Your Privacy Is Important To Us
Below are steps Focus takes to ensure your privacy and protection
Collection and Use of Personal Information
Focus provides users (“Users”) access to mental health Therapists (“Therapists”) by secure real-time video communication, telephone or text messaging 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, “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 we have your consent to do so, 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 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.
Disclosure of Personal Information
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, with your prior written 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 do not authorize them to use or disclose personal information for their own marketing or other purposes.
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).
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.
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 email@example.com. We may request certain personal information for the purposes of verifying your identity.
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
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 we have your consent to do so, we may from time to time send you marketing-related 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).
You should report any security violations to us by sending an email to firstname.lastname@example.org.