The purpose of this Goal Management Training Privacy Policy is to describe the collection, use and retention practices that apply to your use as a therapist of the Goal Management Training website (the “Website”) or other programs and services (including both free programs and services for which there is a fee) (“Programs”). In this Privacy Statement, “we”, “us”, “our” and “Baycrest” refers to Baycrest Centre for Geriatric Care (“Baycrest”).

If you are a patient/client using GMT Training (including games or other digital offerings), please refer to the Goal Management Training Terms of Use – General Public/Patients/Clients which includes a privacy statement.

By accessing, browsing, registering with or using any part of the Website and the Programs you agree that we may collect, use and disclose your Personal Information as described in this Privacy Policy. “Personal Information” means information about you or that may be used to identify you. “Account” means an account required to access and/or use certain areas and features of the Website and the Programs.

Collection of Personal Information
Baycrest does not collect Personal Information about you through the Website and the Programs except when you specifically provide this information on a voluntary basis.

Baycrest collects Personal Information to provide and manage your access to the Website and the Programs; service evaluation and quality improvement; and in order to comply with legal and regulatory requirements. The Personal Information we collect for such purposes may include your name; email address; telephone number; address; user name and password along with payment information. With your consent, we will collect and display information such as your professional credentials, background and availability.

Third-party services
We contract with third party vendors to supply certain features of the Website and the Programs. For example, Baycrest operates the Website and the Programs using a platform licensed by LearnWorlds (CY) Ltd. In some cases, LearnWorlds and other third party vendors will require access to some or all of your personal data. For more information about LearnWorld’s Privacy Policy, see https://www.learnworlds.com/privacy-policy/.

When you pay for a Program, your transaction will be processed through a third party vendor called Stripe. Please read Stripe’s Global Privacy Policy https://stripe.com/en-ca/privacy so you can understand how Stripe handles your credit card number and other Personal Information.

Your information may be processed in the European Economic Area, the United States and other jurisdictions by us or a third party service provider and may be subject to the laws of those jurisdictions.

Once you leave the Website or are redirected to a third-party website or application by clicking on a link, you are no longer governed by this Privacy Policy. We are not responsible for the privacy practices of other sites and encourage you to read their individual privacy policies and statements.

Automatic Information Collection
Baycrest automatically collects information as part of the standard operating process of the Website. The information collected includes your internet protocol (IP) address, cookie information and browsing actions and patterns such as user analytics.

A “Cookie” means a small text file placed on your computer or device by our Website when you visit certain parts of our Website and/or when you use certain features of our Website or Programs. LearnWorlds, as well as our other third-party vendor Stripe use cookies to collect information about the use of the Website and preferences and to customize and improve the Website. In addition, Vimeo and Google use cookies to collect information on embedded content on the Website. Your use of the Website and the Programs is therefore subject to the LearnWorlds Cookie Policy available from: https://www.learnworlds.com/cookie-policy/, the Stripe Cookie Policy available from: https://stripe.com/en-ca/legal/cookies-policy, the Vimeo Cookie Policy available from: https://vimeo.com/cookie_policy, and the Google Privacy Policy available from: https://policies.google.com/privacy?hl=en. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

Use of Personal Information
Baycrest uses your Personal Information for the purposes for which it was collected, as well as other purposes for which consent was provided or as otherwise permitted or required by law, including for research purposes approved by the Baycrest Research Ethics Board and to improve our services.

With your consent, which we imply when you register to use the Website or Programs, we will send you electronic messages to register and communicate with you about Goal Management Training programs and services. If you do not wish to receive electronic messages from Baycrest, you can unsubscribe at any time by sending an email to goalmanagementtraining@research.baycrest.org with “Unsubscribe” in the subject line.

Disclosure of Personal Information
Baycrest engages third party service providers to provide the Website and the Programs. We share your Personal Information with such parties to assist us in delivering the Website and the Programs to you. These third-party providers will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide for us, in accordance with applicable law.

We may disclose your Personal Information if the law permits or requires us to do so. For example, we may be required to disclose your Personal Information pursuant to a court order or as part of law enforcement investigations or proceedings.

Participation in online interactive programs
If you choose to participate in an online interactive program, such as a group workshop (“Live Program”), the instructor/lead of the group and invited participants will be able to see each other, hear each other and interact. Please do not share sensitive information that you do not feel comfortable sharing publicly during Live Programs. Live Programs may be recorded; you have the choice to not attend, leave the session, disable your video and/or change your user name.

You can help protect your information during Live Programs by using a private computer/device (i.e. not your employer’s or a third party’s computer/device) and a secure internet connection. Depending on the Live Program, you may have the option to turn off your video and/or audio connection.

Security of Personal Information

To protect your Personal Information, we take reasonable precautions to ensure it is not inappropriately lost, misused or accessed. The Website is hosted by LearnWorlds. LearnWorlds provides us with the online platform that allows us to offer the Website and the Programs to you. LearnWorlds stores your information on a secure server and is a Google Cloud partner. For more information about LearnWorlds Data Security, see https://www.learnworlds.com/data-security/.
You are responsible for maintaining the confidentiality of the password you use for the Website and the Programs and are responsible for all activities that occur under your username and password. You agree to notify Baycrest immediately of any unauthorized use of your password or user name or any other breach of security, and to ensure that you exit from your Account at the end of each session.

Although Baycrest takes reasonable precautions to protect your Personal Information, please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, Baycrest does not ensure or warrant the security of any information you transmit to us or from our on-line products or services, and you do so at your own risk. Once we receive your transmission, we make reasonable efforts to ensure its security on our systems.

Withdrawing Consent
If you wish to withdraw your consent for the collection, use or disclosure of your Personal Information, please contact our Privacy Officer at the contact information below. Your withdrawal of consent will be applied on a go-forward basis and may be subject to legal or contractual restrictions and reasonable notice.

Should you wish to opt out of receiving emails relating to the Website or the Programs, please contact goalmanagementtraining@research.baycrest.org.
You may also delete your Account.

Retention and Storage of Personal Information
We will retain your Personal Information to fulfil the purpose for which we collected it, and for as long as necessary or as required by applicable law.

Note to Users Outside Canada
Baycrest is located and operated in Ontario, Canada.

Contact Us
Should you have any questions about your personal information or our privacy practices, please contact goalmanagementtraining@research.baycrest.org.

Baycrest reserves the right to modify, alter or otherwise update this Privacy Policy at any time without prior notice to you. You agree to be bound by such modifications, alterations or updates and agree that any subsequent use by you or the Website following changes to this Privacy Policy is your acceptance of any such changes.

Updated July 18 2023