Introduction 

Counslink(“Counslink”, “we”, “us”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our website located at www.counslink.com (the “Website”) as well as to personal information we collect and use when we provide services on behalf of our mental health practice customers (“Practice Users”). This Privacy Policy applies to all of the services (as more particularly described in our Terms ofService), and websites offered by Counslink. The privacy of our customers is of great importance to us. By visiting our Website and/or using the Services in any manner, you acknowledge that you have read the practices and policies outlined in this Privacy Policy and you understand that your Personal Information will be collected, used and disclosed in accordance with this Privacy Policy. 

What does this privacy policy cover? 

This Privacy Policy describes our collection, use and disclosure of information about identifiable individuals, including information which can be used to identify an individual (“Personal Information”). Personal Information does not include any anonymised information which we may create or derive from information(including Personal Information) you provide to us. Personal Information may be collected about our Practice Users and prospective customers, visitors to the Website, and end users of the Services. You can choose not to provide us with certain Personal Information, but by doing so, you may not be able to take advantage of many of the features and functionality of our Services. We may also collect Personal Information about patients of our Practice Users on behalf of the Practice User. This Privacy Policy does not apply to the practices of companies that we do not own or control, including Practice Users. Our Practice Users are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information and for ensuring that they have obtained the necessary authorisations and consents for any Personal Information made available to us for use in accordance with thisPrivacy Policy. If you have any questions regarding the privacy practices of a particular Practice User, please contact the Practice User directly.

What is Personal Information?

Personal Information is defined in the PersonalInformation Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organisation. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, internet protocol addresses, network and server particulars, and/or other information relevant to the Website, promotional and marketing activities.Personal health information is more specific, and is defined in the Personal Health Information Protection Act, 2004 (Ontario)(“PHIPA”) as identifying information about an individual which relates to that individual’s physical or mental health, the provision of health care to that individual, payments made or eligibility for health care or health care coverage of that individual.Since 2004, all Canadian organisations engaged in commercial activities have been required to comply with the PIPEDA and theCanadian Standards Association Model Code for the Protection of PersonalInformation. These obligations extend to Counslink, and apply with and in addition to the terms of this Privacy Policy. As the Website connects Mental Healthcare Professionals with potential patients/clients, Counslink may at times be subject to the more stringent obligations imposed by PHIPA to the extent that personal health information is collected. Counslink will abide by these higher standards when the more stringent obligations apply.

Consent

By using the Website, the User consents to the collection, use, and disclosure of the User’s personal information in accordance with this Privacy Policy. If the User does not consent to all aspects of the Privacy Policy, they must immediately cease using theWebsite. Please note that the User’s access and continued use of the Website will be deemed as consent by Counslink.A User who does not consent to the collection of personal information or personal health information, or who withdraws their consent, should immediately cease use of the Website and inform Fist Session’sPrivacy Officer (see contact information below). If a User withdraws or limits its consent for Counslink to collect or disclose personal information or personal health information, Counslink may be limited in its ability to provide services or access to certain aspects of the Website.Personal information or personal health information will only be collected or disclosed without the consent of the User in the limited circumstances that are expressly permitted by law. For example, privacy legislation allows for the collection and/or disclosure of personal information where there is an emergency, or a serious concern for health and safety. THE SITE IS INTENDED FOR USERS WHO ARE OVER 18YEARS OF AGE. Persons who are under 18 years of age should not provide personal information or personal health information without the express consent of their parents or guardians.Collection of personal information and personal health information Counslink collects personal information and/or personal health information in one (or more) of three ways:

Volunteered Information: Counslink may collect personal information and/or personal health information that is voluntarily provided by a User utilising the Website (i.e. data or comments entered into forms or data fields on the Website).

Information from Public or Third-PartySources: Counslink may collect personal information and/or personal health information about Users who register or access theWebsite from public or third-party sources.

Information Collected from a User’s Computer or other Electronic Device: Counslink collects information from a User’s computer and other electronic devices (i.e. phones, tablets, etc.) when a User accesses the Website. The information collected includes but is not limited to a User’s Internet Protocol (IP) address, domain name, browser type, date and time of a User’s request and information provided by tracking technologies, such as cookies and single-pixel tags. Counslink may also anonymously use login formation on operational systems and identify categories of Users by items such as domains and browser types to properly manage the Website.Counslink only collects personal information and personal health information that is necessary to accomplish the specific goals for which it is being collected.Storage of personal information and personal health information (including outside of Canada)For efficiency and functionality, Counslink uses cloud-based data collection and storage methods and products from third-party service providers. For example, Counslink collects and stores information collected from Users through the use of products and services provided by EYHost, Google and Webflow, Inc.Third party service providers engaged by Counslink may host, transfer, and process data, including personal information and personal health information, in the United States and in other countries, and subject to the terms of their own respective privacy policies.By using the Website, the User consents to the storage of the User’s personal information in servers located throughout Canada, the United States, and in other countries, including by third party cloud related service providers engaged by Counslink.

How is the personal information and personal health information used?

‍Counslink collects, uses, and discloses personal information and personal health information to provide the User with better services. In particular, personal information and personal health information is collected for the following reasons:

1. to register a User for, and facilitate a User’s participation in, certain areas of the Website (for example, by collecting a User’s name and email address in order to contact the User);

2. to connect potential patients/clients with Mental Healthcare Professionals (for example, basic information may be collected to assist in filtering or matching a User     with Health Cate Providers – provided however that such information will not be shared with a Health Care Provider without the express permission of a User);

3. to provide information and reminders to Users regarding their appointments or consultations;

4. to properly advertise and promote Mental Healthcare Professionals and their degrees, specifications, and certifications;

5. to gather a User’s opinion and feedback;

6. internal record keeping;

7. to improve the Website;

8. to audit online resources for authorised access and security;

9. to customise the Website according to a User’s interests; and

10. such other uses as may be permitted or required by applicable law.

Specifically, the personal information of Users who are seeking to connect with Mental Healthcare Professionals may be collected in order to filter or match a User with Mental Healthcare Professionals. In these circumstances, certain information such as a User’s name, email address, phone number, gender, occupation, therapy history and responses to assessment questions may be used.Aggregated Data may be used for data analytics, and for such purpose may be reported to third parties assisting Counslink in managing the Website and providing its services.In certain limited circumstances, Counslink may be required to release or provide access to personal information or personal health information in response to a subpoena, search warrant, court order, law, or regulation. In such case, Counslink will take all appropriate measures to ensure that Users’ personal information and personal health information is protected to the greatest extent possible while Counslink cooperates fully with court and law enforcement authorities in this regard.

To whom does Counslink disclose personal information and personal health information?

Except as otherwise provided in this Privacy Policy, personal information and personal health information will not be shared without Users’ permission. However, Counslink reserves the right to disclose personal information and personal health information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorised by the presiding court or tribunal and other wise to the extent required or explicitly authorised by law.When a User agrees to be matched with a HealthCare Provider, Counslink will disclose a User’s personal information (to the extent consented to by such User) to the Health Care Provider in order to facilitate appointments and communication.Counslink may disclose personal information and personal health information to a buyer or transferee in connection with the sale, assignment, or re organisation of its business. In this case, Counslink will require the buyer to agree to treat personal information and personal health information in accordance with the terms of this Privacy Policy.

Requests to stop collection, use, and/or disclosure

‍Users may withdraw their consent to Counslink’s collection, use, and disclosure of personal information and personal health information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting Counslink’s Privacy Officer (see contact information below). Notwithstanding the above, certain personal information may be collected automatically when a User visits the Website. Continued use of the Website will be deemed by Counslink to be consented to obtain any personal information that derives from Users’ use of the Website notwithstanding the fact that such User has previously communicated their withdrawal of consent for such collection.

How do Users limit the collection, use, and disclosure of information?

Users may choose not to provide personal information or personal health information by not entering it into forms or data fields on the Website when prompted. Users should be aware that choosing not to provide this information may limit their ability to access all features of the Website. Users who previously agreed to permit the use of personal information for marketing, advertising, or other promotional purposes may revoke their consent by following the opt-out instructions provided in each communication they receive, or by making a request in writing to support@counslink.com.

How does Counslink protect a User’s Personal Information?

Counslink employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. With respect to personal health information collected, Counslink acts as custodian thereof and takes all precautions required by PHIPA to prevent the unauthorised disclosure thereof. Counslink confirms that it does not use any personal health information for treatment purposes. Counslink also confirms that it does not take any steps to verify the accuracy of any personal health information. Counslink will take all reasonable and legally required steps to protect personal information and personal health information as it is transmitted from a User’s computer to the Website or other online resources and servers. Counslink will also protect personal information and personal health information from unauthorised access, disclosure, alteration or destruction.  Counslink ensures that all affiliates and other third parties that are retained to perform services on Counslink’s behalf and are provided with personal information and/or personal health information are contractually required to observe the Privacy Policy. It is a User’s personal responsibility to secure a User’s own copies of any logins, passwords and related access codes used on or for the Website. Please note, security risks on the internet cannot be eliminated, and Counslink cannot and does not guarantee that a User’s personal information and personal health information will not be accessed in ways not otherwise described in the Privacy Policy.

‍Access and correction to personal information and personal health information

‍Users may access, update, and correct inaccuracies in personal information in Counslink’s possession, subject to certain exceptions prescribed by law.Upon written request, Counslink will provide a User with any personal information and personal health information in its possession to the extent required by law. If a User would like to access any of its personal information and personal health information or believes that any of the personal information and personal health information collected by Counslink relating to a User is incorrect or incomplete, they should contact Counslink’s Privacy Officer (see contact information below).

Miscellaneous

1. Former UsersIf: a User ceases using the Website, or aUser’s access to the Website has been terminated for any reason, Counslink may continue to use and disclose a User’s personal information and personal health information in accordance with the Privacy Policy.

2. Terms and Conditions of Use of Website: Any applicable terms & conditions of use governing a User’s use of the Website, including but not limited to the Terms of Service, contain important provisions, including provisions disclaiming, limiting, or excluding the liability of Counslink for a User’s use of theWebsite and provisions determining the applicable law and exclusive jurisdiction for the resolution of any disputes regarding a User’s use of theWebsite.  Each of those provisions applies to any disputes that may arise in relation to the Privacy Policy, including any collection, use and disclosure of personal information and personal health information and are of the same force and effect as if they had been reproduced directly in this Privacy Policy.

3. Third Party Links and Websites: The Website may contain links to other third-party websites or internet resources, which are not affiliated with the Website, nor provided by Counslink, and are not subject to the Privacy Policy.  The User assumes any risk associated with any third-party links or web sites. Counslink assumes no responsibility or liability for, or control over any third-party websites or their collection, use and disclosure of a User’s personal information and/or personal health information.

4. Privacy Policy Amendments: To accommodate amendments to the Website, changing technology, and legal developments, the Privacy Policy may be revised in Counslink’s absolute discretion and without any prior notice or liability to the User or any other person.  Counslink’s collection, use and disclosure of the personal information and personal health information through the Website will be governed by the version of the Privacy Policy in effect at that time when the information is collected, used, or disclosed. New versions of the Privacy Policy will be posted on the Website and will be available upon request from Counslink.  A User’s continued access, use and/or dealings with the Website after any amendments to the Privacy Policy, will signify a User’s consent or continued consent to the collection, use and disclosure of personal information and personal health information in accordance with the revised Privacy Policy.

Further Information

‍For more information about the Privacy Policy, please contact via electronic mail at support@counslink.com.