use personal identifiers to recognize you when you arrive at the Site via an external link, e.g., such as a link appearing on a third party site or in a Myndplan-generated email presented to you. We will also use your information to provide customer service and support.

Generally, our Services automatically collect usage information, such as the numbers and frequency of visitors to our Sites and its components. We only use this data as a statistical measure, and not in a manner that would identify you personally. This type of information helps us to figure out how often customers use parts of the Sites or Services so that we can make the Sites interesting to as many customers as possible. We may provide this de-identified, “aggregate” data to our partners to identify how our customers, as a group, use our Sites or Services. We share this type of statistical data so that our partners also understand how often people use the Sites or Services, so that they, too, may provide you with an optimal online experience. Again, we never disclose aggregate information to a partner in a manner that would identify you personally.

E-mail Communications

 
We often receive a confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. When you receive e-mail from us, you can opt out of receiving further e-mails by following the included instructions to unsubscribe.

Cookies

 
Cookies are identifiers that we place on your computer’s hard drive using your browser to help our systems to recognize your browser and tell us how and when pages in our Sites are visited and by how many people. We use cookies to understanding how visitors and / or users engage with and navigate our Sites so that we can make improvements.

Most browsers have an option for turning off the cookie feature. If you do this, it will prevent your browser from accepting new cookies. Turning off cookies may also allow you to decide on acceptance of new cookies in a variety of ways. If you choose to turn off your cookies some of our Site’s features will no longer work. If your browser is set to reject cookies, our Sites will not be able to recognize you when you return to the website, and some website functionality may be lost. If your cookies are turned off you will probably have to repeat entering the same information each time you visit the Sites or use a specific Service.

WHAT PERSONAL INFORMATION DO WE SHARE?

 
Personal Information about our customers is the most important part of our business. Consequently, we are highly motivated to protect it. We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide Services, when we otherwise have your permission, or under the following circumstances:

Forums


 
We may provide functionality for you to participate in activities, blogs, bulletin boards, chat rooms, discussion boards, games, instant messaging, and other forms of communication with other Clients and/or Clinicians. We may make available your Personal Information through these Services to which you post information and materials. Some of these Forums are described more specifically below. Please note that any information, text, and images posted or disclosed by the user on or through such Forums may be visible to the user’s group(s), as well as Clinicians, Site administrators, visitors to the Sites, and other users of the Sites. Specifically, Personal Information such as the picture you’ve uploaded and your screen name may be available for other users to view when you make a posting to such Forums. Information regarding your activities in such Services may also be available for view by other users (for example, other users may be able to view a list of all postings you have made in all available Forums). Any postings you have made to a Forum may also be available for view later by users of the Sites by scrolling to older posts on the Forum. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, such as your illness, or any other information, through a Forum or otherwise through the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION DISCLOSED BY YOU OR ON YOUR BEHALF BY YOUR SYSTEM THROUGH A FORUM OR OTHERWISE THROUGH THE SITES.

Discussion Boards and Chat Rooms

 
We may provide functionality to post on our discussion boards, and permit you to enter into chat rooms and communicate with other users in the chat rooms. Please note that if you use such functionalities to communicate, your name / screen name will be disclosed to all visitors to the discussion boards, present and future, as well as all users in the chat room at that time. Please remember that information posted to discussion boards becomes public information. Use caution when posting. Further, if a comment you make on the discussion board or in the chat room contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the other users of the discussion board or chat room. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any comment and/or message, and to be careful about the people to whom you send such comments and/or messages. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT IS DISCLOSED BY YOU OR ON YOUR BEHALF BY YOUR SYSTEM ON DISCUSSION BOARDS, IN CHAT ROOMS OR OTHERWISE THROUGH THE SITES. We may provide functionality to permit you to send messages, including instant messages, to other users through the Sites. Please note that if you use such functionality to send such a message to another user, your screen name will be disclosed to that user, as well as Site administrators. Further, if a message you send using such functionality contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the recipient of your message. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any message, and to be careful about the people to whom you send such messages. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT IS DISCLOSED BY YOU OR ON YOUR BEHALF BY YOUR SYSTEM IN SUCH MESSAGES.

User Profiles

 
We may provide functionality to permit you to create a user profile page in which you may provide information about yourself, including, without limitation, your illness, symptoms, treatments, as well as your feelings about your illness and/or yourself (“User Submissions,” as further defined in our Terms). You may also be able to upload pictures, videos and stories to your profile page as part of the User Submissions. User Submissions may be displayed to other users (including members of your group(s), who may be affiliated with you in some way) to facilitate user interaction within the Sites. Email addresses are used to add new User Submissions to user profiles and to communicate through User Submissions. Users’ email addresses will not be directly revealed to other users by us, except when the user is “connected” to another user via a shared group membership, or an invitation, or if the user has chosen to include their email address in their User Profile. Please note that any User Submissions you make, including Personal Information, on or through your profile page may be available for other users, the Company, administration, moderators, and other staff. Additionally, other users may be able to post comments and view posted comments on your profile page.

Communication in Response to User Submissions
As part of the Sites and Services, you will receive from us email and other communication relating to your User Submissions. You acknowledge and agree that by posting such User Submissions, we may send you email and other communication that we determine, in our sole discretion, as related to your User Submissions.

Affiliated Businesses We Do Not Control

 
In order to provide you with the optimal user experience, we anticipate that we may become affiliated, and work closely with a variety of third-party businesses. In certain situations, these businesses may sell products or services to you through the Sites. In other situations, we may provide services, or sell products jointly with affiliated businesses. You should be able to recognize when an affiliated business is associated with your transactions, and throughout the course of the transactions we will share your Personal Information that is related to such transactions with the affiliated business.

Agents

 
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and/or services to you. Without specific authorization and/or consent, we limit the rights of our agents to use Personal Information we share with them to that which is minimally necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.

Promotional Offers

 
We will never disclose your personal information to other businesses for their marketing purposes, but we may send you offers that promote the products of other businesses. These offers will be intended to benefit you, your health, or your Myndplan experience. If you do not wish to receive these offers, please send an email with your request to privacy@myndplan.com, and we will process your request within a reasonable time. Please note that you may receive additional offers as we process your request.

Business Transfers

 
In some cases, we may choose to buy or sell assets. In these types of transactions, customer information, including Personal Information about customers, is typically one of the business assets that are transferred. Moreover, if the Company, or substantially all of its assets were acquired, or in the unlikely event that the Company goes out of business or enters bankruptcy, Personal Information would be one of the assets that is transferred or acquired by a third party. By continuing to use our Sites and Services, you acknowledge that if we sell or transfer our business (e.g., through an acquisition) or an asset (e.g., our website) to another company, we will share your personal information with such company and will require such company to use and protect your personal information consistent with this Privacy Policy.

Protection of the Company and Others

 
We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to control the sharing of this information.

IS MY PERSONAL INFORMATION SECURE?

 
We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. These measures include encrypting your communications by utilizing Secure Sockets Layer (“SSL”) software using the industry standard 256-bit AES (Advanced Encryption Standard), and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we try our best to use systems and processes consistent with information privacy and security requirements under applicable federal, provincial and state laws, including, without limitation, the Personal Health Information Protection Act (PHIPA) and the Health Insurance Portability and Accountability Act (HIPAA).

Furthermore, your individual user account is protected by a password for your privacy and security. To prevent unauthorized access to your account and Personal Information, we recommend that you choose a high level password, safeguard it appropriately and limit access to your computer and browser by signing off after you have finished accessing your account. Many computers, tablets and mobile phones now offer full encryption capabilities and we recommend that you use such features if they are available. To help protect your privacy we may include a time-out feature that logs you out of your account if it is inactive for a specified amount of time. We endeavor to protect user information to ensure that user account information is kept private. However, we cannot guarantee the security of your personal and other information or the appropriateness of the measures we use to safeguard such information. Unauthorized entry, access, or use; loss; hardware or software failure; and other factors, may compromise the security of user information at any time.

The Sites contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read the privacy policy published on that site. This Privacy Policy only governs information collected on our Sites or through our Services.

If necessary, we will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored, “personal information” or “medical information” (as defined in applicable state statutes on security breach notification). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on your private profile on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Services offered through our Sites, by Internet or email cannot be guaranteed. If you have reason to believe that your data or your interactions with us are no longer secure, you may contact us at the mailing address or telephone number listed at the end of this document. In addition, if you have privacy or data security related questions, please feel free to contact the office identified at the end of this document.

WHAT PERSONAL INFORMATION CAN I ACCESS?

 
To the best of our abilities, we treat your information as a form of personal health record. We believe that you should have access to as much of this information as possible for viewing and updating. The following is a list of the types of information we give you access to.

• Legal Name
• Account and user profile information (e.g., nickname and picture)
• User email address
• User mailing address
• User mobile phone number
• Username and password
• Communication preferences  
  Other information about you is available for limited access. Your responses to questionnaires or records from self-monitoring are examples of this. We allow you to view your various scores and other information in your personal record to the best of our abilities. This information usually cannot be altered once you have entered it.
  
  Furthermore, we cannot always give you access to the “raw data”, (i.e., individual item scores or raw scale scores) upon which scores are based. If you should request us to remove your personal information, in some cases we can only remove identifying information. For example, information of yours that has been “anonymized” and used for quality assurance purposes, (i.e., that has had your identifying information removed so that it can be used for quality assurance purposes), cannot be removed because we can no longer identify it as yours.
  
  

WHAT CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?

 
You can always opt not to disclose information, even though it may be needed to take advantage of certain features of the Sites and the Services.

You are able to add or update certain information on pages, such as those listed in the “What Personal Information Can I Access” section, above. When you update information, however, we often maintain a copy of the unrevised information in our records.

If you would like us to remove your records from our system, you may request deletion of your account with us by sending e-mail to privacy@myndplan.com. Some information will remain in our records even after we delete your account. For example, we are legally obligated to retain certain types of information to maintain records necessary to meet certain provincial, state or federal standards or regulations. We will also keep an anonymized record of your data for statistical purposes. Note that once your data has been anonymized, no one can connect the information with your identify. Consequently, in the event that you decide you would like us to retrieve your information, we will not be able to do this. If you want to be able to use your information at a later date, then you should not request for it to be deleted.

We will process your request within a reasonable time, but please note that you may receive additional offers as we process your request. If you do not wish to receive email or other mail from us, please indicate this preference by emailing us at privacy@myndplan.com. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Sites, and you are responsible for reviewing such legal notices for changes.

HOW DO WE PROTECT CHILDREN’S PERSONAL INFORMATION?

 
Our Services are not designed for children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of our Services, nor do we knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information, we will delete such Personal Information from our files.

CHANGES TO THIS PRIVACY POLICY

 
By using our Sites and Services, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. Use of any information we collect now is subject to the Privacy Policy in effect at the time such information is used or disclosed. If any changes are made in the way we use Personal Information, we will notify you by posting an announcement on our Sites and/or sending you an email. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease accessing the Sites and / or using the Services.

QUESTIONS OR CONCERNS

 
Direct any questions or concerns regarding privacy on our Sites to privacy@myndplan.com or to our mailing address at Myndplan, Inc., Box 250, Flesherton, Ontario, N0C 1E0.