Privacy Policy

Legal Information

Last Updated: December 8, 2022

Wellness Together Canada Privacy Statement

This privacy statement explains how Wellness Together Canada (“WTC”) processes your personal information when you use the WTC website (the “Website”) or the PocketWell app (the “App”), collectively referred to as the “Platform”.

Collection and Use of Personal Information

The following table describes the personal information we collect, the purpose and lawful basis for processing it, and whether you can opt out of its processing.

Purpose/Activity	Type of information	Lawful basis for processing	Can you opt out?
Enable you to create a WTC account and access the Platform	Email address, password, security answer	Your consent. This information is collected when you create a WTC account and when you log in.	You can opt out of these activities, although you will only have access to the signed-out experience, which will limit access to some services.
Report and optimize user experience based on demographic data	Year of birth, gender identity, province/territory/community, race	Your consent. This information is only collected if you choose to provide it to WTC.	You are not required to provide this information, and can opt out of this activity.
Enable you to track your mood, well-being and functioning through self-assessment and mood meter	Self-assessment responses and scores	Your consent. This information is only collected if you decide to complete the self-assessment, and is only collected and maintained on the Platform for your own use. WTC does not use or disclose this information for any other purpose.	You are not required to complete the self-assessment and can opt out of this activity.
Communicate with you for various purposes, including: reminders to complete your self-assessment; requests to respond to surveys; updates about WTC, terms of use and the privacy statement.	Email address	Your consent and to comply with our obligations to inform you about updates to WTC, our terms of use and privacy statement. Your email address is collected when you create a WTC account.	You may opt out of most communications by configuring the preferences in your account. You cannot opt out of communications we are obligated to send.
Send you reminders to complete self-assessments	Phone Number	Your consent. Your phone number is only collected if you choose to provide so that you can receive self-assessment reminders by SMS text message.	You may opt out of receiving reminders by SMS text message.
Administer and protect WTC, including troubleshooting, data analysis and system testing	IP address, device information	This information is necessary to protect and ensure the Platform operate as intended. This information is collected when you access the Platform.	You cannot opt out of these activities, otherwise we will be unable to provide the services to you.
Analyze Website usage to identify trends, identify location of users, troubleshoot issues and make improvements.	IP address, device and browser type, referring website, website activity such as click rate and bounce rate	Your consent. This information is automatically collected when you use the Website.	You may opt out of some of these activities by following the instructions described in Analytics, Cookies and Other Technologies. You cannot opt out of the collection of web log files.

In accordance with the principle of data minimization, we only collect the personal information we actually need. We will only use your personal information for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal information for that purpose. We will inform you and obtain your express consent for any changes in the processing of your personal information if required.

We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not itself considered personal information if it is not reasonable to expect that you could be identified using that information alone or in combination with other available information. For example, we are required to provide reports to Health Canada about how the Platform is used. However, these reports only include only Aggregated Data that is not used to identify people. Identifiable information about individual users is not shared in the report.

In some circumstances, where permitted or required by law, we may process your personal information without your knowledge or consent. For example, we may be required to use your personal information to protect the security or availability of WTC, to protect or enforce our legal rights, or to protect the health and safety of individuals.

Disclosures of Personal Information

We keep your personal information confidential, unless you have asked us to share it, or we are required to by law, including the following circumstances:

If you choose to use the WTC “single sign-on” to access services from a service provider. We will share your email address only;
A lawful court demand has been made for details related to your use of the Platform;
To protect the security of the Platform; or
To protect the health or safety of individuals.

In each instance we will share the minimum amount of personal information required for the purpose.

As explained above, we are required to provide certain Aggregated Data to Health Canada. However, we do not share personal information with Health Canada.

WTC Service Providers

We use service providers to assist in delivering and supporting the WTC Platform. There are also several service providers who provide the mental health and substance use support services accessible through WTC.

Mental Health and Substance Use Support Providers

WTC provides access to self-guided tools, peer-to-peer support and coaching, and one-to-one counselling to promote and support mental health. WTC is not a health care provider. Some of the providers of self-guided tools, peer-to-peer support and coaching, and one-to-one counselling available through WTC may need to collect and use your personal information to provide services. For example, some providers may require you to create an account on their website. Other services, such as coaching, counselling, and crisis support require you to share more information about yourself.

When you use any of these providers, you form a direct relationship with the provider. These providers are accountable for the personal information they collect from you, and your use of their services is subject to those providers’ terms of use and privacy policies.

Certain providers, such as Breathing Room, WellTrack and TAO, may allow you to log on to their website using your WTC log on credentials to provide for a simpler, “single sign-on” experience. If you choose to use your WTC log on credentials to access those sites, WTC will share your email address with the provider. WTC does not share any other personal information with any of the service providers accessible through the WTC site.

Greenspace Mental Health

Greenspace Mental Health Ltd. (“Greenspace”) provides the technology that powers the Platform. As a service provider to WTC, Greenspace collects, manages, and protects personal information of WTC users on behalf of WTC, and Greenspace is only legally authorized to process your personal information to provide those services on behalf of WTC. Greenspace has legal obligations to secure your personal information through their contract with WTC. You can find details about how Greenspace meets these obligations in the Greenspace Terms of Use, Privacy Policy and Security Information Page. No transfer or assignment of your personal information to another company can occur without WTC consent.

Greenspace has arrangements with certain technology-related service providers who may process personal information on behalf of Greenspace in order to help deliver the Platform. These service providers are given access the least amount of 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, Greenspace may use service providers to host its platform, deliver assessments, operate certain Website or App features, send email or other communications, and manage and analyze data.

Other Service Providers

WTC uses other service providers who may also require access to your personal information. These providers may assist with such things as conducting surveys and research on how WTC is used, communicating with WTC users, and providing guidance on how to improve the services.

Analytics, Cookies and Other Technologies

Web log files, analytics tools, cookies, web beacons and similar technologies are used to deliver the Platform, remember user preferences and obtain information about how the Platform is used.

Web Log Files

Log files are automatically generated records of all visits to the Website that are used report on website trends and identify and troubleshoot issues. Log files include the following information:

The user’s operating system (example: iOS 12),
IP address,
The date and time,
Length of the website visit,
The pages and documents accessed, and
Previous site accessed (for example, the search engine that referred the user to the Website).

Analytics Tools

We use analytics tools, which means we use programs to help us identify patterns and make the Website better and troubleshoot technical issues if necessary. Some of the tools we use include Google Analytics, Hotjar, Pendo.io and Mixpanel. These tools help us to learn about how the Website and App are used in order to improve the website. These tools use cookies and similar technologies to collect certain information, which are listed below:

IP address,
Device or browser type, and
Activity on the Website such as click rates and bounce rates

This information is used to measure and report statistics about how users interact with the Website. The tools allow us to make reports and identify trends. We do not use this information to identify you.

Find out more information about analytic tools at the links below.

To stop these tools from collecting information follow these links.

Cookies

Cookies are small text files stored on your device that identify your IP address to our servers each time you visit the Website.

You can control which cookies are set on your device. You can turn off cookies through your internet browser. To turn off cookies follow the instructions found in “Help,” “Tools” or “Edit” menus in your internet browser. Note our Website depends on the use of certain cookies. If you choose to turn off all cookies you may not be able to use some features of the Website.

Other Tools

We also use pixel tags, web beacons, clear GIFs or similar tools to run or manage some of our Website pages and HTML-formatted email messages. These tools do the following:

Track the actions of users and email recipients,
Measure the success of marketing campaigns, and
Compile statistics about Website usage and email response rates.

Security

We, and Greenspace, use reasonable administrative, technical and physical safeguards to protect personal information against theft, loss, and unauthorized access, use, modification and disclosure. This includes the following measures:

Data is encrypted at rest and in transit with at least AES 256-bit encryption. Transport Layer Security (TLS) 1.2 or higher is used for information transmitted over the internet;
Employee access to data is logged and restricted on a need-to-know basis; and
Network monitoring and intrusion detection are used to prevent unauthorized access to systems containing personal information.

Greenspace has also been certified as Service Operational Control (SOC) 2 Type II compliant.

Despite our efforts, no safeguards can eliminate all security risks. Please take the following steps to help secure your personal information:

Install the latest security updates and anti-virus software on your device to help prevent malware and viruses;
Make sure your browser is up to date;
Use complex passwords to lock your device and mobile applications;
Do not use the same password for multiple sites;
Never share your password with others; and
Enable 2-step verification in your account.

Data Retention

We will retain your personal information for only as long as necessary to fulfil the purposes for which it was collected, and as may be required to comply with applicable law. When your personal information is no longer required, we will make reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed and irreversibly deleted from our systems in accordance with industry standards. However, if your information has been disclosed to third parties for the purposes described above, they may retain the information according to their own retention policies.

Storage of Personal Information

Most of the information processed on the Platform is stored on secure servers in Canada provided by Amazon Web Services (AWS). Most of your personal information, including your profile and self-assessment results, is therefore stored in Canada. However, some service providers who assist in providing the Platform may process certain personal information, but never information related to the state of your mental health and personal quality of life, outside of Canada, and, as a result, your personal information may be subject to the laws of those jurisdictions and could be accessible without notice to you by the courts, law enforcement and national security authorities of those jurisdictions.

Accessing Your Personal Information

Most of the personal information we have about you can be accessed in your WTC account, either on the Website or the App. You also have the ability to edit personal information in your account. However, if you believe we have personal information not available in your account, and would like to request access or make corrections to that personal information please contact the WTC Privacy Office.

Deleting Your Account

You may delete your WTC account at any time. To delete your account please contact the WTC Privacy Office. The following will happen when you delete your account.

We may ask for personal information to verify who you are before deleting an account.
We will make sure that all electronic and hard copies of your information are securely destroyed. This means your personal information is permanently deleted from our live systems as soon as possible.

Sometimes we have legal obligations that require us to keep some of your personal information. We would only keep your personal information for as long as necessary. Note that WTC does not manage any personal information collected by mental health service providers. If you want to delete all your information you will have to connect with each service provider you have used.

Changes to this Privacy Statement

We may update this Privacy Statement at any time. We will notify you by email of any material updates.

For Further Information

If you have any complaints or questions about this Privacy Statement or our personal information handling practices, please contact the WTC Privacy Office.