Last Updated: March 7, 2018
TABLE OF CONTENTS
- Collection and use of Personal Information
- Disclosure of Personal Information
- Security of Personal Information
- Retention of Personal Information
- Access to Personal Information
- Contact Us
COLLECTION AND USE OF PERSONAL INFORMATION
Information we collect from Clients:
Account creation and profile: In order to access and use the Services, clients are required to create a Snapclarity account. We collect your email address, password, full name, mobile phone number, and date of birth/age verification in order for you to create an account with us. We use this information to administer your account and verify your age. If you are under the age of 16 we require permission from your parent or legal guardian in order to create an account or use paid features on the Services. We collect and use the name and email address of your parent or legal guardian for this purpose. We may also collect additional information such as your gender, profession and employment status if you choose to provide this information on your account profile that is accessible to your matched therapist(s).
Payment information: While certain features on the Services are free (such as the assessment questionnaire and assessment summary), clients are required to pay a monthly membership fee for access to text therapy services. We collect your payment-card details (including payment card number, security code, expiration date, cardholder name and billing address) for the purposes of processing your membership payments. If you chose to schedule additional video or phone sessions with your therapist through Snapclarity, we also collect and use your payment information to facilitate payment to your therapist.
Assessment questionnaire: In order to connect you with a therapist that matches your personal needs, we collect your responses to a mental health assessment and provide you with an assessment summary. This assessment summary is not a diagnostic tool or medical advice. It is only used by Snapclarity for the purposes of matching you with an appropriate therapist. Once matched with a therapist, we will provide your therapist with a copy of your assessment summary.
Text messages and live audio or video sessions: With your permission, our Services may enable your therapist to record video and audio, access your calendar for the purposes of providing text therapy and/or live audio or video sessions. We use a third-party service provider to facilitate the text messages and maintain a record of the text communications between you and your therapist for a limited period of time to enable your therapist to create their own clinical records. These communications are stored solely on behalf of your therapist and we and our service provider do not access or use them for any other purpose.
If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with appointment reminders and other relevant notifications. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.
Information we collect from Therapists:
Therapist registration: We collect information from therapists including email address, password, full name, phone number, college of accreditation, license number, clinical supervisor (if available) and areas of competencies for the purposes of registering the therapist in our online system, verifying accreditation and creating an account profile that is accessible to clients.
Payment information: We collect payment-card details from therapists (including payment card number, security code, expiration date, cardholder name, billing address and social insurance number) to process subscription payments. We also collect mailing address, date of birth, and bank account information to process and deposit payments received from clients on behalf of therapists.
Text messages: Our service provider maintains a record of the text communications between you and your client for a limited period of time for the sole purpose of enabling you to create your own clinical records. We store these communications solely on your behalf and do not access or use them for any other purpose.
Additional information we collect:
Inquiries: If you contact us with an inquiry, you may be asked for information that identifies you, such as your name, address and a telephone number, along with additional information we need to help us promptly answer your inquiry. We may retain this information to assist you in the future and to improve our customer service and service offerings.
Job Applications: If you apply for a job at Snapclarity, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purposes of processing and responding to your application and assessing your suitability for current and future career opportunities.
Feedback: We may publish your feedback, excluding your personal information, on our Website or other promotional materials. We shall be the sole and exclusive owners, in accordance with our Terms and Conditions, of any intellectual property rights that may subsist in the feedback, including, without limitation, any suggestions of new features, functionality, or performance, or any improvements on the existing features, functionality, or performance, for the Platform or App, whether or not they are subsequently incorporated into the Platform or App by Snapclarity and/or its suppliers or licensors.
Surveys and Customer Research: From time to time, we may offer you an opportunity to participate in one of our surveys or other customer research. The information obtained is used in an aggregated, non-personally identifiable form. We use this information to help us understand our clients and therapists and to enhance our product and service offerings.
Marketing Communications: We may offer the ability for you to sign-up to receive our newsletter and other promotional communications, in which case we collect your name and email address to send you the communications you have requested to receive. You can opt-out of receiving promotional email from us by following the opt-out or “unsubscribe” instructions provided in your email, or by contacting us as set out below. Please note that you will continue to receive transactional and account-related electronic messages from us. We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please send an email to privacy@Snapclarity.com
DISCLOSURE OF PERSONAL INFORMATION
Snapclarity does not disclose, trade, rent, sell or otherwise transfer personal information without consent, except as set out below.
Service Providers: In connection with our Website and Services, we may transfer (or otherwise make available) personal information to third parties who provide services on our behalf. For example, we may use service providers to host our Website or App, store data and provide back-up services (including cloud-based service providers), process payments, facilitate text message communications between clients and therapists, or provide data analytics services. Personal information may be maintained and processed by Snapclarity or our third party service providers in the US, Canada or other jurisdictions. 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: We may transfer personal information as an asset in connection with a prospective or completed 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 Canadian, US and other service providers and affiliates may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case 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.
Where we receive a request for personal information that we maintain on behalf of a therapist, we promptly notify the therapist prior to complying with such requirements (to the extent we are not prohibited from doing so) and fully co-operate with the therapist’s instructions with respect to our response.
ADDITIONAL INFORMATION ABOUT OUR WEBSITE
Visiting our Website: We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to improve our Website.
Using our App: When you use our App, we collect information regarding your device type, operating system and version, carrier provider, unique device identifier, language setting, and the date and time that the App accesses our servers. We use this information to help us understand the activity on our App and to monitor and improve our App.
Analytics: We may use third party service providers to collect information about your use of the Services and Website, such as the features used and time spent on the Services, to help us better understand our users and improve our Services and Website. The information we gather is used in an aggregate, non-identifiable form.
Social Media: We may offer you the opportunity to engage with Snapclarity content on or through third-party social networking websites, plug-ins and applications. When you engage with us or our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender). We may use this information to personalize your experience on the Website and on the third-party social networking websites, plug-ins and applications, and to provide you with other information you may request.
SECURITY OF PERSONAL INFORMATION
We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
RETENTION OF PERSONAL INFORMATION
We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes for which such information was provided or to otherwise meet legal requirements.
ACCESS TO PERSONAL INFORMATION
You may request access, updating or correction of your personal information (subject to limited exceptions prescribed by law) by submitting a written request to our Privacy Officer (see “Contact Us” below). We may request certain personal information for the purposes of verifying your identity.
If you request access to personal information that we maintain on behalf of your therapist, we will refer your request to your therapist.
102 Terence Matthews Crescent,
Ottawa, Ontario K2M 0J1.