Last Updated: May 19, 2024

Introduction

Soul Thrillers (“we” or “us”) values the relationship we have with our clients and is dedicated to protecting their Personal Information (as defined below in Section III, “Definitions”) in compliance with applicable laws. The term “client” refers to any individual who is receiving or has signed up to receive the Soul Thrillers Services and Partnership Services (defined below).

Services Overview

Soul Thrillers provides personalized psychological assessment and psychotherapy services (“Partnership Services”) as an agent to its healthcare provider partners (our “Partners”). Soul Thrillers employs or contracts with a team of psychologists and mental health therapists (“Soul Thrillers Health Professionals”).

By receiving the Soul Thrillers Services or Partnership Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your Personal Information as outlined below. If you do not agree with this Privacy Policy, please do not provide your Personal Information to us.

I. Background

a) Soul Thrillers Services

Soul Thrillers assists individuals in finding, choosing, and accessing therapists and mental health programs based on:

• Current situation and therapy goals

• Insurance coverage

• Scheduling and logistical preferences

• Therapist preferences

These services are collectively referred to as the “Soul Thrillers Services.” Therapists and mental health programs suggested by Soul Thrillers based on these criteria are referred to in this Privacy Policy as “Therapists.” The selection of a Therapist by Soul Thrillers is a suggestion only, and the Therapists are regulated healthcare professionals solely responsible for the services they provide. Clients can accept or reject such suggestions. Soul Thrillers may engage regulated health professionals, such as social workers and psychotherapists (“Contracted Professionals”), to assist in providing the Soul Thrillers Services.

II. Application of Privacy Policy

This Privacy Policy outlines Soul Thrillers' policies and practices for managing Personal Information, including how we collect, use, and disclose Personal Information in providing the Soul Thrillers Services and Partnership Services.

This Privacy Policy applies to Personal Information collected by Soul Thrillers from individuals in the course of providing the Soul Thrillers Services and Partnership Services. It does not cover:

• Personal Information provided directly to a Therapist by clients or indirectly through the Therapist’s employees or agents;

• Use of Soul Thrillers' website www.soulthrillers.com and all associated webpages, any other websites, digital properties, audio offerings, mobile applications, and mobile-enabled sites owned or operated by Soul Thrillers that do not have separate terms and conditions (collectively, the “Soul Thrillers Website”). A separate privacy statement, available at www.soulthrillers.com/web-privacy-policy, applies to the Soul Thrillers Website. This Privacy Policy supplements but does not replace the privacy policy applicable to the use of Soul Thrillers’ Website;

• Any third-party websites, including any linked from the Soul Thrillers Website. Clients are responsible for reviewing the privacy policies of any such third parties. Soul Thrillers disclaims all responsibility for the content, privacy policies, or practices of any third-party websites.

III. Definitions

• Agent: A person authorized by a health information custodian (as defined in section 3 of the Personal Health Information Protection Act, Ontario, 2004 (“PHIPA”)) to act on behalf of the custodian concerning personal health information for the custodian’s purposes, not the agent’s own purposes.

• Collect: To gather, acquire, receive, or obtain Personal Information by any means from any source. “Collection” has a corresponding meaning.

• Consent: Voluntary agreement to the collection, use, and/or disclosure of Personal Information for identified purposes. Consent can be either “express” or “implied” and can be provided directly by the individual or by an authorized representative. “Express” consent can be given orally, electronically, or in writing, but is always unequivocal and does not require any inference on the part of Soul Thrillers. “Implied” consent can reasonably be inferred from an individual’s action or inaction.

• Disclose: To release or make available Personal Information that is in the custody or control of Soul Thrillers to another person not using the Personal Information as an agent of Soul Thrillers. “Disclosure” has a corresponding meaning.

• Health Information Custodian: As defined in PHIPA, a health information custodian.

• Personal Information: Information about a specific, identifiable individual, including, for example, name, date of birth, address, and Personal Health Information. It does not include information related to a person in their professional (work) capacity.

• Use: To handle or deal with Personal Information in the custody or control of Soul Thrillers, transferred from our Partners to Soul Thrillers, and includes transferring the information to an agent acting on behalf of Soul Thrillers.

IV. Collection of Personal Information by Soul Thrillers

Soul Thrillers may collect the following Personal Information from clients:

• Name, contact information (including home address and email address), date of birth, religious affiliation(s), gender, employment status, Personal Health Information, and other relevant Personal Information.

• Credit card information and/or bank account information (for payment purposes).

• Other identifying information about the client that we did not request but was provided by the client or any other authorized person.
  
  

We always collect Personal Information by fair and lawful means. We may collect Personal Information directly from clients and/or from third parties (including our Partners), where we (and/or those third parties) have obtained the client’s consent or as otherwise required or permitted by law. Typically, we collect Personal Information directly from clients when they voluntarily provide it in the course of accessing the Soul Thrillers Services and Partnership Services. For example, Personal Information may be collected when a client:

• Completes a client profile or intake form;

• Provides it to Soul Thrillers Health Professionals during care;

• Communicates with Soul Thrillers representatives via phone, email, or mail.
  
  

We limit our collection of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy. Soul Thrillers’ privacy practices comply with applicable privacy laws, including PHIPA, PIPEDA, and PIPA.

V. How We Use Clients’ Personal Information

We use clients’ Personal Information for the following purposes:

• To provide mental health and assessment treatment services;

• To plan, administer, and monitor the Soul Thrillers Services and Partnership Services;

• For quality control purposes;

• For billing purposes;

• To communicate with Therapists and their agents about the client to determine a suitable match and to assist in service provision (e.g., psychotherapy, counseling);

• To de-identify it (i.e., make it so that it no longer identifies a client). Soul Thrillers may use de-identified and/or aggregate information for any appropriate purpose.
  
  

From time to time, we may retain third-party service providers to assist in delivering the Soul Thrillers Services and Partnership Services or to perform tasks related to our business operations, such as accounting, financial, audit, legal, consulting, operational, and practice management services. These service providers are subject to necessary restrictions to enable Soul Thrillers to provide the Soul Thrillers Services and Partnership Services in compliance with applicable law.

VI. Access to Clients’ Personal Information

Clients’ Personal Information will be accessible to Soul Thrillers’ employees, Soul Thrillers Health Professionals, and third-party service providers, including Contracted Professionals and Therapists, on a “need-to-know” basis. All parties must enter into agreements with us to comply with applicable law (including privacy laws), this Privacy Policy, and our related policies and procedures.

VII. Disclosure of Personal Information

Soul Thrillers will maintain clients’ Personal Information in strict compliance with this Privacy Policy and will only disclose it as permitted or required by law. We will identify to whom, and for what purposes, we may disclose Personal Information at the time of collection and obtain the client’s consent unless otherwise required by law. For example, under section 7(2)(b) of PIPEDA, Soul Thrillers may use Personal Information without the client’s consent to respond to an emergency that threatens life, health, or security. If required by law to disclose Personal Information without consent, we will disclose only the necessary information and inform the client if permissible.

VIII. Security and Safeguards

Information we collect may be processed and stored on servers in Canada or outside of Canada. If Personal Information is processed or stored outside Canada, it will be subject to the laws of that jurisdiction. Soul Thrillers uses standard security measures to protect Personal Information from theft, loss, unauthorized access, use, disclosure, or destruction.

Employees, partners, and third-party service providers may be located outside Canada, and Personal Information may be subject to the laws of those jurisdictions. All parties must protect the confidentiality of Personal Information in accordance with our privacy policy.

IX. Retention of Personal Information

We will retain Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. Soul Thrillers will return Personal Information to its Partners following the completion of the Partnership Services agreement.

X. Contracted Professionals and Soul Thrillers Health Professionals

By receiving the Soul Thrillers Services, you agree that:

• Soul Thrillers may use Contracted Professionals to assist in delivering the Soul Thrillers Services;

• Contracted Professionals may be subject to other privacy legislation, such as PHIPA;

• Contracted Professionals may use Personal Information collected from Soul Thrillers, its employees, and third-party service providers to assist in delivering the Soul Thrillers Services and may provide Personal Information to Soul Thrillers and its service providers.

  
  

By receiving Partnership Services, you agree that:

• Soul Thrillers Health Professionals may use Personal Information collected from our Partners, Soul Thrillers, its employees, and third-party service providers to assist in delivering the Partnership Services and may provide Personal Information to our Partners and service providers.

  
  

Contracted Professionals and Soul Thrillers Health Professionals must enter into written agreements to comply with applicable law (including PHIPA), this Privacy Policy, and other related policies and procedures.

XI. Changes to Our Privacy Policy

Soul Thrillers may change this Privacy Policy from time to time at its sole discretion. The updated Privacy Policy will be posted on the Soul Thrillers Website, and the date of the latest update will be indicated at the top. Clients should review the Privacy Policy periodically. Continued use of the Soul Thrillers Services constitutes acceptance of the updated Privacy Policy. If a client objects to any terms, their sole recourse is to stop using the services. A copy of the most recent Privacy Policy is available on the Soul Thrillers Website or upon request.

XII. Access, Correction, or Other Requests

Our Chief Privacy Officer can be contacted as follows: Email: contact@soulthrillers.com. Clients have the right to request access to their Personal Information and to request corrections if there are errors. If you have any questions about this Privacy Policy or our privacy practices, please contact our Chief Privacy Officer.