It is our policy to comply with all applicable Canadian privacy laws and regulations relating to the privacy of our clients or website users (“you”). For greater certainty, Manifest Wellness adheres to the practice standards of British Columbia Association of Clinical Counsellors (“BCACC”).
2. Information We Collect About You
2.2 We may also collect non-personal information that does not directly or indirectly reveal your identity such as demographic information, or statistical or aggregate information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users booking Sessions or accessing a specific Website feature.
2.3 We may also collect technical information, including your login information, browser type and version, time zone setting, browser plugin types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
3. How We Collect Personal Information
3.1 The Personal Information we collect directly from you on or through our Website may include:
(a) information that you provide by creating an Account or filling in any other forms on our Website;
(b) information you voluntarily submit to your Clinical Counsellor during a Session; and
(c) records and copies of your correspondence (including email addresses) if you contact us.
4. Information We Collect Through Cookies and Other Automatic Data Collection Technologies
(a) details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website;
(b) information about your computer and Internet connection, including your IP address, operating system, and browser type.
4.2 We may also use the technologies described in Section 4.1 to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). To learn more or to opt out of tailored advertising visit the following link: https://youradchoices.ca/en/tools .
5.2 You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. To learn more about the opt-out tool, please visit https://youradchoices.ca/en/tools. You can also access this website to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
5.3 We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or targeted content, you should contact the responsible provider directly.
Jeffrey Huang – email@example.com
Identifying Purpose: Why We Collect Personal Information
6.3 The purpose of collecting any Personal Information is strictly for providing the Clinical Counselling Services to you (by the Clinical Counsellor). This includes the following purposes:
(a) to maintain a clinical file/chart or working file that meets the standards of BCACC;
(b) to provide the Clinical Counselling Services to you in a manner that ensures your safety;
(c) to maintain a high standard of professionalism in the provision of the Clinical Counselling Services; and
(d) to assist with the process of billing for the Clinical Counselling Services.
6.4 We obtain your Personal Information directly from you, or from other health practitioners whom you have authorized to disclose to us. We will limit the Personal Information we collect to what is necessary to provide the Clinical Counselling Services to you, and we will use the Personal Information only for the purpose set out herein. We will obtain your express consent if we wish to use your Personal Information for any other purpose not described in Section 7.1.
7.1 You will be required to provide meaningful, express consent to commence the Clinical Counselling Services with a Clinical Counsellor through Manifest Wellness. Meaningful consent means you must understand what you are consenting to. By taking the following explicit actions, you provide consent to receiving the Clinical Counselling Services and to our procedures related to the handling of your Personal Information:
(c) reading, completing, and accepting the Intake Consent Form presented to you through Jane App when you book your first Session.
7.4 A record of your explicit consent as described in Section 8.1 and 8.3 will be maintained by our Privacy Officer.
8. Limiting Collection
9. Limiting Use, Disclosure, and Retention
9.2 You acknowledge that Manifest Wellness abides by the principles of confidentiality set forth by the BCACC. Any information collected during the Sessions and the Clinical Counselling Services are strictly confidential. Information provided by you will not be released by Manifest Wellness without informed, written consent from you, except where the Clinical Counsellor assesses the need to consult with their supervisor or clinical director to provide the best possible care to you, or where the Clinical Counsellor (or Manifest Wellness) is bound by applicable law to disclose the information, such as where:
(a) the Clinical Counsellor assesses by law that there is a risk of harm to you or to others;
(b) the Clinical Counsellor assesses that a child may have been harmed in the past, or that a child is at risk of harm in the present or future;
(c) the Clinical Counsellor assesses that there is a risk to the country or threat of terrorism;
(d) the Clinical Counsellor is bound to report a colleague to their governing body for professional misconduct;
(e) the Clinical Counsellor is required to defend themselves against a complaint filed with their governing body;
(f) the Clinical Counsellor is required by a court order, issued by a judge, to release information contained in records and/or requires a Clinical Counsellor to testify in a court hearing.
9.3 Under no circumstances will Manifest Wellness sell patient lists or other Personal Information to third parties.
9.4 You acknowledge and agree that Manifest Wellness uses a third party software, Jane App, for the purpose of online booking, scheduling, billing, and charting. For greater certainty, Manifest Wellness uses Jane App’s clinic management platform to collect your Personal Information and to create patient records. These records will include your Personal Information, such as, your name, address, health insurance and billing information, and appointment history. Jane App’s role is to store the Personal Information in its secure data centers and makes it available to Manifest Wellness and to you (when you access your Account) through Jane App’s clinic management platform. Jane App otherwise has no control over your Personal Information. Jane App will only access your Personal Information on the instructions of you or Manifest Wellness or, in rare cases, where needed in order to prevent or address technical problems or if required by law or court order. Your Personal Information is stored in Jane App’s regional data centre located in Canada.
9.7 Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary, and at all times in compliance with BCACC standards and applicable Canadian privacy laws to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
10.1 Manifest Wellness endeavours to ensure that all decisions involving your Personal Information is based upon accurate and timely information. Notwithstanding this Section, you acknowledge and agree that it is your responsibility to disclose only accurate, truthful, and complete Personal Information to Manifest Wellness or the Clinical Counsellor, as applicable.
11. Safeguards: Protecting your Personal Information
11.2 The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to your Account, you are responsible for keeping such access credentials confidential.
12. Accessing and Correcting Your Personal Information
12.1 It is important that the Personal Information you provide is accurate and current. Please keep us informed if your Personal Information changes. By law, you have the right to request access to and to correct the Personal Information we hold about you. You can review and change your Personal Information that you submit when creating your Account by accessing your Account through Jane App. You can also contact our Privacy Officer for more guidance on how to change your Personal Information.
Contact Information and Challenging Compliance
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