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
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
||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
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
Report and optimize user experience based on demographic data
Year of birth, gender identity, province/territory/community, race
This information is only collected if you choose to provide it to
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
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;
Your consent and to comply with our obligations to inform you about
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
Your phone number is only collected if you choose to
provide so that you can receive self-assessment reminders by SMS
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
This information is automatically collected when you use the
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
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
- 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
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
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
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
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).
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
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 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.
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.
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
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;
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
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.
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
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
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
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
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.