Effective date: May 20, 2020
Snapclarity (“us”, “we”, or “our”) operates the snapclarity.com mobile application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service is the snapclarity.com mobile application operated by Snapclarity
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, City, State/Province, ZIP/Postal code
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
In the course of using the Services (excluding Therapy Services), You may provide certain information, data and material through the Services (the “Your Data”). You agree that Your Data will: (i) comply with all applicable laws; (ii) not contain infringing, obscene, threatening, libelous, or other illegal material and does not violate, infringe, or misappropriate other people’s intellectual property, privacy, publicity, or other legal rights; (iii) not include material containing software viruses, worms, Trojan horses or other harmful computer codes, files scripts or programs designed to interrupt, destroy, or limit the functionality of any computer software or hardware telecommunications equipment; and (iv) not contain any content, work, name, logo or mark that infringes any intellectual property right of any person.
We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Provider working with local authorities). Generally, we will only use your information within our company. However, sometimes we use third parties to process your information (for example as credit card payment providers). We will require these third parties to comply strictly with its instructions and we will require that they not use your personal information for their own business purposes snaclarity stores data only for as long as it is necessary to provide products and services to you and others, including those described above and for legal protections or as required by applicable laws and regulations. Snapclarity may allow service providers to access information so they can help us provide services.
The Snapclarity Platform advises both its Client/Users and practicing Platform Providers to be aware of and respect and comply with the local laws of any international based Client. Snapclarity is cognizant and respects the formal promulgation of the existing European Union (EU) data privacy regulations. The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the export of personal data outside the EU and EEA and is commonly referred to as “GDPR.” Snapclarity has always respected our Client’s Privacy, and we were already a HIPAA certified platform following stringent data privacy rules. The basic tenants of the promulgated GDPR regulations include, but are not limited to the following:
- Access to collected data: At Snapclarity, you already have the ability to access your shared data (Your personal information, your emergency contact information and all your interactions with your Providers) and use it as you wish.
- Security: At Snapclarity, we have encrypted our data from day one and has always been stored all Private Health Information with full HIPAA compliance and in an anonymized form as required by the GDPR.
- Notice/Audit: At Snapclarity, we will provide our Clients notice of any data breach, and we employ a full-time security Officer, as well as engaging a third-party security firm to periodically audit both or code and technology security as well as our HIPAA /PHIPPA policies and procedures around data security.
Finally, dependent of your EU country of origin, the GDPR takes into account what has previously termed the right “to forget” or request deletion of your data once you cease using a particular application or site. This particular tenant of the GDPR may conflict with applicable medical records retention laws. In the United States and Canada, this requires at least seven years of retention, which is common around the world and is sometimes up to ten years or more in certain countries. So, unlike some data platforms, snapclarity cannot erase private health data directly upon a Client’s request, as it may be considered essential for other medical file retention purposes. Applicable individual country medical retention laws are generally considered an acceptable exception to the GDPR regulations regarding the right to deletion of specific data.
We may transfer or disclose personal information as follows:
- Circle of Care: If you access the Platform or receive Services, your personal information may be disclosed to and among Counsellors and Support Staff to provide or assist in the provision of Services to you. Your personal information may be provided to third parties such as other health professionals, specialists, consultants or pharmacists, pharmacies and laboratories to provide or assist in the provision of Services to you, with your prior written consent. Service Provider Arrangements: In connection with the provision of our Platform and Services, we may disclose (or otherwise make available) personal information to third parties who provide Services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Personal information may be maintained and handled by third party service providers in Canada and the United States and may be accessed by the courts, law enforcement, and national security authorities as required under the laws of this jurisdiction. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below.
- Sale of Business: Snapclarity may transfer personal information as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Snapclarity or as part of a corporate reorganization or other change in corporate control.
- Legal: Snapclarity and our affiliates and service providers may disclose personal information to third parties as required or permitted by applicable law. For greater certainty, Snapclarity will disclose your personal information to the extent that it is legally required or necessary for the establishment, exercise or defence of legal claims and legal process; or in the event of an emergency about your health and safety or that of a Counsellor. Where a disclosure of our clients’ information is required by applicable law, we promptly notify our client prior to complying with such requirements (to the extent we are not prohibited from doing so). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking & Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
Snapclarity uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
Snapclarity may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data
Snapclarity will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Canada or the USA and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Snapclarity may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Snapclarity may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Snapclarity
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area – European Free Trade Association (EEA EFTA), you have certain data protection rights. Snapclarity aims to take reasonable steps to allow you to
correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Snapclarity relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area – European Free Trade Association (EEA EFTA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service- related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page: https://policies.google.com/privacy? hl=en
Firebase is an analytics service provided by Google Inc.
We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/60042
For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy? hl=en
Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy? hl=en
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest- based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest- based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self- Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
- By visiting this page on our website: