Privacy Policy

Last Updated: June 1, 2022

About Your Privacy and This Privacy Policy

Speak Fluent recognizes the importance of privacy and the sensitivity of personal health information.  Speak Fluent has developed this Privacy Policy in accordance with PHIPA legislation to ensure that the personal health information of our clients is safeguarded and that clients and their families are made fully aware of our information practices.  PHIPA Legislation requires staff to adhere to each and every facet of the legislation. This means strict compliance to all rules under PHIPA are followed, when collecting, using, or disclosing PHI.

PHI Information Collection, Use and Disclosure

PHI is defined as identifying information about an individual in oral or recorded form, if the information:

  • relates to the physical or mental health of an individual, including information that consists of the health history of the individual’s family;
  • relates to the providing of health care to an individual, including the identification of a person as a provider of health care to an individual;
  • identifies an individual’s substitute decision-maker; or
  • Identifies an individual’s health card number.

PHI is collected about clients to facilitate and provide assessment and counselling/therapy services.  The information that we collect may include, for example, a client’s name, date of birth, address, health history, family history, records of visits to us and the care received during those visits.  We also collect background information with respect to our clients and their family members to the extent that it is relevant to the provision of treatment services.

PHI is collected about clients to facilitate and provide assessment and counselling/therapy services.  The information that we collect may include, for example, a client’s name, date of birth, address, health history, family history, records of visits to us and the care received during those visits.  We also collect background information with respect to our clients and their family members to the extent that it is relevant to the provision of treatment services.

By law and in accordance with professional standards, Speak Fluent maintains a record of services to, and contacts with, all clients.

All HICs and individual agents within the HIC are required to:

  • Have a Privacy Officer
  • Develop privacy policies
  • Implement parameters around health information which can or will be shared with other providers (i.e., locking the disclosure of specific facets of a file or record)
  • Collect only the amount of PHI that is required to perform our services
  • Ensure that only those parties that are providing service(s) have access to and knowledge of the individual file or record
  • Notify individuals if their information has been shared with or without intent with any party other than the person(s) who is/are providing service(s)
  • Ensure that all agents including staff, students, and volunteers are informed of their responsibility under PHIPA legislation.

Our Privacy and Security Policy is designed to support Speak Fluent staff to understand their legal and professional obligations to maintain the confidentiality of individuals seeking service through our agency. It provides an overview of the confidentiality requirements set out under the Personal Health Information Protection Act, 2004 (PHIPA) and to outline other professional obligations related to client confidentiality within our professional scope of practice – counselling and therapy.

Non-PHI Information Collection, Use, and Disclosure

Categories of Information Collected
For us to conduct the Services per professional and legal requirements, we may collect, use, and store the information described below. We also disclose certain information to third parties, as described further below. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy.

Visitor Data: Speak Fluent collects, uses, and stores data regarding user visits to its website and use of the Speak Fluent application ("Visitor Data"), including the particular pages visited or viewed by the user, the amount of time the user spent on the website or application, website errors experienced by the user, visits to the Speak Fluent "FAQ" page, and information about the browser or device used to access the website and application, such as the user’s mobile device ID and IP address. These practices apply to users who visit pages for prospective new customers as well as those who visit pages for prospective Service Providers.
Onboarding Data: In addition to the questionnaire responses provided by users (including Service Providers) in the process of initial registration, Speak Fluent collects, uses, and stores certain additional data from users during the onboarding process ("Onboarding Data"). This data includes the pages viewed by the user, whether the user clicks the "Get started" link to begin completing the questionnaire, and whether the user responds to any of the questionnaire prompts.

Transaction Data: Speak Fluent collects, uses, and stores certain information regarding payment for its services by users and related transactions on its website, such as whether a user completed payment for Speak Fluent’s services, signed up for Speak Fluent’s services using a trial offer, canceled or otherwise ended a trial, or completed a request to receive financial aid for Speak Fluent’s services ("Transaction Data").

Session Data: Speak Fluent collects, uses, and stores certain general data regarding user sessions such as whether a live session has been scheduled by the user, whether a Service Provider or user joins a scheduled session, when a session began and ended, and whether a session was canceled or re-scheduled.

Customer Data: Speak Fluent collects, uses, and stores certain data from users that have signed up for Speak Fluent’s services such as a user’s self-reported name or nickname, age, e-mail address, phone number, and emergency contact information ("Customer Data").

Communications Data: Speak Fluent collects, uses, and stores communications between users and Service Providers, and communications between users and Speak Fluent’s customer service team ("Communications Data").
Protecting this information is important for us. Other than in the ways detailed in this Privacy Policy, we will never use or disclose any information unless you requested or approved us to do so.

Purposes for Which Information Is Used

We may use the information we collect for one or more of the following purposes:
Communication with you

  • To contact you or provide you with information, alerts and suggestions where applicable
  • To verify your identity.
  • To complete an activity you requested, such as obtaining more information.
  • To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

Delivery of services to you

  • To manage your account, provide you with customer support, and ensure you are receiving quality service.
  • For billing and transaction processing purposes.
  • To match users with Service Providers and facilitate the Services.

Administration and improvement of services

  • To measure and improve the quality, effectiveness, and delivery of our services.


  • To personalize the website experience and to deliver content and product and service offerings relevant to individual interests, including targeted offers and ads.

Compliance with law

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To comply with applicable provincial and federal laws, including, but not limited to laws related to protecting client and public health and safety.
  • To allow therapists to comply with the licensure, legal and quality requirements in their jurisdictions.

Other uses with consent

  • Any other purpose with your consent.

Purposes for Which Information Is Disclosed to Third Parties

Information about you may be disclosed to third parties for one or more of the following purposes:

With your direction or consent: We may share your information with third parties if you request or direct us to do so.

Compliance with law: We may share your information with a court, a regulatory entity, law enforcement personnel, or pursuant to a subpoena, to comply with applicable law or any obligations thereunder.

Insurance company claims validation: We may share your information with the insurance provider for the following purposes:

  • verifying client information and validating claim information provided
  • reviewing previous claims, if applicable
  • assessing eligibility for benefits payments
  • assessing damage or injury and determining benefits
  • obtaining compensation or contribution from third parties
  • settling any disputes with third parties
  • facilitating claim adjustment activities with the collaboration of third parties as required (e.g., property repairs, rehabilitation)
  • detecting, investigating, and preventing errors and omissions
  • detecting, investigating, suppressing and preventing fraud or illegal activities, including by pursuing criminal or civil actions. Claim information may be pooled with information from other sources and may be subject to analysis for the limited purposes of preventing and investigating. For this purpose, the information may be disclosed to fraud prevention organizations, other insurance companies, and the police, and databases or registers used by the insurance industry to analyze and check information provided against existing information.
  • making claim payments
  • coordinating payments

Opting-out of Marketing Communication

You can opt out of receiving email marketing by unsubscribing using the unsubscribe link provided in all of our marketing email communications.

Cookies and Web Beacons

Like many websites, we use "cookies" and "web beacons" (also known as pixels) to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. A "web beacon" is a tiny and sometimes invisible image or embedded code, placed on a Web page or email that can report your visit or use to a third party. Web beacons are typically used by third parties to monitor the activity of users at a website for the purpose of web analytics, advertising optimization, or page tagging. Additional information regarding web beacons is available on Wikipedia.
You can change your browser's settings so it will stop accepting cookies and web beacons or to prompt you before accepting a cookie or web beacon.

Use of Cookies, Web Beacons, and Similar Technology for Analytics
We may use third party cookies or web beacons for the purposes of web analytics, attribution, and error management. Our website may use vendor services that use cookies, web beacons, and similar technology to collect and store anonymous information about you, including when you pay for services, load a page, indicate that you heard about us on television, sign up for services, enter your payment information (but the payment details are not disclosed), start the intake questionnaire, and your response as to the referral source to the website.
Our website also uses analytics vendors to collect information (for example, Visitor Data and Onboarding Data) about user actions on our websites for purposes of analytics and analysis of certain website usage.

Social and General Information Tools

We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, a Facebook page, a Twitter account, and others (collectively "Social and General Information Tools"). Any information you provide or share while using Social and General Information Tools may be read, accessed, collected by that site and users of that site according to their Privacy Policy.

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

The website may contain links to other websites, services, or offers that are owned, operated, or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third-party websites and services, and we do not have control over their privacy policies and terms of use.

Security of Information
While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built, and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with all applicable federal laws, provincial laws, and regulations regarding data privacy.

Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal processes (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Service Providers may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases: (a) reported or suspected abuse of a child or vulnerable adult; (b) serious suicidal potential; (c) threatened harm to another person; (d) court-ordered presentation of treatment.

Changes to the Privacy Policy
We may update this privacy provincialment at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to stop using our Services.

Contacting us

If you have any questions or concerns about this Privacy Policy or our privacy-related practices, please contact us by clicking the "Contact" link on any page in our website.