Privacy Policy for Individuals
Effective date: April 29, 2025
Your privacy is of the utmost importance to Kii Health (Santé) Canada Inc. (“Kii Health”, “we”, “us”, “our”), HumanaCare Organizational Resources Inc. (“HumanaCare”) and Kii Health (Santé)'s other subsidiaries, divisions and affiliates (“we”, “us” or “our”, as appropriate). This privacy policy (“Privacy Policy”) aims to give you information on how we collect and process your Personal Information in connection with our Services (all capitalized terms defined below).
PLEASE NOTE: For each of the Services, we will provide you with a Consent outlining the details of how we collect, use and disclose your Personal Information (all capitalized terms defined below) as described in this Policy.
This Policy applies only to the Personal Information that we collect in connection with providing you the Services through the Platform (all capitalized terms defined below). The Policy DOES NOT apply to information that you provide to, or is collected by, any third party.
Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms & Conditions for Individuals and any Consent.
What types of Personal Information do we collect?
How do we use Personal Information?
How do we disclose Personal Information?
Accessing Personal information
Changes to This Privacy policy
“Consent” means any consent you have provided us to collect, use or disclose your Personal Information in connection with providing you access to or use of the Platform or Services.
“Personal Information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, social insurance number, gender, income and family status. Personal Information includes personal health information.
“Platform” refers to our Snapclarity mobile App and web-based application.
“Service Provider” means any natural or legal person who processes Personal Information on our behalf. We may use the services of various Service Providers in order to process your data more effectively, as explained further below.
“Services” means the services that we may provide you, including an online mental health assessment and care plan (“Assessment”), following which you may engage in either:
a. Services that provide you with access to mental health counsellors and therapists (“Therapists”) by secure real-time text and video communication for mental health consultations (“Therapy Services”); or
b. Services that connect you with mental health coaches (“Coaches”) for the creation of a customized wellness plan (“Wellness Plan”) and navigation to services available within the healthcare system (“Coaching Services”)
(Therapy Services and Coaching Services, collectively, “Services”).
We require certain Personal Information in order to perform the Services. In particular, we will collect the following types of Personal Information:
- Registration information, such as full name, date of birth, email address, mobile phone number and preferred language spoken (English/French);
- Responses to the questions asked as part of the Assessment;
- Information you may provide to help match you with a treatment provider;
- In the case of Therapy Services, payment-related information if you engage in our Therapy Services through the Platform; and
- In the case of Coaching Services, information you may provide to a Coach to assist in developing a Wellness Plan (for more information on the Wellness Plan, see below).
PLEASE NOTE: In the course of receiving Therapy Services, any information you share with your Therapist will remain confidential between you and the Therapist, as outlined and described in the Consent you sign prior to engaging in Therapy Services. That information will not be shared with us and is not governed by this Privacy Policy.
We use your Personal Information in order to provide you with the Services and to improve those Services. Specifically, following the completion of your Assessment, we may use your Personal Information in the following ways:
- To provide you with mental health service recommendations, which can include recommended therapies and life interventions;
- To provide you with a Wellness Plan, which can include personalized information about services available to you within the healthcare system, health education material and articles and services that may be available to you through your employee benefit program;
- To match you with recommended treatment providers, in your area or available virtually, which you may or may not choose to pursue;
- To provide health education material and articles with information relevant to the issues identified in your Assessment; and
- To provide follow-up communications and invite you to complete a reassessment, if you choose to participate.
We may disclose your Personal Information in order to provide you with the Services and to improve those Services. Specifically, we may disclose your Personal Information in the following ways:
- In the case of Therapy Services,
o To and among Therapists and specific, authorized administrative staff to provide or assist in the coordination of Therapy Services for you; and
o With your prior written consent, to third parties such as other health professionals, specialists, consultants or pharmacists, pharmacies and laboratories to provide or assist in your further treatment, as applicable.
- In the case of Coaching Services, among Coaches and specific, authorized administrative staff to create and update your Wellness Plan.
- We may disclose your Personal Information to specific, authorized Kii Health (Santé) management personnel for the purpose of managing the Services. Specifically, certain Personal Information may be shared with such personnel for the purposes of:
o Assessing and improving the quality of Services provided;
o Monitoring the rate of participation in the Services; and
o Responding to inquiries regarding related to participant experience.
- If the Services are offered as a benefit by your employer, de-identified and aggregated information may be shared with your employer sponsored benefit provider for the purposes of monitoring the utilization and effectiveness of the Services. Information is only shared in accordance with the Consent you sign at the beginning of the Services.
Service Providers
We may disclose your Personal Information to Service Providers, who provide services on our behalf in connection with the provision of our Services.
For example, we may provide paid products within the Therapy Services. In that case, we use third-party services for payment processing (e.g. payment processors). The payment processor we work with is Stripe. The only type of Personal Information shared with Stripe is payment-related information, such as name and credit card number. Stripe may process and store your payment-related information outside of Canada, including in the United States, and therefore may be available to the courts, law enforcement or other government authorities of the foreign jurisdiction under lawful orders and laws applicable there. For more information, please visit Stripe’s Privacy Policy at https://stripe.com/en-ca/privacy#how-we-use-personal-data .
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 the “Contact Us” section below.
In addition, we may disclose Personal Information in the following circumstances:
- Sale of Business: We may transfer Personal Information as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Kii Health (Santé) or as part of a corporate reorganization or other change in corporate control.
- Legal: We may disclose Personal Information to third parties as required or permitted by applicable law. For greater certainty, we 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 about your health and safety or that of someone else. Where applicable law requires a disclosure of your Personal Information, we notify you as soon as reasonably practicable 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.
- Contacting You: We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein and in the Consents.
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
We have implemented a comprehensive information security program that includes written policies and procedures, and security controls. We have implemented reasonable administrative, technical and physical safeguards 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) and the Personal Information Protection and Electronic Documents Act (Canada). Access to Personal Information is restricted to authorized personnel who require such information to properly perform their duties, and access is limited to only that information that is strictly necessary for the performance of those duties. Further, we contractually require that our Service Providers implement similar safeguards to protect your Personal Information.
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Services do not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.
To ensure that your Personal Information held by us is accurate, complete, and up-to-date, you may request to access, correct, and update any such Personal Information. Any such request should be addressed to our Privacy Officer at privacy@snapclarity.com or at the coordinates listed in the “Contact Us” section of this Privacy Policy.
To protect your privacy, you may be required to provide authenticating information prior to gaining access or making changes to your Personal Information. We undertake to respond to all requests to review or request changes to Personal Information within 30 days. In some cases, we may not be able to allow you to access certain Personal Information in certain circumstances (e.g., if the file contains Personal Information of other persons, or where required by law). In such event, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.
You will be able to access most of your Personal Information through the Platform. However, you may have rights to other Personal Information in your Therapist’s care, such as Personal Information your Therapist has collected through notes. In this situation, you should contact your Therapist directly for access or copies of that Personal Information.
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 specific 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 anonymized/de-identified information about your use of our Services. After we delete Personal Information, we will retain anonymized/de-identified information and will continue to use anonymized/de-identified information without restriction as it is no longer Personal Information as defined in this Policy.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions or comments about this Privacy Policy, including the ways in which we collect and use your information described above please contact us: privacy@snapclarity.com