2. INFORMATION WE COLLECT & HOW WE USE IT
2.1 Personal information
2.1.1 Registering for Account
When you register for an account on the Programs (an “Account”), we may collect and store the Personal Information that you provide us, and employment identification number and other unique organization or insurance plan number, if applicable (the “Unique Identifier”) to provide you with access to the Programs. This Unique Identifier will be an anonymized ID.
2.1.2 Use of the Programs
When you complete assessments, questionnaires, evaluations, exercises, training modules, or otherwise enter information on, or use, the Programs, we may collect, store and use this Information, some of which may be or contain Personal Information, such as your assessment results, goals, thoughts, common stressors, mood tracking information, self-identified mental and physical well-being including your perceived stress, anxiety and depression levels, and 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 Programs (together, the “Assessment Information”) to provide you with assessments, scores, educational tools, and other meaningful use of the Programs as well as tailored and relevant mental health information.
NOTE: You can only create an Account to use the Starling Programs if the organization of which you are an employee, contractor or associate (a Starling “Client”) is paying for your access to the Programs. You acknowledge that your name may be sent to the Client for billing and administrative purposes. No other Personal Information collected (including your Unique Identifiers, frequency of use, Assessment Information, or your use of educational tools) will be shared with the Starling Client, unless you have specifically consented to such disclosure.
2.1.3 Contacting Us
When you choose to contact Starling Minds using the Programs’ functionality, 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. If you send us correspondence using the functionality of the Programs we retain the information in that correspondence in the records of your Account. We will also retain all related correspondence from us to you and all related records. We retain these records in order to measure and improve our customer service, or as required to comply with applicable law and/or regulation.
2.1.4 Other Purposes
Additionally, Starling Minds may collect, store, and use Personal Information to solicit your feedback or to help improve the Programs and other Starling Minds products, advise you about new products, notify you about changes to the Programs 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.
We may offer optional questionnaires and surveys to you for the purposes of assessing Programs quality. By way of example we will ask if your use of the Programs increased your mental well-being We then ask you to rate the Programs. We also give you a chance to identify if you perceived any bias.
Such survey information and results, once completely stripped of Personal Information, may be shared with other medical practitioners or regulatory bodies in applicable jurisdictions for purposes of quality assurance and additionally the use of the information collected will be explained in detail in the survey itself. No Personal Information will be collected in the course of conducting the survey but if we collect personally identifiable information from you, our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
If you give us permission, we may contact you for a follow-up in connection with survey results.
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 Aggregated Data
Starling Minds may collect, use and disclose de-personalized information generated from the Programs for the purposes of statistical and demographic research, analysis, reporting and to further develop the Programs and ancillary services. “Aggregated Data” means data Starling Minds collects about your use of the Programs, including Assessment Information, that has been aggregated and de-personalized. All Aggregated Data is and will be, as between us and you, the property of Starling Minds and not considered to be Personal Information.
When you access or use the Programs, we may use “cookies” to track what you view and interact with on the Programs. 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 Programs, (2) monitor how many people are using the Programs, and (3) track trends. Once you leave the Programs, 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 Programs.
2.2.3 User Generated Comments
You should be aware of the open nature of certain features of the Programs that we may make available to you such as user-generated content such as comments. quotes and interactions you have with other members via communities or forums (“Submissions”). You may choose to disclose information in the course of a Submission, but this must not include any of your Personal Information. Starling Minds may publicly post your Submission within the Programs after it has been de-personalized and stripped of any of your stored Personal Information. Any Personal Information which you disclose in the body of the Submission, in contravention of this clause, may be posted with the rest of your Submission.
2.2.4 Server Logs
Starling Minds’ servers may log non-personal information about your use of the Programs, 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 Programs, such as your browser type, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.
2.2.5 Trusted Partners and Sponsored Companies and Organizations
We may use and disclose to our affiliated companies, contractors, trusted partners or persons and Sponsoring Organizations collected non-Personal Information for the purpose of reporting aggregate and de-personalized Assessment Information, auditing, researching and analyzing usage of the Programs, ensuring the technical functionality of the Programs and further developing the Programs and other Starling Minds products.
2.2.6 Site Traffic Information
Due to the technical nature of web-browsing, when you visit our Website or use obtain Programs from us, we obtain the following information:
(a) the web address of the website that you came from or are going to;
(b) which pages of our Website and features of our Programs you visit or use;
(c) the type of browser you use;
(d) the times you access our Website or use our Programs;
(e) the type of device you use to access our Website or use our Programs;
(f) the content of any undeleted cookies that your browser previously accepted from us or delivered to your device via use of our Programs;
(g) technical information, including the address used to connect your device to the Internet, your login information, system and operating system type and version, browser or app version, time zone setting, operating system and platform, and your location (based on IP address);
(h) information about your visit, including products and services you viewed or used, Programs response times, interaction information (such as button presses) and any phone number used to call our customer service number
We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Website or use of our Programs. We may allow third-parties, including our authorized service providers, to access usage information regarding how you use our Programs or our Website. We use all this collected information only to try to understand your preferences better and to manage the load on our servers, so as to improve our service, analyze trends, optimize Programs performance, administer the Website, improve Website performance, and gather broad demographic information for aggregate use. Finally, usage activity information is required to meet legal and regulatory requirements in order to ensure compliance with certain laws requiring medical-related applications to achieve certain performance standards. We do not track the websites that you visit before or after you leave our Website
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 Programs, then when you register for an Account on the Programs Starling Minds may disclose your name, and email address to your Sponsoring Organization for authentication and authorization purposes only. No PHI or other Personal Information generated by your use of the Programs will be disclosed to your Sponsoring Organization unless you have consented to such disclosure.
However, you understand and consent that Assessment Information may be collected, used or disclosed to your Sponsoring Organization for uses consistent with the reason for the Starling Programs are made available by that organization to you; for example, for wellness programs, for claims administration or for ongoing benefits administration.
3.2 Need-to-know disclosure
Only those who “need to know” have access to Personal Information. This includes relevant quality control personnel, Starling Minds developers, and technical support. All Personal Information is stored indefinitely on an encrypted server. All data is backed up daily and a copy is stored securely off-site.
Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the Website and/or Programs, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you – it is only about improving our Website and/or Programs so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
We limit access to all personal information about you to those employees and agents who need to know the information to provide products and services to you.
3.3 Other disclosure
We will not disclose any of your Personal Information (and in particular PHI) to third parties except in the limited circumstances described below, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is disclosed. We disclose information appropriate to the circumstances as determined in our sole unfettered discretion.
(a) We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process whether criminal or civil, including subpoenas from private parties in a civil action.
(c) We may use a third party communication company to communicate with you. We will require such third party to only use your contact information for the purpose of our communications with you and will also require such third party to delete such contact information from their records following the termination of their retainer by Starling Minds
(d) We may share your Personal Information with our authorized service providers that perform certain services on our behalf. These services may include hosting, performing business and sales analysis, supporting our Website and/or Programs functionality, and supporting features offered through our Website and/or Programs. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
(e) We disclose information that we are required by applicable law to disclose to applicable parties including, without limitation, law enforcement authorities, regulators or auditors.
4. CHOICES FOR PERSONAL INFORMATION
5. THIRD PARTY PRIVACY POLICIES
Starling Minds may make available third party hyperlinks or otherwise enable you to access third party products or services from the Programs 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, endorsement of, or affiliation with those people or companies. You recognize and agree that we are not liable for any third parties’ collection or use of your Personal Information and you should review the respective privacy policies of these third parties.
6. DATA STORAGE
Unless otherwise permitted by applicable law, your personal information will be stored and maintained on servers and databases located in Canada or the United States and is subject to regulation under the laws of Canada and the United States.
We retain all records related to messages sent or received via Starling Minds, your personal identification or any other information about you or pertaining to you for as long as you have an Account. When you become a Starling Minds Member, we also retain records and information about you throughout the application process.
Once we terminate your Account, subject to applicable laws requiring us to retain records, Starling Minds will delete any information you have provided to Starling Minds, including, without limitation, any confidential information or personal information of yours. Depending on legal or regulatory requirements (which may require us to retain records for an indefinite period) we may retain Personal Information you provided to us.
You can see what information is deleted and what we continue to store after the Account is disabled by request to firstname.lastname@example.org.
7. ACCESSING YOUR INFORMATION AND EXPORTING IT
You have the ability to review and update your personal information online by logging into your Account. You can also review and update your personal information by contacting us. More information about how to contact us is provided below.
You can disable your Account by request. We can disable it at our discretion. You can permanently disable and/or delete your Account at any time by sending an email to email@example.com. We can terminate or suspend your Account at any time at our discretion.
These terms remain in effect after your Account is disabled.
You can export a copy of content in your Starling Minds Account if you want to back it up or use it with a service outside of Starling Minds. Contact customer support at: firstname.lastname@example.org for assistance in this.
8. INFORMATION SECURITY MEASURE
8.1 Information and Data Security
Information and data security is of paramount importance at Starling Minds. Starling Minds is committed to handling all of your information with applicable industry-standard information security practices. Starling Minds follows these basic principles with respect to data security and data ownership:
a) You own your private data, not us.
b) You can delete your private data from Starling Minds when you want.
c) You can request access to the Personal Information Starling Minds holds about you.
d) You can ask us to rectify or erase Personal Information we hold about you subject only to regulatory record-keeping requirements that may be imposed by governments on us to store personal information or personal health data for prescribed periods of time.
e) We restrict access to your Personal Information to employees who need to know that information in order to provide products or services to you.
f) We maintain other physical, electronic and procedural safeguards that comply with applicable laws to guard your Personal Information.
g) We use what we believe to be “best-of-class” hosting services and security technologies and services that we believe provide you with a secure and safe environment.
h) We encrypt data transmitted to and from the Website and/or Programs.
8.2 Your Responsibilities
The security of your Starling Minds Account also relies on your protection of your password. You may not share your password with anyone. Starling Minds will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Starling Minds websites, at the following URLs: www.starlingminds.com or any of our other sites.
Any email or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL other than those specified within this document should be treated as unauthorized and suspicious and should be reported to Starling Minds immediately. If you do share your Starling Minds password with a third party for any reason, you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please contact us right away.
9. ACCURACY AND ACCESS/CONTROL OVER PERSONAL INFORMATION
You can review the Personal Information you provided us and make changes to some information, or to the settings for your Account, at any time by logging in to your Account and changing your Personal Information.
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 applicable law.
10. CHANGES TO THIS POLICY
11. CONTACT INFORMATION