Privacy Policy

At First Response Mental Health Inc. (“FRMH”), we value your trust and respect your privacy.

A. SCOPE

This privacy policy applies to https://myfirstresponse.ca and www.firstresponsemh.com and their subdomains, and the FRMH Software Application (the “Site,” or “Sites”) and the PeerConnect mobile application (the “Service”), all of which are owned and operated by FRMH. It does not apply to any third-party websites, which have their own policies. Throughout this policy, when we say FRMH, we mean our company, including the Site and any FRMH mobile apps, and when we say Services we mean our mobile app, including its various modules for newsfeeds, peer support, FAQ, etc.
By “Personal Information”, we mean information about an identifiable individual. That’s what this policy is about – our collection, protection, use, retention, disclosure, and other processing of Personal Information and your rights relating to these activities. We also compile certain aggregate data about our users.
What is aggregate data? “Jane Smith buys a coffee at a coffee shop on Main Street” is the Personal Information of Jane Smith, but “20% of FRMH users buy coffee on Tuesdays” is aggregate data.
We use Personal Information in order to provide you with the Service(s). Our Privacy Policy is based on the following 10 fair information principles:

• Accountability
• Identifying purposes
• Consent
• Limiting collection
• Limiting use, disclosure, and retention
• Accuracy
• Safeguards
• Openness
• Individual access
• Challenging compliance

1. Accountability and Challenging Compliance

FRMH has named a Privacy Officer who is responsible for all things privacy at FRMH. This includes our policies and procedures that are designed to keep your information safe. If you have any questions about our privacy practices or this policy, you can contact me at:

First Response Mental Health
Privacy Officer
285 Squier St.
Thunder Bay, ON P7B 4A7
Canada
Email: privacy@firstresponsemh.com

If you’re not satisfied with our response, you have the option of contacting Canada’s Office of the Privacy Commissioner.
https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/

2. Identifying Purposes

FRMH collects, uses, discloses, and otherwise manages Personal Information in a variety of ways related to the Services we provide. We’ve outlined these below. Your use of the Services determines which information we collect and use. For example, Peer Support information is optional, unless you are using the Peer Support module, at which point we will need to collect email and telephone information in order to provide you with this service.
FRMH may collect, use, store, or disclose your Personal Information for the purposes described below.
In order to provide you with the Services, which includes the following:
We collect information directly from you, but may also collect information from third parties, such as your employer. These integrations may pull data into or share data out of FRMH. In some cases, we use a service provider to connect to you, for example when we send you a phone-based notification.
We may also collect your name and email address from third parties when you sign up and log in to our Site using a single sign-on (SSO).
To promote or offer you products or services, and to determine your eligibility for new services we may offer from time to time.
To provide you with educational materials and guides relevant to the Services you use.
To contact you for the purposes of Service updates and system and account notifications.
To provide you with support in connection with the Services.
To comply with any laws, regulations, court orders, warrants, inquiries, subpoenas, or other legal processes or investigations, and to protect ourselves, other individuals, or property from harm.
In connection with a prospective or completed merger or sale (including insolvency or bankruptcy proceedings) involving all or part of FRMH or as part of a corporate reorganization or stock sale or other change in corporate control.
We will never sell your Personal Information to other companies.

3. Consent

FRMH takes a consent-based approach to the collection, use, and disclosure of Personal Information.

Submitting the Personal Information of others

When you submit the Personal Information of your customers or employees to us, you are responsible for informing such customers and employees about FRMH, and for obtaining any necessary consent or authority from them.
You may also choose to refer someone to our Site. We will send them a single invitation email to the address you provide. Please ensure that you only submit email addresses of individuals or businesses with whom you have a relationship and who would want to receive the message.

Closing your FRMH account

At any time and without penalty, FRMH users can withdraw their consent to the continued use or disclosure of their Personal Information by closing their FRMH account. Please ensure you complete the account closure process which includes a confirmation email. Otherwise, your account may not be closed.

Email and communications consent

At any time, you can opt-out of commercial email communications from us by clicking on the unsubscribe link in such emails, or via the Email Preferences settings in your account. Certain non-commercial communications may still be sent to you that are required to provide you with our Services. For example, system notifications, major product changes, changes to our Terms of Use, or other news that we believe will materially affect how you interact with FRMH.
The only way to completely stop all emails from FRMH is to close your account as outlined above.

4. Limiting Collection

FRMH only collects the Personal Information necessary to provide the Services to you. The Services you use will determine which information FRMH collects. We’ll also provide you the option of sharing additional information to enhance your FRMH experience.

FRMH is not intended for children and we do not knowingly or intentionally collect information about individuals under the age of thirteen (13).

5. Limiting Use, Disclosure, and Retention

We will use your Personal Information as described in this policy.
We will share your Personal Information with third parties only as described in this policy.
We will retain your information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required by law or regulation. To be clear, that means we’ll retain your Personal Information while you have an active account, and afterward if we need to do so to meet our legal obligations. If you choose to close your FRMH account, we will destroy your Personal Information within 60 days unless we are otherwise obliged to keep it longer.

6. Accuracy

FRMH relies on you to provide us with information that is accurate and complete. We provide you the mechanisms and rely on you to keep your information up to date. You can request updates or corrections of any inaccuracies in your Personal Information at any time by contacting us at the contact information listed in the policy. We will respond to your request within a reasonable timeframe.

7. Safeguards

FRMH uses a combination of reasonable and appropriate safeguards designed to protect your information. These safeguards are administrative controls (things like policies, procedures, and training), technical controls (things like encryption, firewalls, and secure coding frameworks), and physical controls (secured hosting environments).
We ensure that any third party acting on our behalf maintains reasonable and appropriate safeguards in respect of your Personal Information. Additional information about our third parties’ privacy practices is available upon request.
If you have questions about security on our Site, you can contact us at security@firstresponsemh.com.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Services to third parties. Our team will never request your password or PIN, and we ask that you never post account or credit card numbers to our resource channels.

8. Openness

This policy outlines our privacy practices. If you have questions about it, please contact our Privacy Officer. This policy is available publicly at https:/www.firstresponsemh.com/privacy.

9. Individual Access

You may access, update, and correct inaccuracies in the Personal Information in our custody or control at any time, subject to limited exceptions prescribed law. You can download or export data you input into the Site at any time, or to correct inaccuracies, simply log into your account and make the necessary changes.
You can also request access, corrections, or updates to all your Personal Information, including information not available through your account, by contacting us as set out in the Challenging Compliance section of this document. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their personal information records.

B. ADDITIONAL DETAILS

1. Public content and Social Media

FRMH has public forums and blogs. Any information submitted there may be read and collected by anyone.
You may request removal of Personal Information from forum or blog posts and comments by contacting us at privacy@firstresponsemh.com.
If you provide us with a testimonial, with your consent we may post it on our Site or in other materials and media, along with your name. If you want your testimonial removed, please contact us at privacy@firstresponsemh.com.
You may engage with us through social media sites. When you engage with us on these sites, we may have access to certain information about your account (e.g., name, username). These sites may collect your IP address, how you’re engaging with us and may use cookies to enable the site to function properly. We may use this information to personalize your experience and to provide you with other products or services you may request.

2. Service Providers

We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to host our website and to process payments. Your Personal Information may be maintained and processed by these third parties in other jurisdictions, like the United States. When your information is in another jurisdiction, it will be subject to their laws. We only share the information these service providers need to do their job and we don’t authorize them for any other use or disclosure of personal information.

3. California Consumer Privacy Act

If you live in California, you are granted additional rights under the California Consumer Privacy Act.

4. Visiting the Site and using PeerConnect mobile apps

In general, you can visit the Site without telling us who you are or submitting any Personal Information. However, we and/or our service providers (such as Google Analytics) collect IP (Internet protocol) addresses from all visitors to the Site and other related information such as page requests, browser type, operating system, and average time spent on our Site. When you use any of our mobile apps, we also collect device type, operating system, unique device identifier, and date and time stamp. This information is used to help us understand the activity on, and to monitor and improve, our Site and mobile apps.

5. Cookies, Tags, and Web Beacons

Technologies such as cookies, web beacons, tags, and scripts are used by FRMH, our advertising and analytics service providers (such as Google Analytics), and affiliates to analyze usage trends, administer the Site, and to gather demographic information about our user base as a whole.
A cookie is a small piece of data that our Site can send to your browser, which may then be stored on your device so we can recognize you when you return. We use cookies for session tracking to make it possible to navigate the secure environment inside our Site. These cookies (1) may let us know who you are, (2) are necessary to access your account, and (3) will give us information that we can use to personalize our Site according to your preferences. You can control the use of cookies in your browser. If you disable cookies, you will not be able to access your account or take advantage of all of the features of the Site and mobile apps.

6. Notification of Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our website prior to the change becoming effective. We encourage you to periodically review our Privacy Policy for the latest information on our privacy practices.