Privacy Policy

Get A-Head Inc. ("Get A-Head", “we” or “us”), the operator of the geta-head.com website (the “Website”) and the Get A-Head mobile application (the “App”) is committed to protecting any personal information which you may provide while using, or that we may obtain from your use of, the Website or the emails we send to you. The purpose of this privacy policy (the “Policy”) is to inform you of our privacy practices and policies, including:

· how and why we collect your personal information on behalf of your organization;

· how we intend to use your personal information within your organization's interactions;

· with which parties we may share your personal information; and

· to provide you with contact information should you have questions or concerns about our practices.

We know that customers care deeply about privacy and data security. That’s why Get A-Head gives you ownership and control over your content through simple, powerful tools that allow you to determine how this data is managed and retained.

The Get A-Head platform is a PaaS (platform as a service) solution where the Get A-Head organization operates the platform on behalf of the organizations who are our customers. With this in mind, all customer data is owned by the organization customer. Get A-Head is a data custodian of this customer data, and we protect this data on behalf of our organization customer.

The impact of the above approach is that Get A-Head is both reliant and supportive of the organization's data retention and data management policies and processes. We provide the tools for manipulating, adding, removing and expunging all the customer data in support of your internal processes. More specifically, this impacts the typical touchpoints:

· Data Retention policies

· Data Privacy policies

BY USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, STORAGE, USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, YOU MUST NOT ACCESS OR USE THE WEBSITE.

Overview of Our Privacy Practices

Our privacy practices are summarized here. Under this Policy, Get A-Head:

(1) Collects personal information through the Website and the App, in the course of facilitating the delivery of your organization's services, when you make inquiries and for marketing purposes;

(2) Collects information relating to individual sessions including audio recordings;

(3) May collect data through your Website usage, your internet protocol (IP) address, the Website cookies and email web beacons;

(4) May collect non-identifiable information regarding Website users (such as the date and time you accessed the website);

(5) Shares this information with its service providers, service providers' supervisors, authorized employees, agents, service providers and legal representations, and may also share this information with third parties that we engage to provide products and services on our behalf;

(6) Except as set out in (5), does not share your personal information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected;

(7) Collects and uses this information to connect you with and to facilitate counseling services, to comply with applicable laws and regulations, to administer the Website and the App, to protect Get A-Head and Website users from fraud, to contact you with your billing inquiries (when applicable), and to communicate with you (unless you have opted out of receiving such information);

(8) Allows you to withdraw your consent to the collection, use and disclosure of your personal information at any time; and

(9) Mitigates the risk and impact of potential harms involved in the disclosure of personal information through the adoption of reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to us. Even with these measures, there is a residual risk of the loss of, unauthorized access to or unauthorized disclosure of your information which could result in financial or other harm to you. network information.

Personal Information Collected by Get A-Head

We maintain information relating to our clients and their orders based upon network information. The information we collect comes directly from you, our counselors, our provided by the organization. Information is collected through the Website and the App and in the course of facilitating the delivery of your organization's services. Only personal information that is reasonably necessary is collected. Types of information collected may include health and wellness data, client data, financial (when applicable), service and computer and network information. The information we collect comes directly from you, our counselors, our Website or App or is information relating to the delivery or performance of our services.

You should exercise discretion when disclosing your personal information to us.

Service Provision Information: When you first sign up for your organization's service through Get A- Head, you may be asked questions with information collected about:

· personal information identifying you;

· any stressors that you may be experiencing; and

· any medical information that we should know about.

these questions are used to inform a matching algorithm with service providers within your organization.

We also collect information relating to individual sessions including audio/video recordings. These recordings are considered training data and cannot be considered medical or health data and therefore cannot be retrieved by the client without the express written consent of the service provider(s) and supervisor.

Client Information: We may also you to provide various information about yourself including your name, street address, postal code, email address, occupation and such other information as may be reasonably requested by us from time to time.

Service Information: We may collect personal information from you when you request assistance through our customer service department or when you voluntarily subscribe to a Get A-Head service or newsletter.

Computer and Network Information: We may also collect your Website and App usage data and your internet protocol (IP) address, and other similar information that you provide to us via the Website or the App, including information collected through the use of cookies on your browser. As well, we may collect information relating to the emails that we send to you, such as when you open the email, through the use of single pixel gifs, also called web beacons, or other tracking technologies.

The Website may automatically collect certain non-identifiable information regarding Website users, such as the date and time you access the Website, the Internet address of the website from which you linked directly to the Website, the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and the materials you post to or download from the Website. We may collect, use, transfer and disclose aggregated and/or non-personal information.

The Website uses "cookies", a technology that installs information on a website user's computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to track your activity at the Website in order to respond to your needs, to offer personalized web page content and information for your use, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.

We also include web beacons in the emails that we send to you. Web beacons allow us to collect information about when email recipients open the emails we send, what parts of the email they review, their IP address, browser or email client type and other similar details. Some of this information may be correlated with recipients’ email addresses. We use this information to review how recipients are responding to the emails we send.

Purpose of Collection and Use of Your Personal Information

Get A-Head collects and uses personal information that you supply through your use of the Website or the App, from participating in health and wellness sessions, or from the emails we send for the following purposes:

· To connect you with and to facilitate counseling services;

· To maintain records of your use of the Website, the App and counseling services (including transcriptions of any counseling sessions);

· To process payments for our services and to give refunds (when applicable);

· To administer the Website and to manage the emails that we send;

· As permitted by, and to comply with, applicable laws and regulations;

· To protect Get A-Head and Website users against fraud;

· To contact you in connection with your billing inquiries;

· To notify you in connection with any changes to our services or this Policy;

· To communicate with you about Get A-Head and its products, unless and until you opt- out of receiving such information by contacting us at privacy@geta-head.com; and

· Other purposes permitted by law.

Disclosure of Personal Information

We will keep personal information that you provide to on Get A-Head private, and will disclose such personal information only in accordance with this Policy.

Get A-Head does not sell, rent, or lease to third parties any personal information it collects from you. Get A-Head may disclose or share personal information with its authorized employees, agents, service providers and legal representatives for the purposes described in this Policy. We may also share your personal information with third parties that we engage to provide products and services on our behalf. Get A-Head shares your personal information with service providers who assist with administering, providing services, hosting and supporting our Website and App.

Get A-Head will not otherwise share your personal information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected. Get A-Head may disclose your personal information to a government institution or agency that has asserted its lawful authority to obtain the information or where Get A-Head has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to protect Get A-Head’s rights and property. If Get A-Head is involved in the sale or transfer of some or all of its business, Get A-Head may disclose your personal information in connection with the transfer or sale.

How Get A-Head Protects Your Privacy

Get A-Head keeps the personal information collected through the course of organization's service confidential and has adopted reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to Get A-Head. Notwithstanding these measures, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be 100% secure, and therefore we cannot ensure, warrant or guarantee the security of any such information.

Withdrawal of Consent

You may withdraw your consent to the collection, use and disclosure of personal information about you at any time. To do this, please contact our Privacy Officer at the e-mail address listed in this Policy. Withdrawal of your consent to the collection, use and disclosure of personal information may result in you being unable to continue use of our Website or services.

Verifying and Amending your Personal Information

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information held by Get A-Head and you may request that your personal information be corrected or updated. Please e-mail our Privacy Officer and we will assist you. You may be required to put your request in writing to confirm your request and identity. It is your responsibility to notify us of any changes to your personal information, including contact information, so we can contact you and inform you about updates to this Policy and any other relevant information with respect to your use of the Website or App.

Retention of Personal Information

We will keep and retain your personal information in compliance with our legal obligations, that of your organization's obligations and only as long as necessary for the purposes for which it was collected.

Storage, transmission, and Location of Information

Get A-Head may store and process your personal information collected through the Website on the servers of our third-party service provider, Medstack located in the Country specified by your service provider.. As such, foreign governments, courts, law enforcement or regulatory agencies may be able to access your personal information under foreign laws. Medstack is only permitted to store your personal information, and is not otherwise authorized to collect, use or disclose your personal information, except in accordance with the purposes set out in this Policy or as required by applicable law. The chat feature is meant for quick and easy communication between you and your service provider and is not meant for the exchange of personal health information. We strongly encourage you to use this feature as it was intended and avoid divulging any personal or sensitive information . It is important to understand that there are risks unique and specific to telehealth, including but not limited to, the possibility that your sessions or other communication by your service provider to others regarding your care could be disrupted or distorted by technical failures or could be interrupted or could be accessed by unauthorized persons.

Privacy Policy Changes and Updates

We may revise this Policy at any time, without notice to you. We may, however, choose to notify you of a change to this Policy, for example by announcing the change on the Website. Your continued use of the Website constitutes your consent to the contents of any updated policy.

Where we make significant changes to this Policy, we will notify you directly of the changes by sending you an email informing you of the changes, and will require your consent prior to the changes coming into effect. Significant changes include using your personal information for a new purpose not anticipated originally or a new disclosure of your personal information to a third party for a purpose other than processing that is integral to the delivery of a service.

Resolving Your Concerns

If you would like more information about this Policy or the personal information collection, use and disclosure policies and practices of Get A-Head or its service providers, please contact our Privacy Officer by e-mail at: privacy@geta-head.com.

Please let us know your questions or concerns and we will do our best to help you.