Last Updated: February 12, 2022
We are proud to show our commitment to your privacy, by complying with American or Canadian provincial, state and federal laws and regulations pertaining to privacy and health information. Further, we are compliant with the privacy and data requirements of the pharmacy regulatory bodies of the American or Canadian jurisdiction in which you reside.
“Personal Information” is any information that is identifiable with you, as an individual. This information may include, but is not limited to, an individual’s name, email address, residential address, telephone number, date of birth, medical history, gender, insurance information, payment card information, transaction history, other billing information, and in some cases, use name and password.
Any information you disclose to a third party is dealt with in accordance with the privacy policies adopted by each of those third parties. Individuals are encouraged to review the privacy policies maintained by each of those third parties to understand how their information will be used by them to process requests.
If you do not wish to have us collect your Personal Information through the Platform, you can choose not to provide it. However, your decision to withhold details may limit the services we are able to provide and make it more difficult for us to advise you or suggest appropriate alternatives to our services. If we are unable to accommodate your requests based on the information that you have provided, we may ask for additional information so that we may better accommodate your needs.
Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the purposes identified herein at any time by contacting us through the contact details provided below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you or continue to provide you with certain services which may be of value to you.
Collection of Personal Information
We may collect information (including Personal Information) as follows:
● (a) Information You Provide to Us. When you open an account with us, request support, or in any other way take steps that require the submission of information; we may collect Personal Information. This information is necessary for verifying your identity, providing services, contacting you regarding services and providing you with the information and/or services requested.
● (b) Social Media Sites. If you choose to connect to the Platform through a third-party social network (such as Facebook, Facebook Messenger or WhatsApp), we may collect information from your profile on such third-party social networks, such as your name, username, gender, location and date of birth.
● (c) Payment Information. When you make purchases through the Platform, our payment processor Stripe will collect your credit card information. We do not collect or store your credit card information.
● (d) In-Platform Communications. If you choose to send a message to us through our message, chat, post, SMS, email or other function, we may collect any information you may disclose through such means in order to facilitate the communication.
● (g) Telephone Calls and Video Calls. We may record individual or group therapy sessions that you participate in. These recordings may be privately shared within our platform or form part of our content on the Platform.
● (g) Push Notifications. If you choose to enable push notifications, we may use your information, such as a device ID or email address, in order to send push notifications to your device.
● (h) Information You Submit to Us. If you choose to submit your information to us for any other reason, in any other form, we will collect such information and use it for the purposes for which you submitted it.
● (i) Visiting the Website. We will not collect any Personal Information from you simply by virtue of your visiting the Website; we only collect Personal Information if you or choose to submit it to us. We do, however, collect non-Personal Information such as usage data, whenever you use the Platform. Such non-Personal Information is not combined with Personal Information unless and until you choose to submit Personal Information to us.
● (j) Where Permitted by Law. We may also collect information, including Personal Information as otherwise permitted by law.
● (k) “Cookies”. We may also use “cookies” or similar technologies when you use or access our Platform (small amounts of data that are stored on your computer’s hard drive, mobile device or media system platform that identify your computer, mobile device or media system platform and may store information about you, such as behavioural data). Should you choose to submit Personal Information to us, we may link cookie information to such Personal Information. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. However, please be aware that some of our Platform services will not function properly if you do so. Visit www.networkadvertising.org/managing/opt_out.asp, www.youronlinechoices.eu, www.youradchoices.ca/choices, and www.aboutads.info/choices/ to learn more about the choices available to opt out of cookies and advertising.
Use of Personal Information
We identify the purposes for which we collect and intend to use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):
● to facilitate and administer your access to and use of the Platform;
● to provide services, memberships and sell products to you;
● to facilitate communications with third-party service providers with whom we have a contractual relationship such as benefit providers, insurers or to process payment;
● to improve our services and product offerings;
● to send you information related to our Platform, including confirmations, technical notices, updates, security alerts, information related to product safety or recall issues and support and administrative messages;
● for quality assurance purposes and to respond to your inquiries, complaints or requests;
● to investigate and respond to legal claims;
● other such purposes for which we may obtain consent from time to time; and
● other uses as may be permitted or required by applicable law.
Disclosure of Personal Information
Generally, we will only disclose your Personal Information to third parties where you have provided your consent for us to do so or where we are permitted or required to do so by law. We will not transfer your Personal Information to third parties, except our subsidiaries, affiliates and business partners that we engage to provide services on our behalf, such as (but not limited to) web hosting services, credit card payment processing, order processing and delivery, provided that such third parties have agreed to comply with legally required privacy standards and applicable law, and to use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose. We will only provide those third parties with the Personal Information that they need to deliver the services to you or us. Notwithstanding the foregoing:
● We may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all the business (in which case the use of your Personal Information by the new entity would continue to be limited by applicable law).
● We may disclose Personal Information where otherwise permitted or required by law.
We may also share aggregate or anonymized information, including de-identified Personal Information, about you with service providers, business partners, and other third parties, to the extent permitted by applicable law.
Storage and Retention of Personal Information
We will securely store your Personal Information at our secure servers and/or at our service provider’s data centres in Canada. As some of our third-party service providers may retain and store information received from you (including Personal Information) outside of Canada, your information may be subject to foreign laws and in certain circumstances foreign governments, courts, law enforcement agencies, regulatory agencies or security authorities may have access to your information.
All data is stored with reasonable administrative, physical and technical security measures to protect the information from unauthorised access and against loss, misuse or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure. While we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent unauthorised third-parties from illegally obtaining access to this information.
We will use, disclose or retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected or as permitted or required by law. Personal Information is retained in accordance with applicable laws and any applicable document retention requirements.
Accessing and Correcting Personal Information
It is important that the Personal Information we have is accurate, complete and up to date. You are encouraged to inform us when there are any changes to your information by updating your information within the Platform. You may also, at any time, contact Euanoia directly to request access to your Personal Information, verify its accuracy and, if required, to correct it. Eunoia will provide you with access to your Personal Information, except where prohibited by law from doing so, or where permitted by law to restrict your access and have legitimate reasons for doing so.
You may contact the Privacy Officer at firstname.lastname@example.org.
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