Privacy Policy

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1. Introduction

   1. This privacy policy (this “Privacy Policy”) is intended to inform you of our policies, procedures, and practices regarding the collection, use, and disclosure of any personal information that you provide to Wellin5 Innovations Inc. and/or its affiliates (collectively, “Wellin5”, “we”, or “us”) or through the Wellin5 software platform (the “Wellin5 Platform”). The Privacy Policy is part of our Terms and Conditions for Users, which can be found on our website at Terms and Conditions for Users, and our Terms and Conditions for Service Providers. Capitalized terms used in this Privacy Policy but not otherwise defined herein (such as “Service Provider”, “User”, or “Services”) have the same meanings as defined in our Terms and Conditions for Users and/or our Terms and Conditions for Service Providers. When you use the Wellin5 Platform you accept and agree to
      both the applicable Terms and Conditions (User or Service Provider, as the case may be) and to this Privacy Policy. If you do not
      agree to be bound to this Privacy Policy you should stop using the Wellin5 Platform immediately. By accessing and using the Wellin5 Platform you affirm that you have read the applicable Terms and Conditions and the Privacy Policy and that you understand, acknowledge, and agree to be bound by the terms contained in therein.

2. Collection and use of Personal Information

   1. When you use the Wellin5 Platform, update your account details, provide your billing information, provide your emergency contact information, or otherwise provide information to Wellin5, we may ask you for information that could be reasonably used to directly or indirectly identify you (“Personal Information”). Personal Information may include, but not be limited to, your name, your email, your phone number, and your address. We may collect and use Personal Information, either by itself or in conjunction with other information, for the following purposes:
      
      • (a) To create your account on the Wellin5 Platform, let you login into that account, administer your account, monitor your account, provide customer service and contact you with information, alerts, notifications, and suggestions that are related to your account;
      • (b) To facilitate the provision of the Services to you through the Wellin5 Platform, including by disclosing Personal Information to Service Providers;
      • (c) To allow a User or Service Provider, as applicable, to communicate with you effectively using the Wellin5 Platform;
      • (d) If you are a Service Provider, to let a User know you are licensed and qualified to provide the Services;
      • (e) For billing-related purposes;
      • (f) To contact you, either ourselves or using the appropriate authorities, if either Wellin5 or a Service Provider has a good reason to believe that you or any other person may be in danger or may be either the cause of or the victim of a criminal act; and
      • (g) Any other purposes for the collection and use of Personal Information that Wellin5 may determine, in its sole discretion, from time to time and as such shall be posted on this Privacy Policy prior to or at the time such changes take effect.
   2. Wellin5 may request information from Users about their needs, and from Service Providers, about your credentials, the Services, and related information (collectively, “Profile Information”). Profile Information provided by Users may be shared with Service Providers, and Profile Information provided by Service Providers may be shared with Users or otherwise posted on the Wellin5 Platform.
   3. Wellin5 may collect and analyze statistical or aggregated information about Service Providers and Users which is not personally identifiable and does not contain Personal Information.
   4. When you use the Wellin5 Platform, Wellin5’s servers or servers of third party services automatically record information that your browser sends (“Log Data”). This Log Data may include, but not be limited to, information such as your computer, Internet Protocol address, pages that you visit and the time spent on those pages, actions that you take and other statistics. We may use this information, either by itself or in conjunction with other information to monitor, analyze, and improve the use and functionality of the Wellin5 Platform and its technical operations.
   5. While using the Wellin5 Platform, Users may write or communicate by means of text-based communication, verbal communication, or video communication, either internally or to each other (collectively “Session Content”). The Session Content is shared with the Service Provider(s) that may work with you from time to time. The Session Content may be used, either by itself or in conjunction with other information, to (a) enable a Service Provider to provide Services to a User; (b) supervise, administer, and monitor the Services provided by a Service Provider; and/or (c) provide a means for professional supervision by qualified professionals for or on behalf of the Service Provider.
   6. Like many websites, Wellin5 uses “cookies” and “web beacons” to collect information. A “cookie” is a small data file that is being transferred to your computer’s hard disk for record-keeping purposes. A “web beacon” is a tiny image, placed on a Web page or e-mail that can report your visit or use. We use cookies and web beacons to enable the technical operation of the Wellin5 Platform, to administer your log-in to your account and to collect the Log Data. You can change your browser settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies you may not be able to use the Wellin5 Platform. The Wellin5 Platform may also include the use of cookies and web beacons of services owned or provided by third parties that are not covered by our privacy policy and we do not have access to or control over these cookies and web beacons.
   7. Wellin5 may share aggregated information that does not include any Personal Information with third parties for any purpose, including but not limited to industry analysis, research, business transactions, and public relations.
   8. The Wellin5 Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.
   9. Wellin5 may sell or transfer some or all of its assets, including your Personal Information, in connection with a merger, acquisition, consolidation, joint venture, reorganization or sale of assets. Any Personal Information sold or transferred pursuant to such an arrangement will be required to be protected by the purchaser or transferee on the same terms and conditions as described in this Privacy Policy and in accordance with applicable laws.
   10. We may employ third party companies and individuals to facilitate our Platform, to perform certain tasks which are related to the Platform or to provide audit, legal, operational or other services for us. These tasks include, but are not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We may transfer information, including Personal Information, to such third parties who may be located outside of your jurisdiction, in accordance with paragraph 2.12 of this Privacy Policy. When needed we may disclose information, including Personal Information, to such third parties but we will try to limit the Personal Information disclosed to the minimum necessary for such third party to perform their task.
   11. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become Users without parental guardian consent. The Wellin5 Platform is not directed at nor intended to be used by children under the age of 13 without parental guardian consent. If you are or become aware that we have collected Personal Information from a child under age 13 without parental guardian consent, please let us know by contacting Wellin5 immediately.
   12. All electronic data collected and stored by Wellin5 is stored on servers located in Canada. However, such electronic data, including Personal Information may be accessed by, or transmitted to, representatives of Wellin5 or its affiliates, Service Providers or other third party service providers, who are located in the United States. Any Personal Information so accessed or transferred will only be used by representatives of Wellin5 or its affiliates, Service Providers or other third party service providers for the purposes for which it was originally collected from you. Any Personal Information so accessed from or transmitted to the United States may be accessed by the courts, law enforcement agencies, regulators and national security authorities of the United States in accordance with the laws applicable in the United States. Your consent to this Privacy Policy followed by your submission of such Personal Information represents your consent to such transfers.
   13. Wellin5 will cooperate with government and law enforcement officials and private parties. Notwithstanding any other term in this Privacy Policy, we may disclose any information, including Personal Information, to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process to protect the property and rights of ourselves or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity and we may disclose information, including Personal Information, to take precautions against liability.
   14. Users should also be aware that Service Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, Users should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; or (c) threatened harm to another person.
   15. You may review, update, correct, or delete your Personal Information by contacting us or by editing that Personal Information on the Wellin5 Platform. If you would like us to delete your Personal Information or any other information from our system, please contact us with such request at privacy@wellin5.com. Wellin5 may retain an archived copy of your records as required by law or for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, including, without limitation, some data that may be still archived and stored offline. Wellin5 is not responsible for removing information from the third parties with which we have already legitimately shared your Personal Information.
   16. Wellin5 is concerned with safeguarding your information. The security of your Personal Information is very important to us. Therefore, Wellin5 employs measures to protect this information from unauthorized access, use, and disclosure. However, the confidentiality of any communication transmitted through the Wellin5 Platform and/or stored with Wellin5 cannot be guaranteed. Please remember that no method of electronic transmission over the Internet or method of storage can be completely secure. You acknowledge and agree that you share and transmit any information, Personal Information or otherwise, at your own risk, as further detailed in our terms of use. If you have reason to believe that there has been a breach of security, including but limited to “hacking” of your account, you must notify us immediately at contact@wellin5.com
   17. We have implemented the following technical safeguards to ensure the protection and maintenance of the confidentiality of all User data. We use password-protected computer screensavers to prevent unauthorized access. We ensure that our systems, servers, and network computers are secure from intrusion by using firewalls, intrusion detection software, antivirus software, and by encrypting all personal information. We use strong and secure passwords to make sure that only authorized employees have access to computer storage devices or to the network. We change our passwords on a regular basis. and perform external audits to safe-test our systems. We also encrypt the transmission of our audio/video during live sessions to counter the security related problems of eavesdropping, data tampering, or message forgery. We encrypt personal as well as sensitive information stored on mobile electronic devices such as laptops and USB flash drives in line with PCI and PIPA standards. All
       User data is physically stored within Canada as per healthcare regulations.

3. User Data

   1. General Information We Collect
      
      • (a) When the User browses the Wellin5 Platform the following information is collected and stored: The IP (Internet Protocol) address of the User’s Internet Service Provider and the location of access or the User’s computer, which may also identify the domain name (such as shaw.ca or the yourcompany.com) from which the User is accessing the internet; times and dates of any visit; the web pages within the Wellin5 Platform and the time of User access (i.e. what session topics were most booked).
   2. What is this general information used for?
      
      • (a) We use this general information to analyze the use and performance of the Wellin5 Platform. It also enables us to improve the Wellin5 Platform, provide general industry trends and insights to help different industry leaders make better decisions in their employee wellness, evaluate our technical infrastructure, and monitor compliance with our User Terms. We do not use this information to identify the User unless required or forced to do so by law in order to investigate any criminal activity.
   3. Personal Identifiable Information
      
      • (a) For the user to sign up or create an account to access our services, we ask for th User’s first name, last name, email address, gender, date of birth, age, session history, if you are on any medication for mental health, any pre-existing diagnosed condition, self-harming behaviors, suicidal tendencies, or harming others. This information is to create and identify an individual account in our database and match you with the most appropriate/relevant Service Provider through keyword matching, previous session history as well as offer other tailored services, information and updates, based on the User’s demographics. Other information is collected to share with your Service Provider to provide client background before beginning your session.
      • (b) All of the provided information is only shared with our Service Providers in order to customize their approach while delivering service via our platform. It is kept strictly confidential and private unless we are forced to disclose it by law.
      • (c) All User information is stored on our encrypted secure servers but during sessions our Service Providers may take some notes offline to keep in their files to provide future services to the User. The Service Providers are required to keep the same standards for record-keeping, confidentiality and privacy as they would perform for an in-person practice.
   4. Information shared with your benefit provider
      
      • (a) If you are covering payments for any Services through your third party employee benefits package/insurance company, then we may share certain information only with your benefits provider/insurance company to process a claim as well as to know what Services were used. This information may include your first and last name, date of birth, name of employer, sex, session name, number of sessions, session date and time, Service Provider’s name, license, and/or other certification.
   5. Information shared with your employer
      
      • (a) As part of our Privacy Policy, we do not share any personal identifiable information about an individual employee but only share general statistical industry trends and information such as counselling preferences, major issues that need addressing in an industry workforce (i.e. burn out, stress levels, depression, anxiety, PTSD (Post Traumatic Stress Disorders) and/or any other relationship issues). This is only to inform and help employers make better decisions on improving the overall health of employees and customizing employee assistance programs (EAP).
      • (b) You understand that our goal is to help employers and other healthcare organizations reduce healthcare costs associated with issues such as productivity loss, sick leaves, return to work, and disability management as a result of Wellin5's services which offer reduced waiting times, ease of access, and confidential, stigma free access to online counselling.
   6. Information shared with a healthcare institution
      
      • (a) If your current physician or family doctor requests any notes on your counselling history with us, we will notify you to obtain your consent prior to releasing any information. All consents will be obtained in written form. In case of a medical or life threatening emergency, information may be shared at our discretion with the authorities.
   7. Financial information
      
      • (a) We collect User email, account name and session purchase history on our system to verify session payments as well as to investigate any cases where there may be suspicion or occurrence of any fraudulent activity or misuse of an account. We also maintain records of your session purchase history to offer you the best deals and discounts in the future.
      • (b) For any payments, we use Payfirma to process credit cards, bank accounts, and other payment information. Once a Client decides to subscribe, pay, or choose a session plan on Wellin5, the Client is taken to the Payfirma payment page integrated within our system where the Client can use their credit card through quick check out to complete the payment for the selected session. In order to process your payment, Payfirma may store and collect your financial information for future purchases. You agree that any third-party payment service provider such as Payfirma has their own privacy policy. For any information or clarification you can contact Payfirma directly. We are not liable or responsible for any miscalculations, stolen data, or glitches within the Payfirma payment system.
   8. Personally covering your costs
      
      • (a) If you make payments for a selected service and session directly using your credit card via Payfirma none of your payment information will be disclosed to prospective employers or healthcare facilities unless you request us to do so, or if such disclosure is required by law.
   9. No recording of sessions
      
      • (a) At Wellin5, we are committed to providing the same level of confidentiality and privacy as the User would expect while seeing a Service Provider in-person. We do not record or share any of the live sessions that occur on our platform. All data which is transmitted between user and Service Provider while streaming of audio/video during the sessions is encrypted .
   10. Retention of user information
       
       • (a) Wellin5 deletes all personal information related with the User account instantly when a User has cancelled/closed their account with the exception of some general User information. For example, we do not retain any User information such as first name, last name, email address, gender, date of birth, and age after the User has cancelled/closed their account. Our Service Providers that are engaged in counselling may be required to keep any collected offline information pertaining to counselling according to the laws of their respective jurisdiction(s).
   11. Protection of user information
       
       • (a) We offer the use of a secure server. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology of 256 bits and then encrypted into our database to be accessed only by authorized personnel on a need-to-know basis. We also utilize industry best practices such as the use of firewall and anti-virus software to keep everything safe. Additionally, our audio/video transmitting/streaming is encrypted and does not retain any user data during any sessions.
   12. Disclosure of information to third parties
       
       • (a) We do not sell or trade the User’s personally identifiable information. From time to time, trusted third parties who assist us in operating the Wellin5 Platform and conducting our business may have access to the User’s general statistical information only after signing a confidentiality agreement and meeting other security software requirements. This information may include the average age of our users, their general location, profession, preferences, and most popular sessions etc. We may also release information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
       • (b) Wellin5 will disclose personal information related to possible mental or physical health concerns of individuals to a third party if: a) the Service Provider believes that an individual is homicidal or suicidal; b) the Service Provider is concerned about possible child abuse or neglect; or c) the disclosure is ordered by law.
   13. Request to release information
       
       • (a) All interactions with Wellin5 Counselling Services, including scheduling of or attendance at appointments, content of your sessions, progress in counseling, and your records are kept confidential. Only with your written consent you may request in writing that your Service Provider release specific information about your counseling to persons/organizations you designate.
   14. Report of abuse & Compliance to court order
       
       • (a) Counsellors at Wellin5 reserve the right to disclose to the proper authorities and/or individuals and take action should they discover or strongly suspect physical, sexual, child abuse or neglect of any person under 18 years of age. Additionally, a court order or subpoena issued by a judge, may require the Service Providers to release information contained in records and/or require a therapist to testify in a court hearing.
   15. Confidentiality
       
       • (a) Wellin5 uses the following safeguards to protect and maintain the confidentiality of all User data physically, administratively, and technically.
       • (b) We have implemented the following safeguards to ensure the protection and maintenance of the confidentiality of all User data. Regular training of our employees on our internal privacy policy and PIPA. All employees enter into confidentiality agreements regarding access to a User’s personal information. Regular privacy audits are conducted to ensure employee compliance with privacy policies. Role-based access to systems so that employees are only able to access personal information which is needed to perform their duties.

Wellin5 may update this Privacy Policy at any time, and from time to time, in its sole discretion. The date of the last revision of this policy shall appear on the last page of this Privacy Policy. We encourage you to periodically review this page for the latest information on our Privacy Policy and on any related practices.

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by sending an email to our Privacy Officer at privacy@wellin5.com

Last updated: April 30, 2021

Client Terms

Counsellor Terms