Your Privacy Is Important To Us
Below are steps Focus takes to ensure your privacy and protection
This Privacy Policy governs how Hasu Behavioural Health Inc., d/b/a Focus Mental Wellness and/or WELL Mental Health & Wellness (“Focus”, “us” or “we”) collects, uses, discloses and otherwise manages your personal information, including your personal health information (collectively, “personal information”). This Privacy Policy applies to our privacy practices on (1) the Focus website located at www.focusmw.com (the “Website”); and (2) all other services provided by Focus, as described on the Website (collectively, the “Platform”).
For information on the general terms and conditions that apply to individuals (the “Terms of Use”) using the Platform and Services (as defined hereafter), please see our Terms of Use. The terms of this Privacy Policy are incorporated into, and considered a part of, the Terms of Use. This Privacy Policy relates to use of the Platform. In the event that any additional or specific terms are inconsistent with the terms contained in this Privacy Policy, such as the terms and conditions prescribed by the Terms of Use, the Terms of Use shall prevail.
The Platform may collect and transmit personal information about you. By accessing the platform, you accept all the terms and conditions of this Privacy Policy. In particular, by submitting your personal data to us, you will be deemed to have given your permission for the use and disclosures referred to herein.
If you do not agree with the terms and conditions of this Privacy Policy, you must immediately cease using and accessing the Platform and any content, services or products contained in or available from the Platform for which you need to provide personal information.
Collection and Use of Personal Information
Focus provides users (“Users”) access to mental health Therapists (“Therapists”) by secure real-time video communication, telephone, text messaging or in person sessions for mental health consultations (“Mental Health Services”), and to support staff (“Support Staff”) for related administrative support services (“Support Services”, and together with Mental Health Services and other services that may be provided by Focus, including group session services, the “Services”). For the purposes of providing Services and purposes consistent with those purposes, Focus and Therapists may collect and use personal information that is provided by clients before or during provision of Services or uploaded by clients to the Platform to complete and update online profiles and personal health histories maintained in secure client user accounts (each, a “User Account”).
Your personal information may include information or records regarding your medical or health history, health status and laboratory testing results, diagnostic images, and other health related information. Your personal information may be contained in medical records, treatment and examination notes, and other health related records maintained by Therapists. Your personal information may also include credit card information and/or bank account information (where provided to us for the purposes of providing the Services). Neither Focus nor Therapists collects or uses personal information for any other purpose than providing and facilitating the provision of Services, and purposes consistent with those purposes, including but not limited to the following:
Providing the Services: you will also need to disclose your personal information to Therapists and Support Staff in order to enable them to provide appropriate Services. You may do so by completing a client profile or online intake form on our website, by talking to or communicating with our Support Staff, or during the course of your interactions with a Therapist. We use your personal information to identify who you are, communicate with you, and otherwise administer your use of the Platform to receive Services.
Processing payments: If you choose to purchase Services, we may collect your payment information such as your name, address, phone number, e-mail address, billing address, and payment method information. This information is used to process and maintain your subscription.
Quality of Care: If you access the Platform or receive Services, your personal information may be used to improve the quality of Services provided by Therapists. Your personal information may also similarly be used to create de identified information such as aggregate statistics relating to the use of the Platform and Services.
Marketing: If you sign up to receive direct marketing or promotional communications from Focus, your non-health personal information (such as your email) may be used to provide information to you regarding product and services that Focus believes may be of interest to you, and to send you information and updates regarding Focus and the products and services we offer;
Quality Assurance and Improvements: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a telephone number) along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service, service offerings, and our Services.
Other Use: We also use the personal information to (i) manage our relationship with you and provide you with the information you requested, (ii) conduct research and evaluate research and development on the Platform including analyzing testing data to improve our services, (iii) communicate with you regarding inquiries for information, service requests, employment opportunities, or appointment reminders, (iv) detect, prevent or investigate security breaches, (v) protect our business against error, fraud, theft and damage, (vi) maintain appropriate records for internal administrative purposes or as required by law.
Disclosure of Personal Information
We will not disclose, trade, rent, sell or otherwise transfer personal information, without consent, except as otherwise set out herein or in our Terms of Use. We may transfer or disclose personal information as follows:
Circle of Care: If you access the Platform or receive Services, your personal information may be disclosed to and among Therapists and Support Staff for the purpose of providing or assisting in the provision of Services to you. Your personal information may be provided to third parties such as other health professionals, specialists, consultants or pharmacists, pharmacies and laboratories for the purpose of providing or assisting in the provision of Services to you, unless you expressly withhold or withdraw your consent.
Service Provider Arrangements: In connection with the provision of our Platform and Services, we may disclose (or otherwise make available) personal information to third parties who provide Services on our behalf. For example, we may use service providers to process payments, host our website and store information on our behalf. Personal information may be maintained and processed by third party service providers in Canada and may be accessed by the courts, law enforcement and national security authorities as required under the laws of this jurisdiction. Our service providers are given the information they need to perform their designated functions, and we only use service providers that ensure a comparable level of protection for your information, as provided in this Privacy Policy. Our contracts with our service providers ensure they comply with that obligation and use your personal information only for the services requested.
Legal: Focus and our affiliates and service providers may disclose personal information to third parties as required or permitted by applicable law. For greater certainty, Focus will disclose your personal information to the extent that it is legally required or necessary for the establishment, exercise or defence of legal claims and legal process; or in the event of an emergency pertaining to your health and/or safety or that of a Therapist. Where a disclosure of our clients’ information is required by applicable law, we promptly notify our client prior to
complying with such requirements (to the extent we are not prohibited from doing so). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Information about Our Services
As you access the Platform or receive Services, certain information may be passively collected by cookies (“Cookies”), navigational data like Uniform Resource Locators (“URLs”) and third party tracking services, including:
Activity Information: We may keep track of some of the actions you take on the Platform, such as the content of searches you perform on the Platform, solely for the purpose of internal evaluation of Platform effectiveness. This information will not be shared with third parties.
Access Device and Browser Information: When you access the Platform from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times (collectively, “Anonymous Information”). We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s).
Cookies: Our Services use a technology called Cookies. A Cookie is a tiny element of data that our Services send to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user when they return. We use Cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a Cookie or to not accept certain cookies. However, if you decide not to accept Cookies from our Platform, you may not be able to take advantage of all of the Platform or Services features.
Third Party Links: Our Platform may contain links to other websites or platforms that Focus does not own or operate. Also, links to our Platform may be featured on third party websites or platforms on which we advertise. Except as provided in this Privacy Policy, we will not provide personal information to these third parties without consent. We provide links to third party websites or platforms as a convenience to the user. These links are not intended as an endorsement of or
referral to the linked websites or platforms. The linked websites or platforms have separate and independent privacy statements, notices and terms of use. We do not have any control over such websites or platforms, and therefore we have no
responsibility or liability for the manner in which the organizations that operate such linked websites or platforms may collect, use or disclose, secure and otherwise treat personal information.
Public Forums: If at any time the Services offer any type of notice board facilities, newsgroups, publicly accessible blogs, community forums, etc. (collectively, the “Public Forums”) we may collect the information that you disclose thereon. Such
information may include, but is not limited to, your name, e-mail address, the messages you write or the content you choose. We may also use this information in order to help administrate the Public Forums. Such information will be used in accordance with this Privacy Policy. Please note that we cannot be responsible for other parties’ use of the personal information which you make available to such third parties through any of the Public Forums.
Security of Personal Information
We understand that data security is a critical issue for our clients and we are committed to safeguarding the personal information in our custody and under our control.
Focus has implemented a comprehensive information security program that includes written policies and procedures, and security controls. We have implemented reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.
Our privacy practices are intended to comply with applicable privacy laws, including, without limitation, the Personal Health Information Protection Act (Ontario) (“PHIPA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). We will maintain the privacy of your personal information as required by applicable privacy laws, including without limitation, PHIPA and PIPEDA and the regulations under those Acts.
Retention
We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
Access to Personal Information
If we receive a request to access or update personal information we have collected on behalf of a particular client, we will direct the party making this request to the relevant client. We will assist our clients wherever possible in responding to such access requests.
If you submit personal information via our Platform or otherwise provide us with your personal information, you may request access, updating or correction of your personal information by submitting a written request to
support@focusmw.com. We may request certain personal information for the purposes of verifying your identity.
De-Identified Information
We may use de-identified information created by us from your personal information without restriction. We may use aggregate data that does not identify an individual for the purposes of research, including academic and non academic research, prospecting new business, artificial intelligence, promotion and advertisement in accordance with applicable law.
Limitation on Deletion
You may request deletion of your personal information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete personal information, it will be deleted from the active database, including from our archives, though we may also retain Anonymous Information about your use of our Platform and Services. Once we disclose some of your personal information to third parties, we may not be able to access that personal information any longer as maintained by the third party and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. After we delete personal information, we will retain de-identified information and will continue to use de identified information without restriction as permitted under this Privacy Policy.
Withdrawal of consent
You can withdraw your consent to us collecting and using your personal information or having your personal information shared with Therapists or other parties at any time by giving us reasonable notice, except where the collection, use or disclosure is authorized or required by law.
Opting out of communications
If you change your mind, you may opt-out of receiving further marketing-related communications by clicking the “unsubscribe” link at the bottom of any email you receive from us or by contacting our Privacy Officer (see the “Contact Us” section at the end of this Policy).
Report Violations
You should report any security violations to us by sending an email to support@focusmw.com.
Changes
This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on the Platform. If we make any substantial changes to this Privacy Policy and the way in which we use your personal data, we will post these changes on this page and will do our best to notify you of any significant changes. Please check our Privacy Policy on a regular basis.
Contact Us
Accountability with respect to your personal information is important to Focus. In the event that you have any questions (including how personal information is managed), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email at support@focusmw.com.
If after contacting us you are still not satisfied, you have the right to file a complaint with your local privacy authority.
Updated: June 18, 2024
