MindShift CBT Privacy Policy

The Anxiety Canada Association is committed to protecting and respecting your privacy in connection with your use of our MindShift resources, including the MindShift app and, where applicable, the MindShift cognitive behavior therapy (CBT) Group (collectively “Mindshift”). Applicable privacy laws, including British Columbia’s Personal Information Protection Act and the federal Personal Information Protection and Electronic Documents Act, set out rules for the collection, use, disclosure, security, retention and destruction of personal information.

This privacy policy is intended to outline how we handle any personal information we collect from you, or that you provide to us, in connection with MindShift. Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information. This privacy policy forms a part of and is incorporated into the Terms of Use for MindShift.  

Anxiety Canada reserves the right to change or update this privacy policy and will notify users by posting any updates. Any changes or updates will be effective immediately upon posting to www.anxietycanada.com. Your continued use of MindShift constitutes your agreement to abide by the privacy policy as changed. We may also elect to notify you of changes or updates to this policy by additional means, such as pop-up or push notifications within MindShift or email.

1. Information We Collect

Anxiety Canada is committed to limiting our collection of your personal information to only the information that is necessary to fulfil the reasonable purposes that we identify to you at or before the time of collection. These purposes are also summarized at sections 7 (Uses Made of the Information) and 8 (Disclosure of Your Information) of this privacy policy.

We may collect and process the following information about you:

• Personal information including, for example, your name, e-mail address, telephone, location, information about your usage of MindShift and information collected by tracking technologies as further described below that may identify you as an individual or allow online or offline contact with you as an individual.
• Device Information such as operating system version, device type, and system performance information.

If you apply to become a participant in our MindShift CBT Group, we will also collect personal information, including information about the nature and severity of your anxiety symptoms, directly from you for the following purposes:
o To assess whether the MindShift CBT Group is an appropriate form of treatment for you;
o If you are a minor, to determine whether you are able to consent on your own behalf to participate in the MindShift CBT Group, or whether consent from your parent/guardian is required;
o To enable you to participate in the MindShift CBT Group sessions via online webinar, where it is anticipated that all Group members will share personal details amongst themselves and the Group facilitators for the purpose of fully engaging in the Group therapy sessions; and
o To assess post-treatment the relative success (or not) of your treatment as compared to the symptoms you were experiencing and how you were coping with them pre-treatment.

2. Confidentiality and Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information you submit to us. We use strict internal procedures and technical security features to try to prevent unauthorized access, use or disclosure of your personal information.  If you have any questions about the security of your personal information, you can contact us at [email protected]

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to MindShift; any transmission is at your own risk.

In addition, ensuring the security and confidentiality of your personal information, and the personal information of others if you are participating in a MindShift CBT Group, is a responsibility that we share with you. Your use of the MindShift app and participation in MindShift CBT Group webinar sessions should take place in an appropriately private space to ensure that neither you nor, in the case of the MindShift CBT Group, other Group members can be seen or overheard.  

3. Protecting Your Password

Where we have given you (or where you have chosen) a password which enables you to access certain parts of MindShift, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and suggest that your change your password frequently. If you have enabled your device to access the app without entering a password, you are also responsible for ensuring your personal information is protected by not allowing others to use your device without your permission.

4. Email Communication

If you sign up to receive promotional materials from us via email, we will use the information you give us to provide the communications you requested.

If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us [email protected], we will remove you from our mailing list.

5. Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often you engage with MindShift, the events that occur within MindShift, aggregated usage and performance data, and where MindShift was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.  The reasons we collect this data include: to understand which parts of the app consumers are using or not using, to be able to understand level of engagement with the app and areas that require improvement or change.  As a charity, we provide aggregated and anonymized data to report out to sponsors and/or donors.

6. Where We Store Your Personal Information

All information you provide to us through MindShift is stored on secure servers located in Canada. In using MindShift, you are deemed to acknowledge and agree that we may access and store your personal information in Canada for the purposes set out in this privacy policy and the Terms of Use.  As a result, your personal information will be subject to the laws of Canada.

7. Uses Made of the Information

We use information held about you in the following ways:

• To ensure that content provided by MindShift is presented in the most effective manner for your mobile device.
• To provide you with information related to MindShift that will facilitate your engagement with the MindShift.
• To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law.
• To carry out our obligations arising from any agreements entered into between you and us.
• To allow you to participate in interactive features of MindShift, when you choose to do so.
• To notify you about changes to MindShift.
• To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as postal code, province or country).
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

8. Disclosure of Your Information

We do not generally disclose your personal information.  We do not provide your personal information to any third party without your specific consent, except as permitted or required by law.  For example, we may disclose your personal information to third parties as follows:

• If MindShift’s service providers (like hosting or market analytics) require this information to provide services to Anxiety Canada. Anxiety Canada requires each of its service providers to agree to maintain the confidentiality and security of your personal information to our standards.
• If MindShift or substantially all of our assets are acquired by a third party, in which case personal information held by us about our users may be transferred.
• If we are under a legal duty to disclose or share your personal information in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of MindShift, our customers, or others.

If, in the context of applying to participate, or participating in the MindShift CBT Group you disclose the type of information specifically identified on the MindShift CBT Group Participant Acknowledgement, in which case we may have a legal and/or ethical obligation to disclose some of that information to the appropriate authorities, the court and/or your parent/guardian.

9. Accuracy and Correction of Information

We make reasonable efforts to ensure that your personal information that we collect, use and disclose in accordance with this Policy is accurate and complete. We need your help to accomplish this. Given that in the vast majority of cases we will collect your personal information directly from you, we rely on you to provide us with accurate information, and to update that information as and when needed.

Whether or not we have collected your personal information directly from you, you have the right to request access to that information and to request that we correct any errors in or omissions from that information. If your request for correction is reasonable, and subject to any legal obligations we might have that require us not to correct the information (e.g. we cannot correct a healthcare professional’s clinical opinions), we will correct the information. Where appropriate, we will also send the corrected information to any organizations to which we have disclosed your personal information during the year prior to your correction request. If your request for correction is not reasonable, or cannot be granted for any other reason, we will nevertheless include a note in the file where the information is held to show that a request for correction was made, but not implemented.

10. Limited Retention of Information

Generally speaking, we will retain the personal information we collect from or about you only for so long as we require it to satisfy the purposes for which we collected the information. We will also retain your personal information for as long as is required to meet our various legal and business obligations, which in some cases might be for a longer period than is necessary to satisfy the purposes for collection.

In particular, if we use any of your personal information to make a decision that directly affects you (e.g. to decide whether you are eligible to participate in a MindShift CBT Group), we are legally required to retain that information for at least one year after the date we use the information to make the decision. This is for the purpose of giving you time to request access to your personal information.

Once there is no longer a legal requirement or business purpose to retain your personal information we will securely delete, destroy or anonymize it.  

9. Contact us with Questions

If you have any questions or concerns about your personal information or privacy, or if you would like to request access to or correction of your personal information that we hold, you can contact us at [email protected]

 

Updated: December 11, 2019