This Privacy Policy governs how HAUS&HAUS INC., d/b/a NEWSELF, (“NEWSELF”, “us” or “we”) collects, uses, discloses and otherwise manages your personal information, including your personal health information (collectively, “personal information”). The term “you” or “User” refers to the person or entity visiting the Platform, browsing or otherwise using the Platform, or receiving any Services. A copy of these Terms of Use may be downloaded, saved and printed for your reference. This Privacy Policy applies to our privacy practices on (1) the NEWSELF website located at www.NEWSELF.ca (the “Website”); and (2) all other services provided by NEWSELF, as described on the Website (collectively, the “Platform”).

For information on the general terms and conditions that apply to individuals using the Platform and Services, please see our Terms of Use[PG1] . 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.

When accessing the Platform and Services, you will be required to read and agree to our Terms of Use and Privacy Policy prior to using the Platform. By accessing the Platform you consent to the collection, use and retention of your personal information according to the terms of this Policy and in compliance with the applicable privacy laws and regulations. You have a choice to withhold or withdraw your consent for processing of your personal information, but sometimes this is not possible because of legal or contractual requirements. Additionally, withdrawing your consent may limit your access to the Services, products and functionalities of our Platform.

You acknowledge that by submitting your personal data to us, you will be deemed to have given your permission for the use and disclosures referred to herein. We may also request your express consent for the use of your personal information. To collect, use or disclose personal information outside of the purposes contemplated in this Policy, we will seek your additional consent.

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.

Children may provide personal information on our Platform only with the consent of their legal guardian. Once the consent of the legal guardian is received, we will collect, use and process all personal information collected in accordance with this Policy. Any access or change to any personal information of children will be given to the parent entitled to the information or the legal guardian only. We may request any relevant documentation from the parent or legal guardian, such as a copy of any custody and access agreement or any related court order, to proceed with any access or change requests. In some jurisdictions, if a User is under the age of majority, the Therapist will determine whether the patient is a mature minor with the capacity to provide informed consent. If the User is not a mature minor, the Therapist will seek informed consent from his or her legal guardian, in accordance with the applicable Privacy Laws.

Accountability

We take the appropriate steps to ensure that we comply with applicable privacy laws of the personal information we collect about you.  We maintain technical, physical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. We limit access to those who have a business need to know. Specifically, we are accountable for:

• developing a governance structure that promotes and values privacy and that enables every one of our team members to make the right decisions, every day, about how to respect privacy when handling personal information;

• ensuring we have in place an outsourcing procedure including identify, assess and contract for security safeguards with service providers that process personal information on our behalf;

• ensuring that we properly identify and mitigate privacy risks throughout our operations, in part by striving to apply the principles of Privacy by Design in the development and review of our products and services, including where necessary conducting privacy impact assessments; and

• earning and maintaining our Users, customers’ and team members’ trust by being transparent about how we handle personal information including personal health information of our Users and by offering choices where it is appropriate to do so.

Collection and Use of Personal Information

NEWSELF provides Users with access to licensed mental health professionals (herein referred to as “Therapists”) by matching Users with Therapists and facilitating secure video communication, telephone or text messaging for mental health consultations (“Mental Health Services”). NEWSELF also provides support staff (“Support Staff”) for related administrative support services (“Support Services”), as well as education and counseling services, self-guided mental health and wellness resources, and other services that may be provided by NEWSELF (collectively referred to as the “Services”).

For the purposes of providing Services and purposes consistent with those purposes, NEWSELF and Therapists may collect and use personal information that is provided by Users before or during provision of Services or uploaded by Users to the Platform to complete and update online profiles and personal health histories maintained in secure client user accounts (each, a “User Account”).

We collect and use several types of information about you, which is collected from various sources:

Information you provide when you create an account on our Platform. During the creation of your account, we ask you to provide personal information that we can reasonably use to identify you and contact you when needed, such as your name, date of birth, mailing address, e-mail address, telephone number, employer, and health plan entitlement. When you create a profile for your dependant(s) or family members, the same information may be collected.[PG2] 

Information you provide when you access and use the Platform and when you receive Services. When you access and use the Platform, you can provide the following type of information, which may be considered personal information:

1. when necessary to the provision of the Services, your health card number;[PG3] 

2. all personal health information about your physical and mental health you may disclose through the Platform, to the Support Staff and to the Therapist that is relevant to identify you, assessing your needs or to establish your treatment plan, such as symptoms, medical history, medication, Therapist observations, appointment history, diagnosis, investigation results and treatment information;[PG4] 

3. all personal information regarding your personal, familial, financial or legal situation (including your employment situation and career goals) you may disclose through the Platform that is relevant to the provision of Services.

Information you share for Identification: You will have the opportunity to provide us with a photo of your health insurance card or if it does not include a photo identifying you, a piece of identification issued by a government authority with a photo, to allow us to identify you when providing mental health care.[PG5] [PG6] 

Information you share for making or receiving payment through our Platform. The Platform enables the collection of payment card information in a wallet managed by a technology service provider. Any transaction information including your credit card or banking information or other financial data in order to process the payment will be collected and processed by a PCI-compliant [PG7] third-party provider.

Personal Information you share when you contact us, or provide feedback in surveys and questionnaires. We also collect the information you provide to us when you contact us or send us questions, comments, suggestions or complaints, including your contact information and information about your inquiry that is necessary in order to address it or to respond to you.

Personal Information collected via the Platform. We may collect personal information from you through our Platform. We may collect this information directly (for example, information about your height, weight and lifestyle which you provide manually through our Platform) or from connected fitness tracker accounts.

Information collected via your connected accounts. Our Platform also lets you connect certain fitness or other health and well-being accounts that you have with third-party providers. If you choose to connect an account you have with a third-party provider (a “connected account”), we will indicate what information we will import from it before you connect it. If you agree, we will then access the connected account and import the information from that connected account into our Platform (going back to the date you first opened the logged in NEWSELF account).[PG8] 

Depending on the information contained in the connected account, this could include data collected from connected trackers or devices, such as:[PG9] 

• Number of steps taken

• Activities/exercise (i.e. swimming, running, walking, hiking, workout, cycling distances)

• Weight

• Blood Pressure

• Calories Burned

• Sleep

• Food and Drink

• Heart Rate

• Body Temperature

• Locations

Information we may collect from third party service providers. [PG10] 

How we use your personal information:

We may use information that we collect about you or that you provide to us, including any personal information for the following purposes listed in this Privacy Policy or as permitted or required under applicable privacy laws and regulations:

To provide you with access to our Platform and our services. We may use your personal information to provide you with access to our Platform and to any information, products, or services that you request from us. More specifically we may use your personal information:

• To determine your eligibility to access the Platform and our services

• To create and administer your User account when you register on our Platform;

• To communicate with you with respect to the Platform registration and your account and respond to your inquiries on the Platform or our products and services offering in general;

• To match you with a Therapist;

• To present Services and resources available to you.[PG11] 

To administer our business activities. We may use your personal information for reasons in connection with our business activities, including but not limited to:

• To carry out our obligations and enforce our rights arising from any contracts we may have with you, notably our Terms of Use, including for billing and collection or to comply with legal requirements;

• To implement and maintain safeguards that protect your personal information.

To support our mental health services providers in the administration of their professional and legislative obligations. In order to provide you with our Services, we may contract with Therapists who are subject to various professional and legislative requirements pertaining to the protection of your personal information and personal health information.

In many provinces in Canada, where certain health services providers are designated custodians of the health information they collect, Therapists have overall responsibility for the privacy of your Personal Health Information. Under applicable Canadian personal health information laws, custodians who receives and uses health information is responsible for ensuring that such information is protected, used and disclosed appropriately. NEWSELF assists Therapists with that responsibility to take the necessary steps to ensure they are equipped to meet all the statutory requirements they are subject to under the applicable laws and regulations.

By way of example, in Ontario, custodians retain ultimate accountability for the management and protection of the Personal Health Information they collect from you. As an affiliate of these custodians, we provide them with services to help administer their obligations under applicable privacy laws. To this end, custodians may provide us with access to your personal information, without seeking further consent from you, to enable us to adequately support them, all in compliance with the provisions of the Personal Health Information Act (PHIPA) and its regulation. For more information on our privacy program management, please contact us at info@newself.ca.[PG12] [PG13] 

To communicate with you and to respond to your inquiries or requests. We may use your personal information to communicate with you on several occasions including:

• To notify you about new products or services releases, new partnerships and other key information on NEWSELF;

• To notify you about changes to our Platform or any products or services we offer or provide through it;

• To provide you with useful mental health information and other information about trends and best practices in mental health and well-being and other relevant topics in connection with our Services;

For study, research and statistical purposes. We may use your personal information for research, research and statistical purposes, including for medical research purposes, to improve our Platform, products or services, marketing or customer relationships and experiences and improve health outcomes. For example, we can create statistics to demonstrate the usefulness of our Platform or conduct research to determine how to improve certain services and develop new ones. When required by law, we use pseudonymized or anonymized information to achieve these purposes.

We may also combine your pseudonymized personal information with other pseudonymized information we receive from your employer or insurer for our internal data analysis purposes (for example, to understand and demonstrate the use and utility of our services) and to create pseudonymized, aggregated reports that do not allow your identification. We may share such de-identified information or insights with our partners to assist in research, planning, or product and service development.[PG14] 

We may collect and analyze information about the actions you take on our Platform or the usage of our Services to better understand what services to provide and product needs. We analyze Personal Information account profile and actions you take on the Platform (such as your usage patterns) and your ratings or responses to surveys, to better understand how we can improve.

We may also 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 laws.  

To improve our services, marketing and customer relationship management. We may use your personal information to provide you with personalized content and services, such as tailoring our products and services, our digital experience and offerings, and deciding which offers or promotions to show you on our digital channels.

We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online support services) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you.[PG15] 

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 us at info@newself.ca.

For 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. We also collect the information you provide to us when providing feedback in surveys.

For other purposes. We may use your personal information to protect you, our rights, property and safety and those of our employees, customers and the public, to detect and prevent fraud and to comply with legal requirements.  

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:[PG16] 

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[PG17] . 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.[PG18] 

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. NEWSELF and our affiliates and service providers may disclose personal information to third parties as required or permitted by applicable law. For greater certainty, NEWSELF 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 User’s information is required by applicable law, we promptly notify the User 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.

Technical information. such as your login information, your geo-location information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.

Digital interaction information. Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

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. For more information on this, please see our Cookie Policy[PG19] .

Flash Cookies. Certain features of our Website or our App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies.

Web Beacons. Pages of our Platform may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit NEWSELF, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Links. Our Platform may contain links to other websites or platforms that NEWSELF 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 Users and we are committed to safeguarding the personal information in our custody and under our control.

NEWSELF 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, 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. NEWSELF retains personal information only for as long as necessary to fulfill the purposes for which this information was originally collected unless further retention is required for legitimate legal, regulatory or business purposes. When personal information is no longer required to be retained, NEWSELF will securely destroy, erase or anonymize the information in compliance with relevant legal, regulatory and contractual requirements.

For any deletion request, please follow the deletion request procedure in the Platform or contact us at info@newself.ca, and we will let you know if we can accommodate your request. 

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 Users 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 info@newself.ca. We may request certain personal information for the purposes of verifying your identity.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable privacy laws may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

You currently will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

If you are concerned about our response or would like to correct the information provided, you may contact us at info@newself.ca.

Request the transfer of your personal information to another organization

In certain circumstances, you may be able to request to receive the personal information that you provided to us in a structured, commonly used and machine-readable format and to transmit it to another organization  

Request additional information about data processing

You can request additional information about data processing, including the personal information collected and how it is processed by NEWSELF.

Request information on automated processing of personal information to render a decision

You may obtain information on the personal information used to render the decision (and request that this information be correct) and the reasons, principal factors and parameters that led to the decision.

Push Notifications

We may send you push notifications via our App related to certain of our services. If you no longer wish to receive push notifications, you can opt out by changing your preferences in the App or by sending us an email stating your request to info@newself.ca.

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.  

Storage of your data

NEWSELF provides its Services to Canadian residents only but some elements of the Services may be hosted on servers located in countries outside your province of residence. NEWSELF Platform hosts personal information in Canada and in European Economic Area (EEA). We transfer your personal information to our service providers globally.

We also use service providers who may access or store other Personal Information in Canada, European Union, the United States or other jurisdictions[PG20] 

The laws applicable to the protection of personal information in such countries may be different than from those applicable in your home country or province and may permit or require disclosure of the data to the law enforcement or national security authorities. Where required by law, or where NEWSELF determine there is a heightened risk to the User in transferring of their personal information outside of their province or territory, country, or region NEWSELF has implemented processes and procedures to undertake a privacy impact assessment.

How we keep information secure[PG21] 

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Such measures include:

• Secure Storage: NEWSELF protects our systems and your data within industry-leading, accredited data centers. All personal information and are in data center which adheres to global privacy and data protection best practices.

• Network Security: NEWSELF has implemented network security controls to protect against unauthorized access, including segregating its internal systems from its publicly accessible systems.

• End-to-End Encryption: NEWSELF encrypts all video, audio and written exchanges with you. Data transmissions and communications on the Platform are end-to-end encrypted.

• Strict limitations on access: we strictly limit access to your personal information to just those employees, contractors and trusted third parties who have a business need to access it, and they are all subject to binding contractual confidentiality obligations.

• Privacy Policies and Training: NEWSELF has implemented written policies, practices and procedures that specifically address the privacy and security of your personal information and PHI. NEWSELF delivers privacy training to employees and contractors on how to safeguard personal information and mitigate operational risks. All NEWSELF employees and contractors are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this 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.

Report Violations

You should report any security violations to us by sending an email to info@newself.ca.

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.

Data Protection Authority

You have the right to make a complaint at any time to the supervisory authority/privacy regulator of your own province of residence.

For Canadian privacy commissioner contact details see the below list:

• Alberta: www.oipc.ab.ca

• British Columbia: www.oipc.bc.ca

• Manitoba: www.ombudsman.mb.ca

• New Brunswick: https://oic-bci.ca/

• Newfoundland and Labrador: www.oipc.nl.ca

• Northwest Territories: https://atipp-nt.ca/

• Nova Scotia: https://oipc.novascotia.ca/

• Nunavut: https://atipp-nu.ca/

• Ontario: www.ipc.on.ca

• Prince Edward Island: https://www.assembly.pe.ca/

• Québec: www.cai.gouv.qc.ca

• Saskatchewan: https://oipc.sk.ca/

• Yukon: https://www.ombudsman.yk.ca/

• Federal: https://www.priv.gc.ca/

We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please do get in touch using the details in our Contact us section below.

Contact Us

If you would like to contact NEWSELF about our Privacy Policy, you can do so by contacting us by emailing info@newself.ca.