This Privacy Policy was last updated on May 1, 2020

Manifest Wellness Inc. (“Manifest Wellness” or “we”) respect your privacy and are committed to protecting it by complying with applicable Canadian privacy laws. This Privacy Policy describes the Personal Information we collect, how we use it, and the standards and procedures in place to safeguard your Personal Information.

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”) as set out in our Terms of Use.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information, as applicable. If you do not agree with our policies and practices, you shall not use the Website or book a Session for Services through Manifest Wellness. By accessing or using this Website, or by clicking “I Accept” on the Intake Consent Form required to create your Account and book a Session, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy. This Privacy Policy may change from time to time. We will notify you in advance of any material changes to this Privacy Policy and obtain your consent to any new ways that we collect, use and disclose your Personal Information.

This Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. if you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

1. Interpretation.

1.1 This Privacy Policy should be read together with the Terms of Use for Manifest Wellness provided at the following link: Terms of Use. Further, all capitalized terms not otherwise defined under this Privacy Policy shall have the meaning ascribed to such term in the Terms of Use.

2. Information We Collect About You

2.1 We collect your Personal Information in accordance with the Terms of Use and this Privacy Policy for the purpose of matching you with a Service Provider who will provide the Services to you. Without limiting Section 1.1 or any of the terms and conditions under the Terms of Use, “Personal Information” means any information that can be used to identify an individual, including without limitation, information concerning the physical or mental health of an individual, information concerning any health services provided to the individual; information concerning any body part or any bodily substance of the individual; information that is collected in the course of providing health services to the individual; information that is collected incidentally to the provision of health services to the individual, contact information, name, address, sex, religion, sexual orientation, or any other information that can be used to identify an individual.

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 Service Provider 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

4.1 As you navigate through and interact with the Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
(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. Third Party Use of Cookies and Other Tracking Technologies

5.1 Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies (alone or in conjunction with other tracking technologies) to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

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.

6. Accountability

6.1 Manifest Wellness takes its commitment to securing your privacy seriously. Each Service Provider and any other personnel of Manifest Wellness is responsible for the Personal Information under their control. The employees and contractors of Manifest Wellness are informed and trained on the importance of privacy and receive updated information as applicable about this Privacy Policy and any changes to applicable Canadian privacy laws.

6.2 Manifest Wellness has appointed a Privacy Officer to handle any questions, comments or concerns you may have about this Privacy Policy. The Privacy Officer’s contact information is as follows:
Dave Lige – [email protected]

7. Identifying Purpose: Why We Collect Personal Information

7.1 The purpose of collecting any Personal Information is strictly for providing the Services to you (by the Service Provider). This includes the following purposes:
(a) to maintain a clinical file/chart or working file that meets the standards of BCACC and the CPBC, as applicable;
(b) to provide the Services to you in a manner that ensures your safety;
(c) to maintain a high standard of professionalism in the provision of the Services; and
(d) to assist with the process of billing for the Services.

7.2 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 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.

8. Consent

8.1 You will be required to provide meaningful, express consent to commence the Services with a Service Provider 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 Services and to our procedures related to the handling of your Personal Information:
(a) reading and accepting the Terms of Use at Terms of Use;
(b) reading and accepting this Privacy Policy at Privacy Policy;
(c) reading, completing, and accepting the Intake Consent Form presented to you through Jane App when you book your first Session; and
(d) reading, completing, and signing the applicable consent form provided to you directly by the Service Provider.

8.2 You can withdraw consent at any time by notifying our Privacy Officer of your intent to withdraw (by email or telephone). You acknowledge and understand that given the nature of the Services, certain Personal Information is required for the Service Provider to ensure your safety when providing the Services. If by withdrawing your consent to providing certain Personal Information, the Service Provider determines that they cannot provide the Services to you, they are entitled to terminate the Services in accordance with the termination provisions set out in the Terms of Use.

8.3 In the event that our Privacy Policy changes in any material way as it relates to your Personal Information, we will notify you and obtain your consent to such changes.

8.4 A record of your explicit consent as described in Section 8.1 and 8.3 will be maintained by our Privacy Officer.

9. Limiting Collection

9.1 Manifest Wellness collects only the Personal Information it or the Service Provider requires to meet the purposes described in this Privacy Policy.

10. Limiting Use, Disclosure, and Retention

10.1 The Personal Information we collect from you is strictly for the purposes defined in this Privacy Policy. We will seek your consent prior to using the Personal Information for purposes beyond the scope of the purposes defined herein.

10.2 You acknowledge that Manifest Wellness abides by the principles of confidentiality set forth by the BCACC and the CPBC, as applicable. Any information collected during the Sessions and the Services are strictly confidential. Information provided by you will not be released by Manifest Wellness without informed, written consent from you, except where the Service Provider assesses the need to consult with their supervisor or clinical director to provide the best possible care to you, or where the Service Provider (or Manifest Wellness) is bound by applicable law to disclose the information, such as where:
(a) the Service Provider assesses by law that there is a risk of harm to you or to others;
(b) the Service Provider 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 Service Provider assesses that there is a risk to the country or threat of terrorism;
(d) the Service Provider is bound to report a colleague to their governing body for professional misconduct;
(e) the Service Provider is required to defend themselves against a complaint filed with their governing body;
(f) the Service Provider is required by a court order, issued by a judge, to release information contained in records and/or requires a Service Provider to testify in a court hearing.

10.3 You acknowledge and agree that the exceptions to confidentiality set forth in Section 10.2 is not exhaustive. Your Service Provider must abide by the rules of their governing bodies. The Service Providers must abide by the code of conduct policies they are subject to as follows:
(a) as to Clinical Counsellors, the B.C. Association of Clinical Counsellors Code of Ethical Conduct. Please refer to the following link to review the Clinical Counsellors obligations, including their obligations with respect to confidentiality and informed consent: Clinical Counsellors Code of Ethical Conduct (BCACC);
(b) as to Psychologists, the CPBC’s Code of Conduct. Please refer to the following link to review the Psychologist’s obligations, including their obligations with respect to confidentiality and informed consent: Psychologists Code of Conduct (CPBC).

10.4 Under no circumstances will Manifest Wellness sell patient lists or other Personal Information to third parties.

10.5 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.

10.6 Without limiting any of the terms in this Privacy Policy, you acknowledge that to book a Session with a Service Provider via Manifest Wellness, you will be required to complete the Intake Consent Form and create your Account via Jane App.

10.7 You acknowledge and agree that you have read and agree to the Jane App Privacy Policy at the following URL: https://jane.app/legal/privacy-policy#patient-data. If you do not agree to the Jane App Privacy Policy, or to the storage of your Personal Information as described in Section 10.4 above, you shall not create an Account or book a Session through Manifest Wellness.
10.8 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 or CPBC, as applicable, 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.

11. Accuracy

11.1 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 Service Provider, as applicable.

12. Safeguards: Protecting your Personal Information

12.1 We use an off-site storage facility provided by Jane App (as described in Section 10.4) to process, store and dispose of your Personal Information. For more information on Jane App’s storage practices, please visit the Jane App Privacy Policy at Jane App Privacy.

12.2 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.

13. Accessing and Correcting Your Personal Information

13.1 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
We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact our Privacy Officer if you have any questions or concerns. We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, our compliance with this Privacy Policy, and with applicable Canadian privacy laws.

Jeff Hoy – [email protected]

 

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