Privacy Policy

NOTE: If your organization is providing the access to this Program, only your name and your Organization Identification Number will be sent to the paying organization to confirm that you are a current member and are eligible to access the Program (as defined below). No other personal information collected (including frequency of use, assessment results, or your use of program tools) will be shared with anyone including your employer or union, unless you have consented to such disclosure.

1. OVERVIEW

Starling Minds Inc. (“Starling Minds”, “we” or “us”) is committed to protecting and respecting the privacy rights of its visitors and users (“you” or “your”). This Privacy Policy (“Policy”), as amended from time to time, applies to your access and use of the Program at www.starlingminds.com (“Website”) and any other online product or service including any module training programs to which you have access or use therein as well as any Account (defined below) you use to access the Website or other online products or services (together, the “Service”) offered by Starling Minds. We have adopted this Policy to explain how we collect, store and use information collected from you in connection with your access and use of the Service.

BY CLICKING “I AGREE”, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE OR OTHERWISE ACCESS THE SERVICE.

 

2. INFORMATION WE COLLECT & HOW WE USE IT

In this section of the Policy, we will describe the type of personal and non-personal information that may be collected and how that information may be used or disclosed.

2.1 Personal information

For the purposes of this Policy, “personal information” means personally identifiable information that specifically identifies you as an individual and includes those items listed below.

2.1.1 Registering for Account

When you register for an account on the Service (an “Account”), we collect and store the personal information that you provide us, such as your name, email address, username, password, date of birth, gender, marital status, primary caregiver, number of children and their ages (if applicable), employment identification number and other unique organization or insurance plan identifiers (such as a union or insurance identification number), if applicable (the “Unique Identifier”) to provide you with access to the Service. 

2.1.2 Use of the Service

When you complete assessments, questionnaires, evaluations, exercises, training modules, or otherwise enter information on, or use, the Service, we may collect, store and use this personal information, such as your assessment results, goals, thoughts, common stressors, mood tracking information, self-identified mental and physical well-being including your stress, anxiety and depression levels, whether you have been diagnosed with a mental disorder, and if so which disorder, whether you suffer chronic pain, and any other information that you provide to the Service (together, the “Assessment Information”) to provide you with assessments, scores, tips and other meaningful use of the Service as well as tailored and relevant mental health information. 

2.1.3 Contacting Us

When you choose to contact Starling Minds through the Service, we may collect, store and use the personal information that you provide to us, such as your name, email address and other information you choose to provide in the content of your message, so we can respond to your inquiry.

2.1.4 Other Purposes

Additionally, Starling Minds may collect, store, and use personal information to solicit your feedback or to help improve the Service and other Starling Minds products, advise you about new products or promotional material offered by us, notify you about changes to the Service or other Starling Minds products, provide you with our newsletter or advertising and marketing material and communicate with you for other commonly accepted purposes. You may opt-out of newsletters and other promotional emails that you receive from us at any time. Finally, Starling Minds may collect and use personal information as required or permitted by applicable law. 

2.2 Non-Personal information

We may also collect, use and disclose non-personal information that does not directly identify you as follows: 

2.2.1 De-Personalized Information

Starling Minds may collect, use and disclose De-Personalized Information generated from the Service for the purposes of statistical and demographic research, analysis, reporting and to further develop the Service and ancillary services. “De-Personalized Information” means data Starling Minds collects about you use of the Service, including Assessment Information, that has been aggregated and de-personalized information, and from which personally identifiable information has been removed.

2.2.2 Cookies, Beacons and Tracking

When you access or use the Service, we (or a third party provider) may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons, to track what you view and interact with on the Service. Starling Minds treats information collected by cookies and similar technologies as non-personal information.

A “cookie” is a small bit of record-keeping information that is sent to your computer. The cookies that Starling Minds uses do not include personal information and may be used to: (1) help you navigate around the Service, (2) monitor how many people are using the Service, and (3) track trends. Once you leave the Service, the cookie is not retained on your computer. Most browsers are initially set up to accept cookies, but you can disable cookies or set your browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to access the Service.

2.2.3 Google Analytics

Google Analytics is a web analysis service provided by Google. Google collects such data as e-mail address, browser and version, event (e.g. clicked on a given link) and operating system of the user’s computer, and utilizes the data collected to track and examine the use of the Google Analytics Service, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Google’s privacy policy can be found here.

We use Google Analytics to collect transactional and location information. This allows us to identify most common devices, device screen sizes and operating systems – and behavioral patterns to improve the experience provided by service. With Google Analytics we do not collect any identifier which we could use to combine this data with any other data collected by and stored into program.

Also, we will not upload information to Google Analytics that allows Google to personally identify you (such as certain names, social security or social insurance numbers, email addresses, or any similar data), or data that permanently identifies a particular device (such as your mobile phone’s unique device identifier if such an identifier cannot be reset), even in hashed form. Google Analytics’ servers are located in the United States.

2.2.4 Keen.IO

Keen.IO is a web analysis service provided that collects such data as when a use registered or signed in to the program, completed module, section or assessment, gave us feedback and tracked a mood or relaxation record. We use Keen.IO to collect transactional and location information. This allows us to identify whether the tools and parts of content we are providing are used by users, and thus gives us opportunity to improve parts which are not used and in the end bring better user experience to our users.

However, we will not upload information to Keen.IO that allows Keen.IO to personally identify you (such as certain names, social security or social insurance numbers, email addresses, or any similar data), or data that permanently identifies a particular device (such as your mobile phone’s unique device identifier if such an identifier cannot be reset), even in hashed form. Keen.IO’s servers are located in the United States.

2.2.4 User Generated Comments

You should be aware of the open nature of certain features of the Service that we may make available to you. You may choose to disclose information in the course of contributing user generated content to the Services, such as comments and quotes (“Submissions”). We may post your Submissions, without information that directly identifies you, on the Service. Any data that you disclose on the Service is public information, and there is no expectation of privacy or confidentiality.

2.2.5 Server Logs

Starling Minds’ servers may log non-personal information about your use of the Service, such as: (1) your search activity, pages viewed, the date and time of activity; and (2) any information provided by your computer or mobile device in connection with your use of the Service, such as your browser type, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.

2.2.6 Trusted Partners and Sponsored Companies and Organizations

We may use and disclose to its affiliated companies, contractors, trusted partners or persons and sponsoring companies and organizations the collected non-personal information for the purpose of reporting aggregate and de-personalized Assessment Information, auditing, researching and analyzing usage of the Service, ensuring the technical functionality of the Service and further developing the Service and other Starling Minds products.

 

3. DISCLOSURE OF PERSONAL INFORMATION

3.1 Limited Disclosure to Sponsoring Organization

If your employer or other sponsoring organization (your “Sponsoring Organization”) is paying the cost associated with your use of the Service, then when you register for an Account on the Service Starling Minds will disclose your name, Unique Identifier (if applicable) and email address to your Sponsoring Organization for authentication and authorization purposes only. No Assessment Information or other personally identifiable information generated by you using the Service will be disclosed to your Sponsoring Organization unless you have consented to such disclosure.

3.2 Limited Disclosure to other Third Parties

Starling Minds does not sell, rent, share, trade or disclose your personal information to or with third parties except in the following limited circumstances: we receive your consent; to enforce applicable Terms of Use including investigation of potential violations thereof; or we are required or authorized to do so by applicable law.

3.3 Data Processing

Starling Minds may also disclose personal information to its service providers for the purpose of processing personal information on its behalf or assisting in the operation of the Service or other Starling Minds products. We require that these parties agree to process such personal information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

3.4 Sale of Business

As Starling Minds continues to develop and grow, we may buy or sell parts of a business, which could include personal information as one of the transferred business assets. We will only disclose personal information to a prospective party of a proposed “business transaction” (as defined in the Personal Information Protection Act (British Columbia) (“Business Transaction”) if it is necessary for the prospective party to evaluate whether to proceed with the Business Transaction and it has agreed to only use personal information for the purpose of evaluating the Business Transaction.

If we complete a Business Transaction that includes personal information as one of the transferred business assets, we may disclose your personal information on the condition that they only use the personal information for the same purpose it was collected, used and disclosed. Additionally, we will provide you with notice that the Business Transaction has taken place and your personal information has been disclosed and now subject to a different privacy policy.

 

4. MINORS

The Service is intended for general adult audiences and you must be eighteen (18) years or older to register, access or use the Service. We do not knowingly collect any personal data from persons under the age of eighteen (18) years of age and if we learn that we have inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, we will take reasonable measures to promptly erase such personal data from our records.

 

5. CHOICES FOR PERSONAL INFORMATION

If Starling Minds propose to collect, use or disclose personal information for any purpose other than those described in this Policy, we will obtain your consent or offer you an effective way to opt out of the use of personal information for those other purposes.

You may choose to withdraw your consent to the collection, use or disclosure of your personal information as outlined in this Policy at any time. If you withdraw consent, then Starling Minds may no longer be able to provide you with full or any access to the Service.

Users are also given the opportunity to “opt-out” of having their personal information used for specific purposes such as receiving newsletters or other information from Starling Minds.

Withdrawals of consent will not have an effect on personal or other data that Starling Minds has used or disclosed in accordance with this Policy prior to such withdrawals.

 

6. THIRD PARTY PRIVACY POLICIES

Starling Minds may make available third party links through advertisements, hyperlinks or otherwise enable you to access third party products or services from the Service that are not affiliated with or controlled by us. We are not responsible for those parties, the content of their products or services, or the use of information you provide to them. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies. You recognize and agree that we are not liable for any third parties use of your personal information and you should review the privacy policies of these third parties.

 

7. DATA STORAGE

Unless otherwise permitted by applicable law, your personal information will be stored and maintained on servers or databases located in Canada.

 

8. INFORMATION SECURITY

Starling Minds take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of personal information. Starling Minds uses physical, electronic and/or procedural safeguards to protect its systems and all personal information under its control against unauthorized access and use. We only use third party server hosts with certified facilities that contain the industry standard physical, operational and digital security and restriction protocols. All safety and security measures are appropriate to the sensitivity level of the information collected.

 

9. ACCURACY AND ACCESS/CONTROL OVER PERSONAL INFORMATION

We will take reasonable steps to ensure that the personal information collected by us or on our behalf is accurate and complete.

Starling Minds will allow you to access your personal information in the custody or control of the program, and you may request that we:update or correct such personal information; change your preferences with respect to communications and other information received from us; or delete your personal information on our primary system, by submitting a request to Customer Support.

 

If Starling Minds is satisfied on reasonable grounds that your request to update or correct your information should be implemented, we will correct your personal information on our primary system as soon as reasonably possible and send the corrected personal information to each organization that we have disclosed your personal information to in the past twelve (12) months. We may retain an archived copy of your records as required or authorized by law.

 

10. RETENTION OF PERSONAL INFORMATION

Starling Minds retains personal information collected pursuant to this Policy only as long as is reasonably required to fulfill the purposes for which it was collected, or as required or authorized by law.

 

11. CHANGES TO THIS POLICY

Starling Minds reserves the right to modify this Policy at any time. We may provide you with notice of such modifications, by sending you an e-mail message or otherwise bringing it to your attention in the Service. Your continued use of the Service will signify your acceptance of the modifications to this Policy.

 

12. CONTACT INFORMATION

Should you have any questions relating to this Policy, please send correspondence to info@starlingminds.com.