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 Service (an “Account”), we may collect and store the Personal Information that you provide us, anand employment identification number and other unique organization or insurance plan 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 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 Service (together, the “Assessment Information”) to provide you with assessments, scores, educational tools, and other meaningful use of the Service as well as tailored and relevant mental health information.
NOTE: If your organization (“Organization”) is paying for your access to the Service, your name and Unique Identifier may be sent to the Organization for billing and administrative purposes. No other Personal Information collected (including frequency of use, Assessment Information, or your use of educational tools) will be shared with your Organization, unless you have specifically consented to such disclosure.
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, 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 your use of the Service, including Assessment Information, that has been aggregated and de-personalized.
When you access or use the Service, we may use “cookies” 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 User Generated Comments
You should be aware of the open nature of certain features of the Service that we may make available to you such as user-generated content such as comments and quotes (“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 Service after it has been de-personalized and stripped of your Account information.
2.2.6 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.
2.2.7 Trusted Partners and Sponsored Companies and Organizations
We may use and disclose to our 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 may 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 Personal 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
3.3 Administering our Business
We have relationships with third party service providers who help us provide services to you such as administering our business, including administrative and billing matters, and designing, maintaining and improving the Services, the Starling Minds’ platform, and our systems and computer security.
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 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, 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.
7. INFORMATION SECURITY MEASURES
Starling Minds is committed to taking appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your 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.
Although we will make commercially reasonable efforts to protect your Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is some risk that an unauthorized third party could thwart our security systems. This risk is higher if you are accessing the Services utilizing an unsecured, public Wi-Fi.
8. ACCURACY AND ACCESS/CONTROL OVER PERSONAL INFORMATION
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 at email@example.com.
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.
9. 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. When your Personal Information is no longer required to be maintained, it will be destroyed or de-personalized in accordance with applicable laws.
10. CHANGES TO THIS POLICY
11. CONTACT INFORMATION
Should you have any questions relating to this Policy, please send correspondence to firstname.lastname@example.org.