Privacy Policy (Patient)

Pursuant to an arrangement with Family Service Kent, Greenspace Mental Health (the “Company”) has made available a platform that facilitates the measurement of patient progress and outcomes and displays such information to you, the patient, and to your health care provider(s). We know you are entrusting us with some of your most personal and valuable information and your privacy is extremely important to us. We are committed to protecting your privacy and safeguarding your personal information.

The purpose of this Patient Privacy Policy is to set out the manner in which the Company collects, uses, discloses and otherwise manages personal information. This Privacy Policy applies to the privacy practices at fskent.portal.gs (“Website”) and offline collection points. This Patient Privacy Policy describes our personal information practices for users of the platform. For additional information regarding privacy practices, including on our website, please see the Website Privacy Policy. Please note that as a patient receiving mental health services from a health care provider, you may receive additional information regarding access, use and disclosure of your personal information from your health care provider.

If you have any questions or concerns regarding this Privacy Policy, please don't hesitate to contact us.

How We Collect and Use Your Personal Information

Below is a summary of the ways we collect and use your personal information:

Registering for Patient Measurement: When you sign-up for patient measurement, we may collect personal information, including your name, email address, phone number, gender, occupation and therapy history. We use this information to connect you with your health care provider and provide you with personalized assessments, as requested by your health care provider.

Delivery of Assessments: We use your name, email address, phone number, as set by your preferences in your user account, to send you a link to your personalized assessment.

Completing Personalized Assessments: We collect personal health information such as responses to assessment questions and quantitative assessment scores when you respond to a personalized assessment delivered by the Company. We use this information to provide you and your health care provider with a display of your assessment responses and a presentation of your or your child’s progress, as applicable.

Data Analytics: We use non-identifying and aggregated information we receive from your responses to the assessments, your feedback on the platform and services and the frequency with which you use the platform and services for certain purposes, including: (i) to improve our platform and services; (ii) to publish data and/or information regarding the Company’s services through various media platforms and academic journals; (iii) for marketing purposes; (iv) for distribution to industry stakeholders and association; (iv) in relation to a research study at the University of Toronto; and (v) to match individuals with health care providers. We will not share anything that could be used to identify you or your personal information.

Interacting With You: When you contact us with a comment, question or complaint, you may be asked for information that identifies you such as your name, address, email address and a telephone number along with any additional information we may need to promptly answer your question or respond to your comment or complaint. We use this information to respond to your inquiry and improve our service offerings. We may also use personal information to establish and manage our relationship with you and provide quality service.

Sharing of Personal Information

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein.

Service Provider Arrangements: In order to provide the services available on the Greenspace platform, we have arrangements with certain necessary service providers that are subject to contractual agreements that include appropriate privacy standards. We may transfer (or otherwise make available) your personal information to such affiliates and other third parties for the purpose of enabling such parties to provide certain services on our behalf. Our service providers are given the 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, we may use service providers to authorize and process payments, host our platform, deliver assessments, operate certain of its features, send email or other communications, and manage and analyze data.

Sale of Business: In the event of a sale of the business, the use of your personal information by the new entity would continue to be governed by this Patient Privacy Policy and limited by applicable law. Personal information may be provided to a potential acquiror in connection with a merger or sale involving all or part of the Company (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Legal, Compliance and Loss Prevention: The Company, its affiliates and its Canadian, US and other foreign service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

Safeguards and Retention

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control to protect against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to your personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

Access to Your Personal Information

You have the right to access, update and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law.

You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. We will post the updated Privacy Policy on our Website.

Contact Us

Please contact our Privacy Officer if:

• you have any questions or comments about this Privacy Policy,
• you wish to access, update or correct inaccuracies in your personal information, or
• you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

You may contact our Privacy Officer at support@greenspacehealth.com or by mail at the following address:

156 Front St. W., Unit 610
Toronto, ON
M5J 2L6

Last Update: April 13, 2019