MindShift CBT Privacy Policy

Last updated: October 13, 2021

 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 and Mindshift CBT Community (collectively “Mindshift”). Applicable privacy laws, including British Columbia’s Personal Information Protection Act and Canada’s federal Personal Information Protection and Electronic Documents Act, set out rules for the collection, use, disclosure, security, retention, and destruction of personal information.

Please read this privacy policy carefully as it describes our privacy practices and how we will collect, use, and disclose any personal information we collect from you, or that you provide to us, in connection with MindShift. This privacy policy forms a part of and is incorporated into the Terms of Use for Mindshift.

  1. Personal Information We Collect

We may collect and process the following personal information about you:

  • Information including, for example, your name, e-mail address, telephone, location, and information about your usage of MindShift.
  • Information included in submissions that you make to Mindshift CBT Community.
  • Information collected by tracking technologies, described below in Mobile Analytics, 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:

  • To assess whether the MindShift CBT Group is an appropriate form of treatment for you;
  • 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;
  • 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
  • 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.
  1. 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 or Mindshift CBT Community, is a responsibility that we share with you. Your use of MindShift and participation in MindShift CBT Group webinar sessions and Mindshift CBT Community should take place in an appropriately private space to ensure that neither you nor, in the case of the MindShift CBT Group and Mindshift CBT Community, other Group and Community members can be seen or overheard.

  1. 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.

You can unsubscribe at any time by selecting “unsubscribe” at the bottom of such communication or by emailing us at [email protected] and we will remove you from our mailing list.

  1. 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.  We collect this data to understand which parts of the app consumers are using or not using and to understand level of engagement with the app and areas that require improvement or change.  As a charity, we provide aggregated and anonymized data reports to sponsors and/or donors.

  1. Location of Personal Information

The personal information you provide to us through MindShift, MindShift CBT Groups and Mindshift CBT Community is stored on secure servers located in Canada.  In using MindShift, you 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.

  1. Protecting Your Password

Your password 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 you 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.

  1. Uses Made of Personal Information

We use information about you in the following ways:

  • To ensure that Mindshift content 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, where you have provided consent to receive such communications.
  • 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 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. Your participation in these surveys is entirely voluntary and will not impact your use of any of the Services or your relationship with Anxiety Canada.

  1. Third Party Websites

It’s important to guard your privacy online. If Mindshift contains links to other websites, this privacy policy does not govern those websites. Whether we have posted those links or other organizations, or individuals have, you should read their privacy notices and make an informed decision about whether you want to use those websites or their services.

  1. Disclosure of Your Personal Information

We do not generally disclose 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 us. Anxiety Canada requires 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 users, or others.
  • If, when 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.

You acknowledge and agree that Anxiety Canada cannot control and is not liable for the disclosure by MindShift CBT Group and Mindshift CBT Community members of personal information that you share with such members.

  1. Accuracy and Correction of Personal information

We make reasonable efforts to ensure that the personal information that we collect, use, and disclose in accordance with this privacy policy is accurate and complete. Where we 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.

You may request access to, make corrections to, or delete the personal information we hold about you at any time, subject to certain exceptions.

  1. Limited Retention of Personal Information

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 of the Mindshift CBT Community), we will retain that information for at least one year after the date we use the information to make the decision. This is so you have 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.

  1. Changes to this Privacy Policy

Anxiety Canada reserves the right to change or update this privacy policy. We will post the date of the most recent changes and provide previous versions upon request. 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. Questions and Complaints

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 our Privacy Officer at [email protected].

We will respond to complaints within 30 calendar days of receipt.

If we are unable to resolve your concern, you may also contact the Office of the Privacy Commissioner of Canada.