Privacy Policy

Last Updated: June 23, 2022

This Privacy Policy describes how Greenspace Mental Health Ltd. (“Greenspace” or “we”) may collect, use and disclose your Personal Information, and the services provided by Greenspace in connection with this Website (collectively, the “Services”).

For the purpose of this Privacy Policy, “Personal Information” means any information about an identifiable individual, within the meaning of applicable privacy laws. Aggregated or anonymous information, which does not or cannot reasonably identify an individual, is not Personal Information.

Greenspace is committed to protecting the privacy and security of your Personal Information. This Privacy Policy is designed to explain the types of information we collect and how it is used, including:

• What Personal Information We Collect and How We Collect It
• How We Use Your Information
• Disclosure of Your Information
• Processing, Retention and Storage of Personal Information
• Safeguarding Your Information
• Accessing Your Personal Information
• Changes to this Privacy Policy
• Contact Us

By using the Services, or otherwise providing us with your Personal Information, you are a user of the Services (“User”) and you consent to our collection, use and disclosure of your Personal Information in accordance with the terms of this Privacy Policy. This Privacy Policy should be read together with our applicable Terms of Use. If you do not agree with this Privacy Policy or the Terms of Use, please do not use the Services.

We encourage you to read this Privacy Policy carefully, and to watch for and read any updates that might be made from time to time, as explained below under “Changes to this Privacy Policy”.

What Personal Information We Collect and How We Collect It

We collect the following information about you either by (i) your providing it to us using the Website, by email or other electronic communications, or by telephone to our customer service representatives, or (ii) data collected when you use the Services.

To use certain features or read certain content, you will need to create an account (“Account”). To create an account you will need to provide:

• your name
• an email address
• a telephone number (optional)
• a password
• a security answer
• answers to certain demographic questions.

While using Services, you may be asked for information related to the state of your mental health and personal quality of life, which we collect from you. We may also request feedback about our services. We recognize this is sensitive Personal Information and treat it as confidential in the manner described below.

Our Use of Cookies and Other Technologies to Collect and Use Your Personal Information

Greenspace uses log files, cookies, web beacons and similar technologies to remember user preferences and collect information about visitors to the Website and App. Some cookies are required for the operation of the Website and App and are not optional.

Log files are records of all visits to the Website, which are automatically generated. These files make a record of each visit to the Website and log a number of details, that may include: the User’s operating system; IP address; the date, time and duration of the visit; the pages and documents accessed; and the previous site accessed by the User (such as, the search engine that referred the User to the Website). Greenspace also uses analytics tools to provide statistics about the visitors to the Website and App. These tools use cookies and other identifiers to collect certain information such as your IP address, your device or browser type, and your activity on our Platform such as click rates and bounce rates to measure and report statistics about user interactions on the Website. The tools collect and analyze non-personally identifiable information in order to create reports and identify platform trends, without identifying individual visitors. We do not share any Personal Information with any of the analytics tools. You can find more information about Google Analytics at https://policies.google.com/technologies/partner-sites. You can opt out of Google Analytics without affecting how you visit our Platform. For more information on opting-out of Google Analytics across all websites visit: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631.

Cookies are small text files stored on your device that identify your IP address to our computers each time you visit our Website and App. Although you can disable or block cookies on your device, the Website depends on the use of cookies. Accordingly, if you choose to block cookies you will not be able to use certain features of the Services.

Also with your consent, we may use pixel tags, web beacons, clear GIFs or similar technologies in connection with some of our Website pages and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, measure the success of our marketing campaigns, and compile statistics about Website usage and email response rates. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can disable or block cookies as noted above. If you turn off cookies, web beacons (or similar technologies) will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded. With your consent, we also use cookies and similar technologies to remember information supplied by you in order to implement your preferences and your personalized content. You have the option to opt out of this aspect of the Website and App at any time by visiting “Manage My Cookies”.

How We Use Your Information

Greenspace uses your Personal Information

• To create an account that registers you to uses certain features or read certain content of the Services
• To provide the Services and customer support you request
• To answer your questions
• To provide you with the results of your self-assessments
• With your express consent, to match you with and recommend to you other’s services
• To customize, measure and improve our Services
• Better identify the locations of our Users
• To troubleshoot any problems
• To prevent potentially prohibited or illegal activities, and enforce our Terms of Use
• To monitor and analyze usage of the Services and identify trends
• To conduct surveys about the Services, and other potential services we could provide
• As required or otherwise permitted by law
• To fulfill other purposes disclosed at the time you provide us with your Personal Information or which are reasonably necessary to provide our Services or other related services requested by you

We use non-identifying and aggregated information from your interaction with the Website to improve the Website and to create reports about usage of the Services. For example, we use aggregated statistical data to track the number of visits to the Website, the number of views to particular pages, time-based traffic patterns, and the proportion of Users using certain devices. Through such records, Greenspace will not make any attempt to identify Users according to their browsing activity.

If a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent, we encourage any concerned parent or legal guardian to contact us.

Disclosure of Your Information

Greenspace does not trade or sell Personal Information to others. On notice to you, we will disclose to the websites, mobile applications or other platforms (operated by third parties) that you choose on this Website, Personal Information about you in order to facilitate your connecting to and using of such services.

Service Provider Arrangements: In order to provide the services available on the Greenspace platform, we have arrangements with certain technology-related service providers that are subject to contractual agreements that include appropriate privacy standards. We may transfer or otherwise make available your Personal Information to such third parties for the purpose of enabling such parties to provide certain services on our behalf. Our service providers are given the information they need solely for the purpose of performing their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes. For example, we may use service providers to host our platform, deliver assessments, operate certain Website features, send email or other communications, and manage and analyze data.

Sale of Business: We may transfer your Personal Information as an asset in connection with any contemplated or actual sale, merger or other disposal of all or part of our business or assets, or as part of a corporate reorganization or other change in corporate control, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In such circumstances, we will ensure that any transfer of Personal Information is subject to applicable law and reasonable data protection security protocols.

Lakehead University: Greenspace will provide statistics and reports to Lakehead University on its program operations. These reports will only use de-identified and/or aggregate data and will not contain personal information.

Other than as required or allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), without your consent your Personal Information will not be used or disclosed for any purpose or to any person not described in this Privacy Policy.

Processing, Retention and Storage of Personal Information

We will retain your Personal Information for only so long as is necessary to fulfil the purposes for which it was collected, and for such periods of time as may be required to comply with applicable law.

When your Personal Information is no longer required or at the direction of Lakehead University, we will make all reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed and irreversibly deleted from our systems. However, where your information has been provided to third parties for the purposes described above, they may retain the information according to their own retention policies.

Safeguarding Your Information

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control to protect against theft, loss and unauthorized access, use, modification and disclosure. Despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings.

Our Website may provide links or references to websites, mobile applications or other platforms operated by third parties. These third party platforms are not governed by this Privacy Policy but by other privacy policies that may differ from our Privacy Policy. This Privacy Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party platforms, whether linked to this Platform or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party platform or any content on such platform. We encourage you to review the privacy policies of each platform visited before using them or disclosing any Personal Information to third parties.

Accessing Your Personal Information

You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law.

You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We will respond to requests within 30 days. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Policy we will revise the “Last Updated” date at the top of the policy. You should check back here periodically to find out if any changes have been made to this Privacy Policy. If we make substantial changes we will, as appropriate prominently post these changes to our Website or notify registered Users directly.

If you disagree with any change to the Privacy Policy, you may close your Account and refrain from using the Services. Continuing to use our Services after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.

Contact Us

Please contact our Privacy Officer if:

• you have any questions or comments about this Privacy Policy,
• you wish to access, update or correct inaccuracies in your personal information, or
• you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

You may contact our Privacy Officer at support@greenspacehealth.com.