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Mobile Privacy Policy

The Beyond Silence application (the “Service”) is owned by McMaster University (“we”, “us”, or “our”).

This document explains how your information and Personal Data will be collected, used, stored and protected in accordance with the terms of this Privacy Policy and any applicable legislation. By using the Service, you consent to the terms and conditions as set out in this Policy.

Information we collect

When you use the Service, information we collect may include, but is not limited to

Personal opinions through anonymous feedback surveys
A randomly generated identifier assigned by the app (not identifiable)
Notification token to support push notifications to your device (optional)
Behavioural activity within the app
Phone number (disguised through 3^rd party Twilio service)
Aggregate data from the wellness log

While using the Service, we may ask you to provide us with certain personally identifiable information (“Personal Data”). Personal Data may include, but is not limited to:

Phone number: this information will only be disclosed to emergency services if there is concern about imminent risk to the safety of yourself or others

How we use your information and Personal Data

We use your information and/or Personal Data to:

Provide the Service that you request;
Detect and address any technical or other issues with the Service; and
Improve and maintain the Service.

Please be aware that your information could be used for research purposes, but only for research projects approved by a research ethics committee and any other authority required by the applicable laws. We anticipate that for most studies (e.g. those using data collected in the past, duly de-identified) the research ethics committee might waive the need for your specific individual consent. In all cases, the information will be coded so that researchers using the data bank, which may contain your information and/or Personal Data, will not have access to any identifying information. Your email address will never be provided to third parties, except as allowed in this Privacy Policy.

How we store and protect your data

Access to your information and Personal Data is limited, controlled, and managed to make sure that confidentiality is preserved. Your information and Personal Data are kept on the database which is physically located in a secure data centre hosted by Amazon Web Services in the central region (Montreal) in Canada with appropriate physical, administrative and technical safeguards in place. These procedures protect your information from misuse, unauthorised access, interference, alteration, loss and/or disclosure. Despite our security measures, we cannot guarantee total confidentiality in the security of our databases.

Only authorised staff at McMaster University with a need to know can directly access your information and/or Personal data. We may retain your information and/or Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law.

Disclosure to Other Third Parties

Your information and/or Personal Data may also be disclosed to the following third parties:

Government and Regulatory Authorities and or other provincial or federal government agencies, if requested and where disclosure is necessary or appropriate.
Law enforcement or other third parties pursuant to valid legal process such as a subpoena, litigation or court order or issues of public importance, where disclosure is necessary or appropriate.
Others, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party, who would be obligated to follow this Privacy Policy or notify you of any changes.

Who we share your information with:

We will share de-identified data for approved research purposes. Aggregated de-identified data about usage of the Service can be shared with authorized third parties under specific data transfer or data reporting agreements. In all cases, the information will be fully de-identified to prevent any access to personal information and/or identification of individuals. Under no circumstances will your email address be provided to anyone.

Data transmission

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction, where the data protection laws may differ than those from your jurisdiction, in compliance with the Freedom of Information and Protection of Privacy Act.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Users from outside of Canada

If you are using the Service from a location outside of Canada, you consent to all your information and/or Personal Data you provide to us will be maintained within Canada. By providing us with any Personal Information through the Service, you consent to the transfer of such Personal Information to Canada.

Your rights to access and control your information and Personal Data

At any point in time, you may request complete erasure of your information and/or Personal Data. After deleting your information, and/or Personal Data some of that data may still be stored as part of previously generated aggregated statistics. At any point in time, and without providing a reason, you may request to obtain a copy, in an intelligible electronic format, of the data stored in your Service record. It should be noted that de-identified data cannot be retrieved. Any request to obtain or delete your data should be directed to (beysilen@mcmaster.ca)

You understand and agree that you assume all responsibility and risk for your use of the Service, the internet generally, and the documents you post or access and for your conduct. Upon your request, we will take reasonable steps to correct, amend or delete your information and/or Personal Data that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise inconsistent with applicable law.

Changes to this privacy policy

This Privacy Policy is effective as of (November 1, 2022) and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. McMaster University is committed to assessing, reviewing and updating this Privacy Policy on a case-by-case basis to meet any changes in regulatory requirements in applicable jurisdictions. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Opt out

You can stop all collection of your information and/or Personal Data via the Service by uninstalling the Service. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also select ‘Request to Delete My Data’ found in the app under ‘Settings’.

Bey Silence Privacy Policy V2. 2022 Oct 20