Effective date: December 23, 2021
2. Types of Personal Information We Collect
For the purposes of this policy, Personal information is any information about an identifiable individual, including any information that, alone or in combination with other information, could be used to identify an individual (“Personal Information”). Personal Information does not include aggregated information, or any Personal Information that has been de-identified through the removal of potentially identifying details, such that the data may not be identified with a particular individual.
We collect Personal Information that you share with us directly or provide by interacting with our Website or otherwise using the Services. The types of Personal Information that we collect are as follows:
- Information you provide to us when you register for an Owl account. When you sign up for an Owl account, we ask you to provide information about you including your first and last name, your address, your phone number, your date of birth, your gender, your email address, your account username and password, your clinic name and health care provider details, your profession (for example, whether you are a psychologist, social worker, psychotherapist, or therapist), and whether you are a student, group practice, or NFP.
- Information you provide when you use the Services. When you use our Services, you may provide us with messages or transaction information relating to your interactions with your clients, receipts, personal data in text, picture, or video form, and other content you may choose to provide to us in the normal course of your use of the Services and the Owl Social Properties, including but not limited to posts, profiles, comments, suggestions, forwarded messages, feedback information, usage information, transaction information and Traffic Data (as defined below). We may also collect information you provide to us when you complete a web form, send us an email, make a support request, or interact with us by any other means of communication.
- Payment Information. We use a third party payment processor to facilitate processing payment information if required in order to provide the Services to you.
Other than some key information which we require to provide our Services, the Personal Information that you provide to us is optional. You can share as much as or as little as you are comfortable with – whether through the registration process or your use of the Services. You may always opt not to disclose certain Personal Information, but that may mean that you will not be able to access certain features of the Services. For example, your name and email address are necessary to complete the registration process.
We rely on you to ensure that the Personal Information you provide to us is accurate, complete, and up-to-date. You may make changes or corrections to your Personal Information at any time. If you would like to review or update your Personal Information, please contact our Privacy Officer at the contact details listed below. While we make every effort to ensure the accuracy of your information in our reports, displays, articles, and support queries, you must verify all information created from your use of the Services and we recommend that you consult with a professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk.
3. How We Use Your Personal Information
We use your Personal Information to provide the Services to you and to operate our business, including for the following purposes:
- to provide customer service and support;
- to resolve disputes;
- to identify, troubleshoot, and fix problems with the Services;
- to fulfill your requests for certain features and functionalities of the Services;
- to customize, measure and improve the Services;
- to inform you of targeted marketing, service updates, and promotional offers, as permitted by law;
- to assist us to measure our performance and to share performance information with others;
- comply with legal or regulatory requirements;
- to provide, maintain, administer or expand the Services, perform business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- to perform data analysis and testing;
- to contact you, as required or permitted by law;
- to fulfill other purposes, subject to your explicit consent.
Please be advised that we or our service providers (including, but not limited to, our insurance billing provider) may aggregate and anonymize Personal Information and utilize such aggregated, anonymized data for benchmarking and other purposes. We also use aggregated data to analyze and understand the usage of our Services by our customers and their clients, and to publish a yearly “State of Private Practice” report that is based on such aggregated and anonymized customer account data.
If you provide us with a testimonial, you expressly agree that we may post such testimonial along with your name on the Website or Services from time to time.
4. Disclosure of Personal Information
We reserve the right (and you expressly authorize Owl) to share or disclose your Personal Information when we determine, in our sole discretion, that the disclosure of such information is necessary or appropriate:
- to prevent prohibited or illegal activities; or
- when required by any applicable law, rule, regulation, subpoena, or other legal process.
If all or a portion of our business, or one or more of our divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your Personal Information may be one of the transferred assets and you agree to the transfer of your Personal Information in such case.
Owl also offers publicly-accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We take no responsibility for any information which you or your employees, agents, contractors and representatives post or publish on the Owl Social Property and you agree to indemnify and hold us harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from any such post or publication.
5. Processing of Personal Information by Third Parties
We may share your information with our affiliates, with service providers who help us to run our operations, or to otherwise provide the Services, fulfill your requests, or as required by law. For example, we may use a third party service provider to facilitate sending text message reminders on your behalf, upon request.
Our service providers are restricted from using Personal Information in any way other than for the service they are providing, and our contracts with such service providers require them to maintain reasonable and appropriate security safeguards.
6. Cross-border Data Transfer
Generally, we collect, use, and store your Personal Information only in Canada. Please note, however, that we may use third-party service providers that may store or process your Personal Information in the United States or other jurisdictions other than Canada, where it may be the subject of laws of the jurisdiction in which it is processed or stored.
7. Cookies and Related Technologies
Cookies are small data files that are stored on a subscriber’s computer for record-keeping purposes. Cookies track how you use the Services and what you look at. A session ID cookie expires when you close your browser. When you log into your account, your browser may ask if you want it to remember you as a registered subscriber of the Services. If you accept, the session ID becomes a persistent cookie, which remains on your hard drive for an extended period of time. Although cookies are used by most major websites and are accepted by default by most web browsers, it may be possible to disable cookies via your browser settings. However, if you decide not to accept cookies from our website, you may not be able to take full advantage of all of the features of our Services.
How do we use other analytics tools?
8. How We Safeguard Personal Information
In order to keep the Personal Information secure, we restrict unauthorized access through protective policies, procedures, and technical measures, including:
- encryption of Personal Information in transit and at rest using secure socket layer technology (SSL). To learn more about SSL, follow this link:
- providing reasonable physical and electronic safeguards with regard to the storage of Personal Information;
- backing up and encrypting your account data routinely;
- limiting access to Personal Information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and
- governing employees and other contractors by strict standards and policies to ensure that Personal Information is secure and treated with the utmost care and respect.
In addition, Owl maintains the following physical safeguards:
- the office reception area is physically separate from the records processing area;
- access to both areas is key-controlled;
- access to Personal Information is restricted to required personnel only and access is monitored and recorded; and
- Owl pre-screens its employees and provides training and orientation on their obligations to maintain the confidentiality and security of Personal Information.
Please note that no data transmission over the Internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect the Information, we cannot warrant the security of any information you transmit to us, and you provide such information to us at your own risk. If you have a security related concern, please Contact Us. We will work closely with you to ensure a quick and personal response to your concerns.
9. Retention of Personal Information
10. Your Choices & Access to Your Personal Information
We value your choices when it comes to your Personal Information. You choose how much information to share with us through the registration process and through your use of the Services. You generally have the right to withdraw your consent to any further collection, use or disclosure of any elements of your Personal Information, subject to legal and contractual requirements; however, such a withdrawal may reduce your ability to take full advantage of our Services.
You have the right to access and request correction or updating of your Personal Information, subject to limited exceptions prescribed by applicable laws. You may do so by Contacting Us. You also have the right to opt-out of marketing communications. If you would like to discuss your privacy choices, including your ability to opt-out of providing certain information, please Contact Us.
11. Your California Privacy Rights
If you are a California resident, California law provides you with the following rights with respect to your Personal Information:
The right to know what Personal Information we have collected, used, disclosed and sold about you, and the right to request that we delete any Personal Information we have collected about you. To make such a request, please write to us at the following address:
Owl Practice Inc.
889 Broadview Ave.
Toronto, Ontario, Canada
ATTN: Customer Service Department—California Privacy Info.
You also may designate an authorized agent to make a request for access on your behalf. When you exercise these rights and submit a request to us, we may verify your identity. We also may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of our Services.
12. Rights of Removal of Posted Information – California Minors
If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted information that you publicly post on the Website. To request removal of such information, you can contact us as provided below. Upon receiving such a request, we will make sure that the information is not publicly available on the Website, but the information may not be completely or comprehensively removed from our systems and databases.
13. Children’s Policy
Our Website is not intended for use by children. We do not knowingly collect Personal Information from children under 13 years of age. Please contact us if you believe we may have unknowingly collected information about a child under 13, and we will take immediate steps to delete any such Personal Information.
14. Right to Lodge Complaints
We are transparent about the ways in which we collect and use Personal Information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your Personal Information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns.
16. How to Contact Us
If you have questions or concerns regarding our policy or practices, please contact our privacy officer by email at email@example.com or at the following address:
Owl Practice Inc.
889 Broadview Ave.
Toronto, Ontario, Canada