Last Updated: July 28, 2022
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:
The security of your Starling Minds Account also relies on your protection of your password. You may not share your password with anyone. Starling Mindswill 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 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.
Below are more details on how we collect, process and use data. If you received a referral from a case manager or a health-care worker for a Starling Program, please pay particular attention to section 4.1
Any data that has been collected in which all personal identifiers have been removed, such that the information could not reasonably be used to identify the individual, is not considered Personal Information or PHI.
When you register for an account on the Programs (an “Account”), we may collect and store the Personal Information that you provide us. We may also collect an employment identification number and other unique organization or insurance plan number, if applicable. This information will be stored and encrypted and a new, unique number will be generated within the program. This new number becomes your unique, anonymized ID.
When you complete assessments, questionnaires, evaluations, exercises, therapy modules, or otherwise enter information in, 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, all of this is PHI) to provide you with assessments, scores, educational tools, and other meaningful use of the Programs as well as tailored and relevant mental health information.
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 laws and/or regulations.
We 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 or functionality, 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 the 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.
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, you will be given notice of how the information will be used prior to your participation in the survey or questionnaire.
If you give us permission, we may contact you for a follow-up in connection with survey results.
We may also collect, use and disclose non-Personal Information that does not directly identify you as follows:
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.
You should be aware of the open nature of certain features of the Programs that we may make available to you 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. 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. At Starling’s sole discretion, any Submissions you make which contain Personal Information or PHI may be deleted, either in whole or in part.
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.
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 Progress Reports, 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.
Due to the technical nature of web-browsing, when you visit our Website or use Programs from us, we obtain the following information:
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 Program 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.
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 collect your Member ID and disclose such 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 for Programs which you were not directly referred to.
If you were directly referred to a Program, you understand and consent that your PHI may be collected, used or disclosed to a representative of your Sponsoring Organization for uses consistent with the reason for which the Starling Programs are made available by that organization to you; for example, for wellness programs, for claims administration or for ongoing benefits administration. These representatives may be employed by your Sponsoring Organization or by an organization contracted to provide services to you and may include, for example, a case manager, a psychologist, a therapist or psychiatrist.
Only those who “need to know” have access to Personal Information and/or your PHI. This includes relevant quality control personnel, some 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.
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.
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.
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.
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 email@example.com.
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.
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.
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 firstname.lastname@example.org. 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: email@example.com for assistance in this.