Section I – Understanding Grief’s Website Privacy Policy
Before you use our Website, please consult our Terms of Use. At Understanding Grief (formally Reconnect from Grief) we are committed to maintaining the accuracy, confidentiality, and security of your personal information. We have developed this Website Privacy Policy to describe our specific privacy policies and practices and how we collect, use and disclose the personal information of those individuals who visit our website.
We have developed other documents that describe our privacy policies and practices with respect to those individuals with whom we interact. Please see See Section II External Privacy Policy below for more details.
If you are unsure of which Privacy Policy applies to you, please contact our Privacy Officer for more information.
Our website address: www.understanding grief.com
The information posted on this website is intended to provide what we at Understanding Grief hope will be useful information, but, are general in nature only. Readers are reminded that the needs and circumstances of each person are unique. To properly diagnose any mental or physical health problem you or someone you know might have, you should consult an appropriate medical professional. To help you or your loved one deal with your grief, we offer one on one grief coaching services. The information on this website cannot be and is not a substitute for medical services.
Privacy Policy Effective for Canada & Europe & California US
This website requires cookies to provide all its features. To accept cookies from this site, please click on the ACCEPT button that is provided located by the Privacy Policy link at the bottom of that page.
This privacy policy sets out how Understanding Grief uses and protects your information when subscribing to and using our website. At Understanding Grief, we are committed to protecting and safeguarding your personal data. As part of this commitment, we have updated our privacy policy to meet the high standards of the General Data Protection Regulation (GDPR). When we ask you to provide certain information by which you can be identified or contacted when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
It is Understanding Grief ‘s policy to comply with the privacy legislation within each jurisdiction in which we operate which includes North America and Europe. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable as well as those of the European General Data Protection Regulation (GDPR) of Europe and California, US Regulation California Consumer Protection Act (CCPA)
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.
What Is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.
What Personal Information Do We Collect?
You can visit our website without telling us who you are or revealing any information about yourself, including your email address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website; the type and version of your browser; the website you came from to access our website; the page you entered and exited at; any website page that is viewed by that IP address; and what country you are from. We use this information to monitor our website’s performance (e.g., number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.
In addition, we collect the personal information that you submit to our website such as your name, address and any other contact or other information that you choose to provide by:
- using the “Contact Us” portion of this website; or
- by corresponding with a representative of Understanding Grief, via email using the hyperlinks created for that purpose.
- Subscribing to our free resources or newsletters
Where you request information from us, we may use the email address that you provide to send you information about our services that we believe may be of interest to you. If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, or if we send you information about our services by email, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up).
What Personal Data is Collected and Why
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
How Do We Use Cookies?
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual; they allow us to get to know customers better. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used to
help us analyze data about web page traffic and improve our website in order to
tailor it to customer needs. We only use this information for statistical
analysis purposes and then the data is removed from the system. Overall, cookies
help us provide you with a better website, by enabling us to monitor which
pages you find useful and which you do not. Don’t worry, a cookie in no way
gives us access to your computer or any information about you, other than the
data you choose to share with us. You can choose to accept or decline cookies.
Most web browsers automatically accept cookies, but you can usually modify your
browser setting to decline cookies if you prefer. Information on deleting or
controlling cookies is available at
http://www.aboutcookies.org
Please Note: by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our site. Sometimes our website, newsletter or other external communication may contain links to other websites of interest. However, you should note that we do not have any control over that other website and cannot be responsible for the protection and privacy of any information which you provide whilst visiting other sites not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.
What About Links to Other Websites?
Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites Understanding Grief is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Why Do We Collect, Use and Disclose Personal Information?
The personal information collected is used and disclosed for our business purposes including those purposes explained in this policy and may be used in the context of providing coaching services to you if you decide to obtain such services from us. The use of Personal Information by us is further explained in our External Privacy Policy (available below ).
Your personal information (other than information obtained by Understanding Grief and Anne DeButte in the context of a coaching session with you which is subject to a different agreement) may be shared with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you. In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of Understanding Grief.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Personal Information
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. You may request details of personal information that we hold about you at any time, we will make readily available information about our policies and practices relating to the management of personal information. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. If there is anything else you would like to know about how information about you might be processed using this site, please get in touch.
Your Consent Is Important to Us
By using our website, we assume that you have consented to the collection, use, and disclosure of your personal information as explained in this Privacy Policy.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
How Is Your Personal Information Protected?
Understanding Grief endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. You may request details of personal information that we hold about you at any time, we will make readily available information about our policies and practices relating to the management of personal information. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
How Long Data is Retained
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights do you have over your data
If you have an information subscription or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where Data is Sent
Visitor comments may be checked through an automated spam detection service.
Access to Your Personal Information
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing. For information on accessing your information, please see our External Privacy Policy below.
In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why subject to any legal or regulatory restrictions.
Inquiries or Concerns?
If you have any questions or concerns about our Privacy Policies, please contact:
Privacy Officer: Anne DeButte
Email: anne@understandinggrief.com
Revisions to this Privacy Policy
Understanding Grief (formally Reconnect from Grief) from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website Understandinggrief.com and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on February 10, 2020.
Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.
This Privacy Policy does not create or confer upon any individual any rights or impose upon Understanding Grief any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, and as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with such privacy laws.
Section II External Privacy Policy- Ontario
At Understanding Grief, we are committed to maintaining the accuracy, confidentiality, and security of your personal information. This Privacy Policy describes the personal information that Understanding Grief collects from or about you, how we use and to whom we disclose that information.
Understanding Grief adheres strictly to the current legislation governing personal privacy for health information in Ontario (Personal Health Information Protection Act).
Understanding Grief has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals. This Privacy Policy applies to the personal information of all individuals with special additional protections afforded to individuals who have entered a coaching contract with Understanding Grief and are receiving coaching services from Anne DeButte.
Privacy Policy Effective for Canada
It is the policy of Understanding Grief to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws and externally, as applicable.
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.
What is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.
What is Personal Health Information?
Personal health information includes oral or written information about an individual if the information:
• relates to the individual’s physical or mental health, including family health history;
relates to the provision of health care, including the identification of persons providing care;
• is a plan of service for individuals requiring long-term care;
• relates to payment or eligibility for health care;
• is the individual’s health number; or
• identifies an individual’s substitute decision-maker.
Any other information about an individual that is included in a record containing personal health information is also included in the definition.
It does not include information about an individual if the information could not reasonably be used to identify the individual although such information might still be confidential and protected under our counseling services contract.
How do we use your Personal Health Information?
The information that we collect is used to:
- Ensure we can contact you
- Provide coaching services to you
- Maintain accountability as a service provider
- Ensure safety, legal and ethical standards are met
- Assess the quality of services provided and the effectiveness of outcomes
All clinical files and data are the sole property of Understanding Grief and are stored in a secure location or on a secure server. Any questions or concerns can be addressed directly to the Privacy Officer, who is the Owner, Anne DeButte.
Confidentiality Policy
All notes, records, and communications created by Understanding Grief during your involvement as a client are kept secure and confidential and can be shared only with your written consent and as agreed to in our coaching services contract with you. Understanding Grief keeps a record of all appointments/coaching sessions, whether by phone or in person or by the exchange of email messages. Information may be shared within Understanding Grief for case management and quality assurance purposes. Any information about a client is kept within the organization in the strictest confidence.
There are a few exceptions to confidentiality when the law requires that our records be disclosed under strict conditions. In the following situations, the law requires that reports be made and/or information released:
- Suspected child abuse
- Any life-threatening danger to a client or to a third party (threat of suicide, threat towards others)
- Court orders and subpoenas
When Do We Disclose Your Personal Information Other than Personal Health Information?
We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf; third parties that assist Understanding Grief in the provision of services to you; and third parties whose services we use to conduct our business. For example, personal information contained on a personal cheque used to pay us for our services will be processed through our bank.
Your Consent Is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be expressed, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use, and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or disclosure and obtain your consent to do so.
As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may withdraw your consent at any time, but the withdrawal cannot be retroactive. The withdrawal may also be subject to legal or contractual restrictions and reasonable notice.
All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.
Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing. Generally, your information is kept at our corporate offices in Ottawa, Ontario (see address information below).
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why subject to any legal or regulatory restrictions.
Inquiries or Concerns?
If you have any questions about this Privacy Policy or have any concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.
Privacy Officer
We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:
Privacy Officer: Anne DeButte
Email: anne@understandinggrief.com
Revisions to this Privacy Policy
From time to time, we may make changes to this External Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website understandinggrief.com and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on Feb 10, 2020.
Interpretation of this Privacy Policy
Any interpretation associated with this External Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.
This Privacy Policy does not create or confer upon any individual any rights or impose upon Reconnect from Grief any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with such privacy laws.
