Inkblot Technologies (“Inkblot”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.
The Inkblot website, including offered products and telehealth services, is owned and operated by GreenShield. GreenShield means, collectively, Green Shield Canada (GSC), the Green Shield Association, and Green Shield Holdings Inc., which is the primary company that houses health services and benefits administration subsidiaries, including but not limited to, Inkblot Therapy, Benecaid, Computer Workware Inc., NKS Health and The Health Depot. Green Shield Holdings Inc. is a wholly-owned subsidiary of the not-for-profit Green Shield Association. The Inkblot products and services are operated by the means of an online platform that is accessible to all users on the Inkblot website and the mobile application (collectively referred to as the “Platform”). The Platform includes two components:
- on-demand access to mental health counsellors by secure real-time text and video communication for mental health consultations ("Counselling Services"), and
- support services with access to support staff for related administrative support services ("Support Services").
Once a user has signed up and created an account, the user can choose which components of the Platform they wish to use the Counselling Services or the Support Services, or both.
This policy applies to the Platform and its use. It also applies to GreenShield and all of its affiliates and subsidiaries, as well as their websites, mobile applications, to the extent that any of these entities collect, use of disclose or receive personal information in connection with the operation of the Platform or the services. Different entities in the GreenShield group may have their own websites, mobile applications and services through their own web and mobile platforms that are unrelated to this Platform, which are not subject to this policy. This policy describes:
- How we collect, receive, use, share, disclose, process, and protect the personal information, including personal health information, of our customers (collectively, "you" or “your”);
- The types of information we may collect from you; and
- Our practices for collecting, using, maintaining, protecting, and disclosing that information on the Inkblot website located at www.inkblottherapy.com and all other services provided by Inkblot, as described on the Website, mobile application and activities (collectively, the "Platform").
We will only use your personal information, including personal health information, in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
The methods that we use for collecting, using, disclosing, and retaining Personal Information is consistent and compliant with all applicable federal and provincial privacy laws. This includes, when applicable, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the provincial acts in place in Alberta, British Columbia, and Quebec.
Inkblot also complies, where applicable, with laws concerning the collection, use and disclosure of personal health information, including, without limitation, the Personal Health Information Protection Act (Ontario) ("PHIPA")
Inkblot follows ten privacy principles based on the same privacy principles outlined in PIPEDA and Canadian privacy laws.
Learn more about accountability...
All Inkblot employees and other persons or organizations who act for or on behalf of Inkblot, are responsible for the protection of your information. Our Privacy Officer is responsible for overseeing our privacy program, which includes policies, procedures and staff training to ensure that our employees are adhering to these privacy principles. See section 10 of this policy for the contact information of our Privacy Officer.
- Identifying purposes
We will clearly identify the purposes for which we are collecting Personal Information before or at the time of collection. When we authorize other parties to collect information on our behalf, they do the same.
Learn more about identifying purposes...
We ask for your Personal Information for various purposes related to the operation of the Platform and its Services, as well as to manage our business , including:
- To provide and administer our Services;
- To create and administer your account when you register for our service, including through our website, apps and service providers;
- To operate, maintain, supervise, administer, and enhance the Platform and services offered, including improving quality of care provided by counsellors, monitoring and analyzing the effectiveness of content on the website, mobile application and services offered, aggregate site usage data, and other usage of the website and mobile application such as checking your eligibility and assisting you in completing the registration process;To communicate with health care providers and individuals involved in your care;
- To attend to and manage your requests to us and respond to your inquiries;
- To confirm your identity and the accuracy of your information;
- To retain appropriate records with Inkblot and meet legal and regulatory requirements;
- To contact you by email, telephone calls, SMS, or other forms of electronic communication regarding updates or informative communications related to our products or services.To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you are already purchased or enquired about, unless you have opted not to receive such information;To bill you and collect payment;
- To promote and market our Platform to you.
- To conduct research on users' demographics, interests, and behavior based upon information provided during use of our Websites.
- To anonymize the Personal Information and to use that anonymized information in studies, reports and other programs that we offer;
- To combine Inkblot data with external data for health management purposes or programs that we offer; and
- To facilitate sharing of data to monitor health outcomes.
We may also share non-personal information with third parties, but only to the extent that such information has been properly de-identified and/or aggregated with other information. If we combine your non-personal information with personal information, the combined information will be treated as Personal Information
Where appropriate or legally required, we will describe how your information we collect through this Platform will be used and will provide choices about whether to allow us to engage in that use. To exercise your choice, you may contact us to correct, update, amend, or request deletion of your personal information through the address listed in the Contact Information section below.
We need your consent to collect, use, share and disclose your Personal Information, with some limited exceptions as determined by law. These limited exceptions can include times where legal, medical, or security reasons make it impossible or impractical to seek consent. You can withdraw your consent any time, subject to legal, regulatory, or contractual requirements. See section 10 of this Policy for the contact information of our Privacy Officer. If you do not want to provide us with this information, you do not have to, however, this may limit your ability to use certain functions or to request certain services or information.
Learn more about how we obtain your consent...
Your consent can be either express or implied. Express consent can be verbal or written. For example, when you sign an enrollment form you are giving us written consent to use your Personal Information to provide you and your dependents with benefits.
Consent can be implied or inferred from certain actions. For example, if you present your benefit identification card to a pharmacist/dentist in lieu of paying for a prescription/dental procedure, it can be implied as consent for the pharmacist/dentist to provide your Personal Information to Inkblot to obtain payment for the service rendered, and for Inkblot to process the related claim for payment and provide other services.
Learn more about limited circumstances when we may collect, use or disclose your Personal Information without your consent...
We may collect, use or disclose your Personal Information without your consent in the following limited circumstances:
- With our service providers. Personal Information may be disclosed (or made available) to such organizations or individuals who perform services on our behalf in connection with the provision of our Platform and services, including suppliers, and companies contracted to process payments, host our website and store information on our behalf, direct marketing agents, data processing and storage firms as well as providers of administrative support service. These agents, representatives or organizations must sign a confidentiality agreement which prohibits them from disclosing the information to third parties without obtaining appropriate consent in advance. 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. For more information about the way in which our service providers treat personal information, contact us as set out in section 10 below
- With third parties, at your request or as permitted by law. We may need to share information with companies, organizations, or individuals outside of GreenShield if we have a good faith belief that access, use, preservation, or disclosure of that information is reasonably necessary:
- For emergencies that may threaten your life, health, or security. We will subsequently inform you of this disclosure;
- In connection with the sale, assignment or other transfer of the business of Inkblot to which the information relates, in which case we will require any such buyer to agree to treat it in accordance with this policy;
- For legal reasons. We may be compelled to release your information by a court of law or other legal or regulatory authority. In those instances, we will only disclose the information that we are legally required to provide;
- For the purposes of investigating a breach of an agreement or a contravention of laws that has been, is being, or is about to be committed and it is reasonable to expect that disclosure with your knowledge or consent would compromise the investigation; and
- For the purposes of detecting or suppressing fraud or of preventing fraud that is likely to be committed and it is reasonable to expect that the disclosure with your knowledge or consent would compromise the ability to prevent, detect or suppress the fraud. In accordance with provisions provided for in the Personal Information Protection and Electronic Documents Act and other provincial privacy law, where applicable, including laws concerning personal health information.
Learn more about how to withdraw your consent...
You may withdraw your consent for us to collect, use, keep, or disclose your Personal Information, subject to legal or contractual restrictions and reasonable notice. However, withdrawing your consent, may impact our ability to provide you with certain services and products. You can also choose to close your account at any time. Upon receipt of your request, we will proceed to close your account promptly and will confirm with you by email when this is completed. Please note that once your account is closed, we need to retain certain Personal Information for a period of time necessary to meet our legal, regulatory, or contractual obligations. For more information on our retention practices, please see section 5 below.
- Limiting collection
We will limit the collection of your Personal Information to that which is needed for the purposes identified by us or as otherwise permitted by law.
Learn more about the information we collect...
Depending on the product or service, we may collect or receive Personal Information about you , including:
- First, Last Name, date of birth, gender;
- Address, postal code, email address, phone number(s), provincial government health ID (e.g. Ontario Health Insurance Plan); user ID/authentication;
- Payment information including your billing address, and payment method information;
- Medical or health information, including your health card number, health history and conditions, underlying diagnosis, laboratory testing results, diagnostic images, and other health related information.
- Interaction and relationship data information with us, such as telephone recordings, communications (CRM data, emails, letters etc);
- Electronic/digital information such as geolocation, IP address, tracker, activities on our website/app etc; and
- Your account and profile information, including password management and security questions and answers, as well as the services you choose to purchase and use.
- How you use our products and services, including through our websites and other electronic means, and your preferences for certain products, demographics, interests and lifestyle activities.
Learn more about where we collect or receive your Personal Information from...
We may collect or receive Personal Information from:
- Completed applications and forms;
- Your interactions with us, including engaging with us over social media and through surveys;
- Your telehealth consultations;
- Updates to your online profile and other information that is maintained in your client user account;
- Your medical records, treatment and examination notes, and other health related records maintained by Counsellors;
- Your doctor, pharmacist and/or other medical and health professionals responsible for your care;
- Medical facilities or providers;
- Professional regulatory bodies (e.g. College of Pharmacists) and governmental agencies.
- Limiting use, retention and disclosure
We will only use or disclose Personal Information for the purposes for which it was collected and consented to, or as otherwise required by law. We will keep the Personal Information to meet our contractual obligations to you and for as long as your User Account is active, it is useful to fulfill our commercial purposes, or as long as it is necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. All medical records will be retained pursuant to the retention guidelines dictated by each province. We may also retain de-identified and/or aggregate information beyond this time for research purposes and to help us develop and improve our services, and as described more fully in this policy. You cannot be identified from de-identified and/or aggregate information retained or used for these purposes.
Learn more about how we disclose Personal Information...
Depending on the product or service, we may disclose Personal Information to:
- People, healthcare providers and other parties we work with to administer the products and services we provide;
- Authorized employees, agents and representatives who need the information to complete their duties for us;
- Your counsellor and any health care professional direct or indirect involved in your care, and their employees;
- Any person or third party organization you give consent to;
- People who are legally authorized to view your Personal Information;
- Other entities within GreenShield;
- Service providers who need this information to perform their services for us. Examples of the services include: data processing, data storage, processing payments, printing and distribution services, mental health management programs; and
- People, organizations, and investigative bodies who work to prevent, detect, or investigate suspected fraud, breaches of agreement, or contravention of law.
Learn more about how long we keep your Personal Information...
We keep your Personal Information as loas we need to for managing the products and services, we provide you and for a reasonable time thereafter in order to meet our legal, regulatory and tax requirements. We have retention standards, which meet these requirements. We destroy your Personal Information when we no longer need to retain it, or we anonymize the information.
We will endeavour to ensure Personal Information under our control is accurate, complete, and as up-to-date as possible in order to properly satisfy the purposes for which it is to be used.
Learn more about accuracy...
You can check your Personal Information to verify its accuracy. You can correct, amend or update the information you provide us by logging into your user account and making the updates to your profile information. For the information that we hold about you which you cannot access through your user account, you can access by emailing us at email@example.com. There is no charge for verifying your Personal Information; however, depending on the circumstances, there may be a minimal charge for the retrieval of Personal Information that you request. We will inform you if there is a charge.
We will assist you in identifying the appropriate means to have the correction(s) made and whenever possible, we will correct any Personal Information which we may have given to an outside organization. If a third party has given us Personal Information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information directly with them. To the extent that you are not satisfied with our response to your request, you can contact our Privacy Office as provided in the section below. If our Privacy Office does not fully address your concerns, you can also bring this matter to the attention of the Office of the Privacy Commissioner of Canada whose contact information is also provided below.
To protect your Personal Information from intrusion, release or misuse, we will use appropriate physical, administrative and technological safeguards that match the sensitivity of the information under our control
Learn more about safeguards...
Our employees who have access to your Personal Information are made aware of how to keep it confidential. As a condition of employment with Inkblot, all employees sign an agreement requiring all information that they have access to be treated confidentially. They are also required to participate in annual security and privacy awareness training programs. We have security standards to protect our systems and your Personal Information against unauthorized access and use. This protects your Personal Information at all times when it is stored in data files or handled by our employees.
Your Personal Information will be kept in a secure environment using appropriate technical, physical and organizational measures designed to protect the information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as other forms of unlawful processing until it is no longer needed for the administration of the benefits plan, or as long as necessary for record retention and legal compliance purposes.
Although the sharing of Personal Information is inherently risky, we implement commercially-acceptable procedures to ensure our systems are secure. We will notify you in the event of a systems security breach resulting in the unauthorized release of your Personal Information where we assess a real risk of significant harm to you or your dependents.
We will make information about our policies and procedures and how we manage your Personal Information available to you. In order to make a written request, see section 10 of this policy for the contact information of our Privacy Officer.
- Individual access
If you send us a written request, we will tell you what Personal Information about you we have and how we use and disclose it. We give you access to the information, with certain exceptions allowed by law. You may verify the accuracy and completeness of your information and request changes, if appropriate.
Please note that we may not be able to provide information about you from our records if it:
- is prohibitively costly to provide;
- contains references to other individuals;
- cannot be disclosed for legal, security or commercial proprietary reasons;
- is subject to solicitor-client or litigation privilege; or
- cannot be disclosed for any other reason.
- Questions, concerns or inquiries
We are committed to answering and resolving any privacy related questions, concerns and inquiries.
Please feel free to contact Inkblot’s Privacy Officer:
- By email: firstname.lastname@example.org
- By mail: Privacy Officer
Green Shield Canada
5140 Yonge St., Suite 2100
The Inkblot Privacy Office will acknowledge receipt of your enquiry. Within 30 days of receiving your enquiry, Inkblot’s Privacy Officer will write or call to tell you if the problem has been resolved, or, in more complex cases, advise you what further steps are being taken and when you may expect a resolution.
If your concern remains unresolved, please contact:
- Office of the Privacy Commissioner of Canada
30 Victoria Street
- Telephone: 1-819-994-5444
- Toll Free: 1-800-282-1376
- Fax: 1-819-994-6591
- Website: www.priv.gc.ca
You may also contact your provincial office of the information and Privacy Commissioner for more information. If your province of residence is Ontario, you also have a right to make a complaint to the Information and Privacy Commissioner of Ontario who can be contacted at:
- Information and Privacy Commissioner of Ontario
2 Bloor Street East,
- Telephone: 1-416-326-3333
- Toll Free: 1-800-387-0073
- Website: www.ipc.on.ca
Changes to this Policy
Cookies and Mobile Services
This Website is not intended for any user under the age of 15 and we do not knowingly allow individuals under the age of 15 to create their own user account. Individuals under the age of 15 may access the Platform or receive services at the discretion of counsellors using their parent or legal guardian’s user account and in the presence of that parent or legal guardian. Inkblot does not intentionally collect Personal Information from children under the age of 15. We request children under the age of 15 to refrain from using the Platform and submitting any Personal Information.
Your Personal Information may be transferred to and/or stored in another province where we or our service providers operate, including Ontario. Your Personal Information is not stored outside of Canada. By using the Platform, you agree to the cross-border transfer of your Personal Information and understand that it may be available to government authorities under lawful orders and laws applicable in the foreign jurisdiction. Inkblot and GreenShield will strive to protect your Personal Information disclosed to third parties by contractual agreements requiring that those third parties adhere to confidentiality and security procedures and protections.
You can contact us directly any time at the address listed in the Contact Information section below to update your personal information or make another type of request regarding the information you know or believe Inkblot holds about you. Here are some rights that you may have according to where you are located:
Subject to applicable law, you have the right to receive information about, and review in person, or obtain copies of, the Personal Information we maintain about you. We may charge you a reasonable fee as allowed by law to obtain this information.
- Amendment or Deletion
Subject to applicable law, 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 de-identified 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 policy.
- Data Processing Use and Objection
Subject to applicable law, you have the right to request we restrict our use or disclosure of your Personal Information for certain purposes. You also have the right to object to the processing of your personal information. We may not be required to agree to a requested restriction or objection. We will agree to restrict use, or disclosure of, your personal information provided the law allows it and we determine the restriction does not impact our ability to operate our business, provide diagnostic services, and comply with the law. Subject to applicable law, even when we agree to a restriction request, we may still disclose your personal information in a medical emergency and use or disclose your personal information for public health, safety and other similar public benefit purposes permitted or required by law.
- Automated Decision Making
Subject to applicable law, if at any time the Platform uses automated decision making to process Personal Information, you have the right to object to the use of your personal information.
- Withdraw your consent
Subject to applicable law, you may withdraw your consent to our processing of your Personal Information. Your withdrawal does not invalidate the consent-based processing that have occurred prior to withdrawal.
Please note that these rights may be limited in some circumstances by local law requirements or contractual restrictions.
Inkblot shall provide you with a response to any such request(s) without undue delay and in any event within 30 days of receipt of the request. That period may be extended by 30 days where necessary, taking into account the complexity and number of request(s). Inkblot shall inform you of any such extension within 30 days of receipt of the request, together with the reason(s) for the delay. If you make the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by you in written documentation.
- Data Portability
Subject to applicable law, you have the right to receive your Personal Information in a structured, commonly used, and machine-readable format.