Review Agreements

A. For Treatment Providers Part of an Organization

This Section A of the Provider Terms of Use is applicable to treatment providers that are associated with a provider organization that has a clinic account on the Platform.

Pursuant to an agreement between your organization and Greenspace Mental Health Ltd. (“Greenspace”), the platform located at https://greenspacehealth.com/ and https://app.greenspacehealth.ca/ (“Platform”) is made available by Greenspace for use by your organization’s treatment providers and patients.

By creating a Therapist account and accessing the Platform, you acknowledge and agree that your access as a treatment provider is provided to you strictly in connection with your organization’s agreement with Greenspace (the “Agreement”). The terms and conditions applicable to your account and use of the Platform —including privacy, security, and permitted use - are governed by the Agreement, including the conditions outlined below. If you require details or a copy of the Agreement, please contact your organization’s designated representative.

Terms of Use:

To use the Platform with a patient you are required to have a clinical relationship with the patient outside of the Platform.
Greenspace is a technology provider only and has no role in the credentialing, delivery, or oversight of clinical care. You are solely responsible for the care provided to your patients.
While the Platform may provide access to certain general medical information, it cannot and is not intended to provide medical, health care or other advice to patients. The content on the Platform is not and should not be considered medical advice or a substitute for individual medical advice, diagnosis or treatment.
The Platform and services do not constitute a medical device, clinical decision support system, or other diagnostic tool. For greater clarity, no services provided by Greenspace shall be construed as a diagnosis of a Patient.
Greenspace is not responsible for the quality or effectiveness of the assessments provided by the Platform. You are responsible for selecting the appropriate assessments for your patients.
Upon registration, you will choose a username and password. You alone are responsible for keeping that password and username confidential and for any and all activity that occurs on Greenspace under such password or username. You agree to immediately notify Greenspace of any unauthorized use of your password or username or any other breach of security. You agree not to give or make available access to your account to any unauthorized individual.
You will maintain the confidentiality of Personal Health Information in accordance with all applicable federal, provincial/territorial laws and local regulations, as well as the ethical and professional standards applicable to you currently.
As a condition of your continued access to and use of Greenspace, you agree not to:

knowingly include or use any false or inaccurate information in any profile;
circumvent, disable, or otherwise interfere with security-related features of the Platform;
attempt to probe, scan or test the vulnerability of the Platform or any other Greenspace system or network or breach, impair or circumvent any security or authentication measures protecting the Platform; or
copy, disassemble, reverse engineer, decompile or otherwise attempt to discover the source code of the Platform;

Greenspace is not an electronic medical record system and you are solely responsible for maintaining your patients’ medical records in accordance with applicable laws, regulations and health regulatory college policies.
You acknowledge that Greenspace or its third party licensors and service providers shall own and retain all right, title and interest in and to all intellectual property rights in the Platform and services, including all names, copyrights, patents, trade secrets, logo designs, trade names, trade-marks and other intellectual property rights, data and information
You may close your account at any time and for any reason by providing written notice to Greenspace (support@greenspacehealth.com). Upon any termination by you, your account will no longer be accessible. Any cancellation request will be handled within 30 days of receipt.
You will be made aware of any changes to these Terms of Use or to the Platform, via email, or by posting notices on https://greenspacehealth.com/ or https://app.greenspacehealth.ca/. Your continued use of the Platform after notice of any changes constitutes acceptance of the updated Terms of Use.
These Terms of Use are subject to and incorporate by reference your organization’s Agreement with Greenspace and the Privacy Policy (Authorized Users). If you require further details, please contact your organization’s designated representative.

B. For Independent Treatment Providers

This Section B of the Provider Terms of Use is applicable to independent Treatment Providers that are not associated with a provider organization that has entered into an agreement with Greenspace to make the platform available to its providers and patients.

These terms of use (the “Terms of Use” ) govern your access and use of the public website located at https://greenspacehealth.com/ (the “Website”) and the private portal which requires registration to be accessed located at https://app.greenspacehealth.ca/ (the “Private Portal”, and together with the Website, the “Platform”). The words “Greenspace,” “we,” “us,” or “our” mean, collectively, Greenspace Mental Health Ltd. and all of its respective affiliates, successors or assigns. “You” or “your” means the regulated professional (“Treatment Provider”) who is permitted to provide psychotherapy services and who opens an account on the Platform. Treatment Providers may include, but are not limited to, psychiatrists, psychologists, social workers, occupational therapists, and psychotherapists.

By creating a Therapist account and accessing the Platform, you acknowledge and agree to be bound by these Terms of Use, which constitute a binding legal agreement between you, as a user of the Services (as defined in Section 4 below), and Greenspace. The obligations set forth in these Terms of Use are in addition to, and not in lieu of, your professional and legal obligations as a regulated professional.

1. Documents Incorporated by Reference

These Terms of Use incorporate by reference the following documents, which shall be construed as forming part of these Terms of Use.

2. Patients

“Patient” means (i) any person who opens an account on the Platform; (ii) any person whose information you input and record on the Platform; or (iii) a parent or legal guardian of a Patient who opens an account on the Platform.

In order to use the Services and Platform in respect of a Patient, you are required to have a clinical relationship with the Patient outside of the Platform. You are solely responsible for obtaining your Patients’ informed consent, where applicable, to treatment using the Platform or Services.

3. Services

The Platform shall enable the provision of the following services: (i) facilitate the delivery by you of assessments to Patients; (ii) enable the display of the results of assessments to you and your Patient(s); (iii) enable the display of aggregate assessment results to you; (iv) facilitate the entry and retention of progress notes and documents; and (v) facilitate the entry and retention of Patient profile information (the “Services”).

THE SERVICES DO NOT INCLUDE THE PROVISION OF HEALTH CARE SERVICES, MENTAL HEALTH SERVICES, SOCIAL OR PSYCHOTHERAPY SERVICES, OR ANY OTHER PROFESSIONAL SERVICES BY GREENSPACE. Greenspace is a technology provider only and has no role in the credentialing, delivery, or oversight of clinical care. You are solely responsible for the care provided to your Patients.

4. Medical Advice

While the Platform and Services may provide access to certain general medical information and is used to store Personal Health Information, the Services cannot and are not intended to provide medical, health care or other advice to Patients. THE CONTENT ON THE SYSTEM IS NOT AND SHOULD NOT BE CONSIDERED MEDICAL ADVICE OR A SUBSTITUTE FOR INDIVIDUAL MEDICAL ADVICE, DIAGNOSIS, OR TREATMENT. No representation or warranty is made that any particular assessment or treatment is safe, appropriate or effective, and Greenspace does not endorse or advocate any treatment method.

5. Diagnosis

The Platform and the Services do not constitute a medical device, clinical decision support system, or other diagnostic tool. If permitted, you are responsible for making your own diagnosis of the Patient or must receive such diagnosis from a qualified health care provider. For greater clarity, no Services provided by Greenspace shall be construed as a diagnosis of a Patient.

6. Assessments

Greenspace is not responsible for the quality or effectiveness of the assessments provided by the Platform. You are responsible for selecting the appropriate assessments for Patients.

7. Use Rights

While you are a registered user of the Platform and subject to the terms of these Terms of Use, Greenspace grants you a limited, non-exclusive, non-transferable, non-sublicenseable and revocable right to access and use the Platform as set out in these Terms of Use (the “Access Grant”). No licenses or other intellectual property rights in the Platform or IP Element (as defined in Section 9 below) are granted to you by implication or otherwise, except for the Access Grant and rights expressly granted in this Agreement.

8. Use Restrictions

You shall not, directly or indirectly: (a) copy, disassemble, reverse engineer, decompile, translate or create derivative works based upon the Platform; (b) license, sell, rent, lease, transfer, grant any rights in or otherwise commercially to exploit the Platform or the Services to any other party; (c) upload, post, email, transmit or otherwise use any IP Elements in any manner not expressly permitted by this Agreement without the prior written consent of Greenspace; (d) use the Services to collect or store Personal Information about other users without their express permission unless otherwise permitted by law; (e) knowingly include or use any false or inaccurate information in any profile; (f) circumvent, disable, or otherwise interfere with security-related features of the Platform or features that prevent or restrict use or copying of any IP Elements; (g) attempt to probe, scan or test the vulnerability of the Platform or any other Greenspace system or network or breach or impair or circumvent any security or authentication measures protecting the Platform or the Services; or (h) remove any copyright and other notices that are on the Platform or any of Greenspace’s social media websites.

9. Intellectual Property

You acknowledge that Greenspace or its third party licensors and service providers shall own and retain all right, title and interest in and to all intellectual property rights in the Platform and Services, including all names, copyrights, patents, trade secrets, logo designs, trade names, trade-marks and other intellectual property rights, data and information (collectively, the “IP Elements”). Any suggestions, enhancement requests, feedback, recommendations or other information provided by the you in respect of the Platform’s functionality shall be owned by Greenspace and shall be deemed included in the IP Elements.

10. Personal Information and Personal Health Information

For the purposes of this Agreement, Personal Information shall include (i) Personal Health Information, as defined in this Section 10; and (ii) De-identified Information, as defined in Section 12. “Personal Information” and “Personal Health Information” shall each have the meanings set out in applicable privacy statutes, including without limitation, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and substantially similar provincial privacy statutes, the Freedom of Information and Protection of Privacy Act (Ontario) (“FIPPA”) and other provincial/territorial/municipal statutes applicable to government institutions and the public sector, the Personal Health Information Protection Act (Ontario) (“PHIPA”) and other health-related privacy statutes, as they may be amended from time to time (collectively, the “Privacy Laws”). “Process” or “Processing” or “Processed” means the collection, recording, organization, structuring, alteration, use, access, disclosure, copying, transfer, storage, deletion, combination, restriction, adaptation, retrieval, consultation, destruction, disposal or other use of Personal Information.

11. Customer Information.

As between the Parties, any information and documentation, which may be uploaded into the Platform or otherwise provided by you to Greenspace in connection with these Terms of Use, including all Personal Information Processed by Greenspace on behalf of you, shall remain the property of you (“Customer Information”). All Customer Information shall be treated as confidential information. For the avoidance of doubt, Customer Information does not include Aggregated Statistics, as defined in Section 13. You hereby grant to Greenspace a non-exclusive, royalty-free, worldwide license to reproduce, distribute, and otherwise use and display the Customer Information and perform all acts with respect to the Customer Information as may be necessary for Greenspace to provide the Services to you in accordance with these Terms of Use and your instructions, and subject to Section 13, a non-exclusive, perpetual, irrevocable, royalty-free, fully paid up, worldwide license to reproduce, distribute, modify, and otherwise use and display Customer Information incorporated within the Aggregated Statistics.

12. De-Identified Information

Any De-identified Information within Greenspace’s control will not be used by Greenspace, either alone or in combination with other information, to identify a specific individual. For the purpose of these Terms of Use, “De-identified Information” means information that has been de-identified to remove all direct personal identifiers in accordance with applicable Privacy Laws and Greenspace’s Privacy Policy (Authorized Users). Greenspace will (i) treat De-identified Information as Personal Information under these Terms of Use; and (ii) use De-identified Information to improve its Services and to train data for machine learning development in accordance with Greenspace’s Privacy Policy (Authorized Users).

13. Aggregate Statistics

Notwithstanding anything to the contrary in these Terms of Use, Greenspace may monitor your use of the Services and collect and compile Aggregated Statistics. For the purpose of these Terms of Use, “Aggregated Statistics” means data and information related to your use of the Services and Greenspace’s provision and operation of the Services for Customer that has been aggregated and anonymized to permanently remove all (direct and indirect) personal identifiers in accordance with applicable Privacy Laws and Greenspace’s Privacy Policy (Authorized Users). For greater clarity, Aggregated Statistics refers to Anonymized Information (as defined in Greenspace’s Privacy Policy (Authorized Users). You agree that Greenspace may (i) publish Aggregated Statistics through various media platforms and academic journals, in compliance with applicable laws, and (ii) share Aggregated Statistics with Greenspace’s current and prospective customers; provided that such Aggregated Statistics do not identify a specific individual, customer or Customer Information.

14. Platform Fees

Access to the Platform requires payment of the applicable fees posted on the Website (“Platform Fees”), plus applicable taxes. Users may choose to pay the Platform Fees on a monthly or annual basis in advance of each subscription period. By submitting payment information, you authorize Greenspace to charge the selected payment method on a recurring basis until the subscription is canceled in accordance with these Terms of Use. Platform Fees are subject to change, and any updates will take effect at the start of the next billing period after notice is provided.

15. Termination

You may cancel your subscription at any time through your account settings or by contacting Greenspace support. Cancellation will take effect at the end of your current subscription period, and you will continue to have access to the Platform until that time. Greenspace does not provide refunds for any partial subscription periods.

Greenspace may suspend or terminate your access to the Platform at any time, with or without notice, if you breach these Terms of Use, if required by law, or if your payment is not successfully processed. Upon termination, your Access Grant and use the Platform will immediately cease.

16. Representations and Warranties

You represent and warrant that (a) you have the legal capacity and authority to agree to acknowledge and agree to these Terms of Use; (b) are responsible for the accuracy of all registration information you submit; (c) have the legal authority and all rights necessary to provide the Customer Information to Greenspace hereunder, your provision of the Customer Information to Greenspace hereunder does not and will not violate or conflict with or result in a breach of any terms, conditions, duties or obligations you have to any third party or any other rights of any third party or any applicable law, rule or regulation; (d) you are and will be at any time you use the Platform, authorized to provide services to Patients, and shall meet all other legal requirements to provide your services to Patients in the provinces and territories in or from which you provides such services; (e) you shall use the Platform and the Services in accordance with all applicable laws and regulations, including all applicable Privacy Laws; (f) all Personal Information provided or otherwise made available to Greenspace and all instructions for Processing is done in compliance with applicable law, including without limitation, applicable Privacy Laws; (g) you shall provide appropriate notices and obtain all required consents or fall within appropriate exemptions under applicable Privacy Laws to enable Greenspace to Process Personal Information, including De-identified Information, in accordance with these Terms of Use. You acknowledge that Greenspace may suspend its access to the Services without warning or terminate for material breach in accordance with Section 15 if you breach of any of the foregoing representations and warranties or if you fail to pay the Platform Fees in accordance with Section 14.

17. Privacy

You acknowledge that Greenspace is acting in the capacity of an electronic service provider to you in Processing Personal Information of users using the Platform and Services. Greenspace will Process such Personal Information only on your behalf to deliver the Services and provide the Platform in accordance with applicable Privacy Laws, its Privacy Policy (Authorized Users) (incorporated herein by reference), the Terms of Use, or your other documented instructions, whether in written or electronic form. Greenspace will not disclose or transfer Personal Information to, or allow access to Personal Information (each, a “Disclosure”) by any third party (not including affiliates or subcontractors of Greenspace) without your express prior written consent, unless such Disclosure is required by applicable law. However, except in cases of gross negligence or willful misconduct, Greenspace will not be liable for any unauthorized disclosure of Personal Information despite the implementation of reasonable administrative, technical, and physical safeguards.

You acknowledge and agree that (i) Greenspace is not a “health information custodian” or “health information network provider” as those terms are defined under PHIPA or equivalent terms under concordant legislation in other provinces and territories; and (ii) Greenspace is not an electronic medical record system and you are solely responsible for maintaining your Patients’ medical records in accordance with applicable laws, regulations and health regulatory college policies.

18. Indemnification

You agree to defend, indemnify and hold harmless Greenspace, its affiliates, members, directors, officers, employees, agents, and licensors from and against any third party losses, expenses, damages, claims, fines, penalties, costs and liabilities (including reasonable legal and accounting fees) resulting or arising from (i) your (or anyone using the your password or username) use of the Platform in a manner that breaches the terms of these Terms of Use; or (ii) any negligent act or any wilful misconduct of yours.

19. Warranty

Except as specifically set out in these Terms of Use, the Platform, Services, IP Elements, and all materials, information, products and services included therein, are provided “AS IS” and “AS AVAILABLE” and Greenspace expressly disclaims all warranties of any kind, express, implied, or statutory, including without limitation all implied warranties of title, merchantability, fitness for a particular purpose, non-infringement, and all warranties arising from course of dealing or performance, usage, and trade practice. You acknowledge that you are solely responsible for use of the Services and IP Elements. Greenspace makes no warranty of any kind that the IP Elements, Services, Platform, content or results of the use thereof, will meet your or any other person's requirements, operate without interruption, achieve any intended result, be compatible or work with any software, system, or other services, or be secure, accurate, complete, free of harmful code, or error free. Greenspace make no warranty that the content accessed by you on the Platform or using the Services satisfies the laws and regulations requiring the disclosure of information for prescription drugs.

In addition, Greenspace and its licensors and affiliates disclaim any warranties regarding accuracy, reliability, timeliness and performance of the Services, and the Services may experience service interruptions. No advice or information provided to you by Greenspace will create any warranty that is not expressly stated in these Terms of Use.

Greenspace makes no representations concerning, and does not guarantee, the accuracy of the Services, including, but not limited to, any information provided through the Services or their applicability to your individual circumstances. Greenspace’s services and website content are developed for use in Canada and Greenspace and its licensors and affiliates make no representation or warranty concerning the services or website content when they are used in any other country.

The laws of certain jurisdictions, including Quebec, do not allow the exclusion or limitation of legal warranties, liability or certain damages or limitations of representations made concerning goods or services. If these laws apply to you, some or all of the exclusions or limitations in these Terms of Use may not apply to you.

20. Limitation of Liability

You acknowledge that Greenspace is not a health care provider, licensed or otherwise. Greenspace cannot and will not assume responsibility for or control over the care of any patient, which shall, at all times remain your responsibility. Greenspace will not be responsible for any activity that involves the practice of medicine or the provision of health care services or social or psychotherapy services. For greater clarity, Greenspace does not provide any medical treatment, advice or opinions to Patients.

You acknowledge and agree that Greenspace is not responsible for any inaccuracy or incompleteness of information on the Platform that is the result of an error by you. Greenspace is not responsible for the results obtained from the use of the Platform or for the provision of Services as a result of reliance on any Personal Information or other data provided by a Patient.

In no event will Greenspace be liable for any special, indirect, reliance, incidental or consequential damages of any kind, lost or damaged data, lost profits or lost revenue, whether arising in contract, tort (including negligence), or otherwise, even if Greenspace has been notified of the possibility thereof.

Greenspace’s liability for all claims arising under or relating to these Terms of Use (including but not limited to warranty claims), regardless of the forum and regardless of whether any action or claim is based on contract, tort, or otherwise, shall not exceed the aggregate fees paid by you to Greenspace in the last 30 days.

21. Liability Insurance or Equivalent Coverage

You are required to maintain appropriate insurance coverage to conduct your practice and provide psychotherapy services to each Patient and to use the Services and the Platform. You acknowledge that Greenspace does not maintain insurance coverage to cover the provision of health care or psychotherapy services by you. It is your sole responsibility to confirm with your insurance provider whether you are covered for all liabilities potentially arising from the provision of health care or psychotherapy services to Patients and to use the Services and the Platform.

22. Electronic Communications

You agree that all electronic communications received by Greenspace in connection with the Services, including communications directing Greenspace to take an action with respect to your account, that match you account information or other identity information you have provided when enrolling in or using the Platform, will be deemed valid, authentic and binding. You agree that all electronic communications it makes, including but not limited to data entry, will not be fraudulent or, to the best of its ability, otherwise incorrect, and that you have the right to disclose any information that it discloses to Greenspace.

23. Changes and Interruptions in Service

Greenspace reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, the Platform (or any part thereof) with or without notice. Further, Greenspace reserves the right to change these Terms of Use at any time and to notify you by posting an updated version of the Terms of Use on this Website. You are responsible for regularly reviewing the Terms of Use, including, without limitation, by checking the date of “Last Update” at the bottom of this document. Continued use of the Platform after any such changes shall constitute your consent to be bound by such changes, with continued provision of the use of the Platform constituting consideration from Greenspace to you for so being bound. Your only right with respect to any dissatisfaction with (i) these Terms of Use, (ii) any policy or practice of ours in operating the Platform, or (iii) any content available through the Platform, is to stop using the Platform.

We may, from time to time perform maintenance upon the Platform or experience hardware, software or other problems related to the Platform, resulting in interrupted service, delays or errors in the Services. We will attempt to provide prior notice of such interruptions, delays or errors but cannot guarantee that such notice will be provided.

24. Area of Service

Unless otherwise agreed by Greenspace, the Services described in these Terms of Use are solely offered within Canada.

25. Assignment

These Terms of User are personal to you and you may not assign these Terms of Use or your rights to the Services to any other party. We expressly reserve the right to assign these Terms of Use and to delegate any of its obligations hereunder, under our sole discretion and without your consent. We may also assign or delegate certain of our rights and responsibilities under these Terms of Use to independent contractors or other third parties.

26. No Waiver

We shall not be deemed to have waived any of our rights or remedies hereunder unless such waiver is in writing and signed by us. No delay or omission on our part in exercising any right or remedy shall operate as a waiver of that right or remedy or any other rights or remedies. A waiver on any particular occasion shall not be construed as a bar or waiver of any rights or remedies on future occasions.

27. Governing Law

Unless the applicable laws of your jurisdiction, such as Quebec, require that the laws of its jurisdiction govern, these Terms of Use will be governed by and construed in accordance with the laws of the Province of Ontario and of the laws of Canada applicable therein. In the event of a dispute between the Parties with respect to the Agreement, the Parties shall: (i) first attempt to resolve the dispute by escalating the discussion within the Parties; and (ii) should the matter not be resolved through an internal escalation process, seek resolution through one or more forms of alternative dispute resolution.

28. Entire Agreement

These Terms of Use and any and all other legal notices or statements posted on the Platform constitute the entire agreement between you and Greenspace with respect to the use of the Platform and Services.

29. Notice

Notices to you may be made via email, or in cases of changes to these Terms of Use or to the Services offered by the Platform, by posting notices or links to such notices on the Platform. Your continued use of the Platform after notice of any changes constitutes acceptance of the updated Terms of Use.

30. Language

You agree that it is the express wish of the parties that this agreement and all related documents be drawn up in English. Vous êtes d’accord que c’est la volonté expresse des parties que la présente convention ainsi que les documents qui s’y rattachent soient rédigés en anglais.

31. Independent Parties

These Terms of Use do not create a partnership, joint venture, or relationship of principal and agent or employer and employee between you and Greenspace or any of Greenspace’s employees, agents, representatives, or subcontractors. Under no circumstance shall you or Greenspace be considered the agent of the other. Each party shall have no authority to assume or create any obligation whatsoever, express or implied, in the name of or on behalf of the other party. You are an independent practitioner who is solely responsible for any health care services or social or psychotherapy services provided to Patients.

If you have any questions or comments regarding these Terms of Use please contact us at support@greenspacehealth.com

Last Update: July 22, 2025

Greenspace Mental Health Ltd. ("Greenspace"", "we" or "our") provides a digital platform that facilitates: (i) the measurement of patient progress and outcomes; (ii) the display of measurement information to patients and their health care provider(s); and (iii) other functions, tools and resources for the purpose of supporting the delivery of mental health care services (collectively, the "Services"). We know that the users of our Services are entrusting us with personal and sensitive information and the privacy of our users is extremely important to us. We are committed to protecting privacy and safeguarding personal information.

Plain Language Summary of Our Privacy Practices
Scope of this Privacy Policy
Who Has Access to Our Services
What is Personal Information?
What is not Personal Information?
Personal Information of Minors
Consent to the Collection, Use and Disclosure of Your Personal Information
How We Collect and Use Your Personal Information
How We Use Cookies and Other Similar Tracking Technologies
How We Use Third Party Analytics Tools
How We Use Anonymized Information
How We Use De-Identified Information
How We Use Artificial Intelligence and Machine Learning
How We Share or Disclose Your Personal Information
How We Safeguard and Retain Your Personal Information
Where We Store and Process Your Personal Information
Your Privacy Rights
Third Party Links
Changes to this Privacy Policy
Contact Us

1. Plain Language Summary of Our Privacy Practices

While this summary is not exhaustive, here are some of the key provisions in this Privacy Policy that you should be aware of:

We are a service provider to our Customer: In providing our Services, Greenspace acts as an electronic service provider to healthcare organizations or individual therapists, who are our Customers (as defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy). All personal information collected, used or disclosed by Greenspace is done in accordance with our agreement with our Customer, as reflected in this Privacy Policy.
You must be an Authorized User of our Customer: In order to use the Services, you must be an Authorized User (Administrator, Treatment Provider or Patient, each defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy) of our Customer.
You must provide consent: Prior to using the Services, you must consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy as described below under section 7 (Consent to the Collection, Use and Disclosure of Your Personal Information) of this Privacy Policy.
We only collect and use what is needed: We only collect and use personal information that is required to provide our Services on behalf of our Customer. This personal information is provided: (i) directly by you; (ii) indirectly and with your consent by your Treatment Provider or an Administrator; or (iii) indirectly by your parent, legal guardian or substitute decision-maker if you are a minor Patient.
We do not trade, rent or sell personal information: Under no circumstances will Greenspace trade, rent or sell your personal information.
We do not disclose your personal information, except as described in this Privacy Policy: We do not disclose or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy Policy.
We safeguard your information: We have implemented reasonable administrative, technical and physical measures to safeguard your personal information that are appropriate to the sensitivity of the information. All personal health information is stored in Canada.
Contact us: You can contact us at any time to exercise your privacy rights, as described below under section 17 (Your Privacy Rights) of this Privacy Policy. Since we are processing your personal information in our capacity as a service provider, certain requests will be forwarded to our Customer for response.

Please read this Privacy Policy carefully. If you have any questions or concerns regarding this Privacy Policy, please contact us at privacy@greenspacehealth.com.

2. Scope of this Privacy Policy

This Privacy Policy describes how we collect, use and disclose your personal information, (including your personal health information) when you use our Services in your capacity as an Authorized User (as defined below under section 3 (Who Has Access to Our Services) of this Privacy Policy). It applies whether such information is collected electronically at https://app.greenspacehealth.ca or any website or other platform on which this Privacy Policy appears (the "Platform"), in person, over the telephone, in writing, via email messages or text messages. We may provide additional "just-in-time" disclosures or additional information about our data collection, use and disclosure practices. These notices may supplement or clarify our Privacy Policy or may provide you with additional choices about how we will process your personal information. This Privacy Policy does not apply to information which we may receive from you through your access and/or use of the general Greenspace website at https://greenspacehealth.com/ (the "Website"). If you are visiting the Website, please refer to the Website Privacy Policy to learn more about Greenspace's privacy practices in relation to the Website.

Please note that privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. While the Platform can be accessed from different countries around the world, the Platform and our Services are only intended for users in Canada. As such, this Privacy Policy is designed in accordance with applicable privacy laws in Canada. Please note that unless stated otherwise, any reference to personal information in this Privacy Policy includes personal health information.

3. Who Has Access to Our Services

In providing our Services, we act as an electronic service provider to our customers, such as healthcare organizations or individual therapists ("Customers"), who may be classified as health information custodians, custodians or trustees of personal health information, as such terms are defined in applicable privacy statutes.

As an electronic service provider, we supply our Services for the purpose of enabling our Customers to use electronic means to collect, use, disclose, modify, retain, dispose or otherwise process personal information. Our collection, use, disclosure and other processing of your personal information is done in accordance with our agreement with our Customer, which is reflected in this Privacy Policy.

You are entitled to use our Services if you fall within one of the following categories of authorized users of our Customer:

supervisors, managers or administrators of the Customer that do not provide direct clinical treatment for Patients (each, an "Administrator");
treatment providers, therapists or clinicians of the Customer, including, but not limited to, psychiatrists, psychologists, social workers, occupational therapists, and psychotherapists (each a "Treatment Provider"); and
individuals with whom the Customer or its Treatment Provider(s) have a clinical health care relationship for whom a file has been created on the Platform, whether such file has been opened by: (i) that individual; (ii) the Treatment Provider or Administrator for that individual; or (iii) a parent, legal guardian or substitute decision maker of that individual for that individual or themselves) (each, a "Patient" and collectively, with Administrators and Treatment Providers, the "Authorized Users").

Patients receiving services from a Treatment Provider may receive additional information regarding access, use and disclosure of their personal information from their Treatment Provider or an Administrator.

4. What is Personal Information?

For the purpose of this Privacy Policy, "personal information" means any information that could be reasonably used on its own, or in combination with other information, to identify an individual or as otherwise defined under applicable privacy statutes. Personal information includes personal health information and de-identified information (as defined below).

"Personal health information" may be defined differently under applicable privacy statutes but generally refers to any identifying information about an individual's physical or mental condition, including family medical history; the provision of health care to the individual; and a plan of service for the individual. It may also include the individual's eligibility for health care coverage and the individual's health card number issued by the applicable governmental authority, as well as the identity of a health care provider(s) and a substitute decision-maker(s) for the individual.
"De-Identified Information" is information that has been de-identified to remove all direct personal identifiers in accordance with applicable law, our internal policies and industry best practices, but retaining some indirect identifiers such as a unique Greenspace system-generated profile identification that is associated with a specific individual of our Platform. Any De-Identified Information cannot be used alone to identify an individual. We treat all De-Identified Information as personal information and safeguard such information in accordance with this Privacy Policy. For specific information on our use of De-Identified Information, please refer to section 12 (How We Use De-Identified Information) of this Privacy Policy.

5. What is not Personal Information?

Personal information does not include "business contact information". Under applicable privacy laws, business contact information refers to any information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual's name, position or title, work address, work telephone number or work e-mail address. Accordingly, the business contact information of Administrators and Treatment Providers is not considered personal information for the purposes of this Privacy Policy.
Personal information does not include anonymized information. "Anonymized Information" is information that has been aggregated and anonymized to permanently remove all (direct and indirect) personal identifiers in accordance with applicable law, our internal policies and industry best practices in a manner that: (i) does not identify an individual; and (ii) ensures that at all times, it is reasonable to expect in the circumstances, it no longer allows a person to be identified, directly or indirectly. Any Anonymized Information within Greenspace's control will not be used by us, either alone or in combination with other information, to identify a specific individual. For specific information on our use of Anonymized Information, please refer to section 11 (How We Use Anonymized Information) of this Privacy Policy.

6. Personal Information of Minors

We do not knowingly collect personal information of minors (i.e., anyone under the age of majority in their jurisdiction of residence), unless: (i) such minors have the capacity at law to consent to the collection, use and disclosure of their personal information; or (ii) with the consent of their parents, legal guardians or substitute decision-makers. Minors may only register for a user account on the Platform, if/when a Treatment Provider or Administrator has created a file on behalf of the minor, and (a) a parent, legal guardian or substitute decision-maker has created a participant account; (b) the Treatment Provider has received consent from a parent, legal guardian or substitute decision-maker to allow the minor to create a user account; or (c) the Treatment Provider determines that consent from a parent, legal guardian or substitute decision-maker is not required, which then permits the minor to create a user account and/or participate on the Service.

If you become aware that a minor has provided us with their personal information without appropriate capacity or consent, we encourage the parent, legal guardian or substitute decision-maker to contact us to have this information removed from our records.

7. Consent to the Collection, Use and Disclosure of Your Personal Information

We require Patient's consent to the collection, use and disclosure of their personal information. The way in which you can provide your consent depends on whether you are using our Services in your capacity as a Patient (which may include a minor Patient who has the legal capacity to provide consent), or an authorized representative (i.e., parent, legal guardian or substitute decision-maker) on behalf of a minor Patient who does not have the legal capacity to provide consent. As previously noted, business contact information of Administrators or Treatment Providers does not constitute personal information.

You, as a Patient, agree that by using our Services or otherwise providing us with personal information, consent to our collection, use and disclosure of such personal information for the purposes identified in, and in accordance with, the terms of this Privacy Policy. You must read and agree to this Privacy Policy by selecting the "I accept" checkbox made available to you before creating a user account on the Platform or completing an assessment remotely if you are a Patient. If you do not agree with the terms and conditions of this Privacy Policy, please do not use our Services.
If you are agreeing to this Privacy Policy as an authorized representative on behalf of (i) a minor Patient (in your capacity as a parent, legal guardian or substitute decision-maker of such minor Patient); or (ii) a Patient that does not have a user account or does not complete an assessment remotely (in your capacity as an Administrator or Treatment Provider of such Patient) you represent and warrant that you have the authority to bind such Patient to this Privacy Policy and that by agreeing to this Privacy Policy you are doing so on behalf of such Patient. In such circumstances, the terms "you" shall refer to such Patient and to you as the authorized representative. For example, when this Privacy Policy speaks of collection, use or disclosure of your personal information, it is referring to the personal information of the minor Patient on whose behalf the authorized representative is agreeing to this Privacy Policy and to any personal information of the authorized representative. Greenspace reserves the right to request proof from such authorized representative that they have the authority to bind a Patient to this Privacy Policy.

8. How We Collect and Use Your Personal Information

The information we collect depends on how you use the Platform and our Services. Only information that is necessary is collected. Below is a summary of the ways we collect and use your personal information:

Registering for Our Services:
- Patients can obtain access and use our Services in a number of ways once a file is created by the Patient or for the Patient by an Administrator or Treatment Provider (whether directly on the Platform, through an integration or the browser extension): (i) offline where your participation is directly facilitated by the Treatment Provider or Administrator; (ii) by invitation sent to you via an email and/or text message with a request to complete personalized assessments; (iii) by creating a Patient user account to allow you to complete personalized assessments and view assessment results (a "Patient Account"); or (iv) via a participant account created by a parent, legal guardian or substitute decision-maker if you are a minor.
- The information required to create a Patient Account includes: first and last name, email address, phone number and password, as well as additional personal information set by our Customer.
Delivering Assessments: In order to remotely deliver assessments to Patients:
- For Patients with a Patient Account, we use the Patient's name, email address and/or telephone number, as set by the Patient to send a link to the personalized assessment(s).
- For Patients without a Patient Account, we use the Patient's name, email address and/or telephone number, as set by their Treatment Provider or Administrator, to send a link to the personalized assessment(s).
Completing Personalized Assessments: We collect personal health information from Patients such as responses to assessment questions and quantitative assessment scores when Patients respond to a personalized assessment delivered by the Platform. We use this information to provide Patients, their Treatment Provider(s) and any appropriately permissioned Administrators, with a presentation of assessment results and progress.
Assessing Results of Personalized Assessments: We use the personal health information collected from Patients' responses to personalized assessments to enable Treatment Providers and Administrators to evaluate results and analyze Patients' progress. This information is provided to the Patient's Treatment Provider(s) and any appropriately permissioned Administrators to enhance their delivery of health services to their Patients, inform their care decisions and provide metrics about their practice in accordance with the Customer agreement.
Improving Our Platform and Services: We use De-Identified Information for internal purposes only to improve our Platform and Services, for example to analyze the usage of our Platform and Services to help inform our product and/or user experience decisions, and train data for machine learning development. We only use data for artificial intelligence and machine learning with permission as further described in section 13 (How We Use Artificial Intelligence and Machine Learning) below.
Providing Technical Support: We may use the personal information of an Authorized User in order to provide them the necessary technical support when using our Services.
Interacting With You: When any Authorized User contacts us with a comment, question or complaint, you may be asked for personal information that identifies you such as your name, address, email address and a telephone number along with any additional information we may need to promptly answer your question or respond to your comment or complaint. We use this personal information to respond to your inquiry and improve our Services' offerings.
Sharing our Newsletter and Other Updates: If you are an Administrator or Treatment Provider, we may use your name and email address, in accordance with applicable law, to provide you with copies of our newsletter or other updates about our products and Services that we believe may be of interest to you. You can unsubscribe at any time by clicking on the unsubscribe link included in every email or by contacting us as set out below at section 20 (Contact Us) of this Privacy Policy. We do not send newsletters or Services updates to Patients.

9. How We Use Cookies and Other Similar Tracking Technologies

Greenspace uses cookies, log files, web beacons and similar tracking technologies to remember user preferences and collect information about visitors to the Platform. Some cookies are required for the operation of the Platform and are not optional.

Cookies are small text files that our Platform can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our Platform where you are prompted to log in or that are customizable. If you have registered with our Platform, these cookies (i) may let us know who you are in order to authenticate and confirm your authorization to use the Platform and our Services, (ii) may be necessary to access your account information (stored on our servers) in order to deliver products and personalized services, and (iii) will provide us and our service providers with information that we will use to personalize our Platform and Services in accordance with your preferences.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Platform, you may not be able to take advantage of all of the features of our Platform.

Log files are records of all visits to the Platform, which are automatically generated. These files make a record of each visit to the Platform and log a number of details, that may include: the user's operating system; IP address; the date, time and duration of the visit; the pages and documents accessed; and the previous site accessed by the user (such as, the search engine that referred the user to the Platform).

We may also use pixel tags, web beacons, clear GIFs or similar technologies in connection with some of our Platform pages and HTML-formatted email messages to track the actions of users and email recipients, measure the success of our marketing campaigns, and compile statistics about Platform usage and email response rates. These technologies usually work in conjunction with cookies.

10. How We Use Third Party Analytics Tools

Greenspace uses Mixpanel as an analytics tool ("Mixpanel") to provide statistics about visitors to the Platform. For more information about Mixpanel, please follow the provided hyperlink. Mixpanel uses cookies and other identifiers to collect certain information such as user device or browser type, and user activity on our Platform such as click rates and bounce rates to measure and report statistics about user interactions on the Platform. Mixpanel is used for analysis, to create reports and to identify Platform trends.

Please refer to section 14 (How We Share or Disclose Your Personal Information) of this Privacy Policy for more detail on our analytics service provider (Mixpanel).

11. How We Use Anonymized Information

We fully anonymize and aggregate data based on responses to assessments, feedback on our Services, and the frequency and way users use our Services (a) to publish fully anonymized and aggregated data, metrics or insights regarding our Services on our Platform and through various communication channels; and (b) to share fully anonymized and aggregated data, metrics or insights with current and prospective Customers, to better understand assessment outcomes and benchmark our Services. The data we may publish or share using Anonymized Information includes high level aggregated statistics such as the number and types of assessments completed on our Platform, or the number of Patients that have used our Platform.

None of this Anonymized Information, directly or indirectly, identifies or can be linked back to any Patients, other Authorized Users or Customers. Notwithstanding the foregoing, with the express written consent of our Customer, Greenspace may associate Anonymized Information of Authorized Users of the Customer with the Customer.

12. How We Use De-Identified Information

In accordance with our Customer agreement, we may use automated systems to analyze De-Identified Information of Authorized Users collected via user input, cookies, analytics tools and other technologies (as described above) in order to: (i) improve the Platform and Services; (ii) personalize Authorized User's experience; (iii) automate certain aspects of the Platform; and (iv) protect the safety and security of the Platform. Notwithstanding the foregoing, De-Identified Information may also be used in accordance with section 13 (How We Use Artificial Intelligence and Machine Learning) of this Privacy Policy.

13. How We Use Data for Artificial Intelligence and Machine Learning

In accordance with our Customer agreement (and provided such Authorized Users have not opted out of such features), we may use automated systems to analyze De-Identified Information of Authorized Users collected via user input, cookies, analytics tools and other technologies (as described above) in order to: (i) use such data for machine learning training; and (ii) provide Authorized Users with certain artificial intelligence and machine learning features, such as predictive analytics.

14. How We Share or Disclose Your Personal Information

Under no circumstances will Greenspace trade, rent or sell your personal information. We will not disclose your personal information, without your consent, except as otherwise set out in this Privacy Policy.

Authorized Service Providers: In order to provide our Services, we have arrangements with our affiliated companies or certain necessary service providers that are subject to contractual agreements that include appropriate privacy standards in accordance with applicable privacy laws. We may transfer (or otherwise make available) your personal information to such affiliates and other third party service providers for the purpose of enabling such parties to provide certain services on our behalf that are directly related to the provision of our Services to you. To the extent that any personal information is provided to our affiliates and service providers, we require that they be bound by legally enforceable written obligations consistent with this Privacy Policy and that they are given only the information they need and solely for the purpose of performing their designated functions. Our affiliates and service providers are not authorized to use or disclose personal information for their own marketing or other purposes.

Our authorized affiliates and service providers that we share the personal information we collect fall into the following categories:

service providers that authorize and process payments on our behalf;
service providers that host our Platform, enable certain of its features, deliver assessments, and manage and analyze data;
service providers that send email and other communications;
service providers that are used to monitor our systems for reliability, security or compliance; and
service providers that are used to enable integration with other systems used by our Customers, including clinical systems, administrative systems and identity providers.

Analytics Service Provider (Mixpanel): We do not send personal information to Mixpanel, with the exception of IP addresses, which are sometimes required for the operation of such service. While an IP address is sent to Mixpanel, it is either not stored or is anonymized by Mixpanel so that the full IP address is not stored, and is not used for any purpose. Personal health information is not shared with Mixpanel at any time.
Business Transactions: Personal information (but not personal health information) may be disclosed in connection with a prospective or completed business transaction, as permitted in accordance with applicable privacy laws. In such cases, your personal information may only be used or disclosed by the recipient in order to assess and complete the transaction. After the transaction is closed, your personal information may only be used or disclosed by the recipient for purposes you have previously consented to and in accordance with this Privacy Policy, any existing agreements with the Customer, or as otherwise permitted by applicable privacy laws, unless subsequent consent is obtained from you for an additional purpose.
Legal, Compliance and Loss Prevention: Greenspace, our affiliates and our service providers may be required to provide your personal information in response to a lawful request such as: (i) a court order, search warrant or subpoena; (ii) for the purposes of investigating a breach of an agreement, contravention of law, or actual or suspected harm to persons or loss of property; or (iii) as otherwise required or permitted by applicable law. Under no circumstances, will Greenspace disclose your personal information (including any personal health information) unless such disclosure is permitted or required by applicable laws.

15. How We Safeguard and Retain Your Personal Information

We have implemented reasonable physical, organizational and technological measures appropriate to the sensitivity of the personal information in an effort to safeguard the personal information in our custody and control or that we process on behalf of our Customers to protect against theft, loss and unauthorized access, use, modification and disclosure. Such measures, which may necessarily evolve over time as the availability and effectiveness of methods vary, include the following:

restricting access to personal information to employees, contractors and third-party service providers who require access to fulfill their job or services, are bound by confidentiality and/or non-disclosure requirements and who are required to abide by this Privacy Policy and Greenspace's privacy and security policies;
restricting access to our systems, accounts and electronic databases or other electronic formats that may contain personal information through password protection and internal security policies; and
implementing technical security measures such as firewall technology, anti-malware screening and data encryption technology.

While Greenspace employs advanced data encryption technology when interfacing with our users, third party service providers and other partners, you should be aware that there is a residual risk in transmitting any data electronically. Despite our efforts, no security measure is perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. This risk is inherent in all Internet dealings.

You should exercise discretion when providing any personal information via email or text messages as such communications may not be encrypted. In particular, you should not include any personal health information or other sensitive information in your email or text messages sent to us.

If you suspect your personal information has been improperly accessed, used, or disclosed, please contact us immediately as set out under section 20 (Contact Us) of this Privacy Policy.

We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes stated above, as provided in our Customer agreements, or to otherwise meet legal requirements. We securely dispose of or anonymize personal information of Authorized Users once it has served such purposes, in accordance with applicable law and our agreement with the Customer.

16. Where We Store and Process Your Personal Information

All personal health information is stored in Canada.

Other types of personal information may be stored or processed by Greenspace or our authorized service providers in the United States. When this occurs, your personal information may be subject to the laws of such jurisdiction and accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. You can obtain more information about our policies and practices with respect to the use of third-party service providers outside of Canada by contacting us as described below, under section 20 (Contact Us) of this Privacy Policy.

17. Your Privacy Rights

You have the right to access, update and correct inaccuracies in your personal information, subject to certain exceptions prescribed by law. You may also withdraw your consent to our collection, use or disclosure of your personal information, however, in accordance with applicable law, such withdrawal of consent will not have retroactive effect. Please note that your withdrawal of consent may result in you being unable to continue to use our Services.

You may exercise the above rights or raise any questions or concerns about our privacy policies and practices by emailing us at the contact information set out below. We may request certain personal information for the purposes of identity verification. Other than responding to customer support requests such as password resets, since Greenspace is acting in the capacity as a service provider, we will forward requests for the exercise of user rights under privacy laws (i.e., access to or rectification of personal information and withdrawals of consent) to our Customer for response to you.

18. Third Party Links

The Platform may contain links to third party platforms. While we try to link only to platforms that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other platforms and this Privacy Policy does not apply to those platforms. We encourage you to review the privacy policies of each platform you visit.

19. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services.

When we make changes to this Privacy Policy we will revise the "Last Update" date at the bottom of this page. You should check back here periodically to find out if any changes have been made to this Privacy Policy. If we make substantial changes we will, as appropriate, prominently post these changes to our Platform and/or notify registered users of our Services.

If you disagree with any change to the Privacy Policy, please refrain from using our Platform or Services or otherwise providing us with your personal information. By continuing to use our Platform or Services or by providing us with personal information after we post or communicate a change to the Privacy Policy, you will signify your consent to the revised terms of the Privacy Policy.

20. Contact Us

Please contact our Privacy Officer at privacy@greenspacehealth.com if:

you have any questions or comments about this Privacy Policy;
you wish to access, update or correct inaccuracies in your personal information;
you wish to withdraw your consent to our collection, use or disclosure of your personal information as described in this Privacy Policy; or
you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

Since email communications are not always secure, please do not include personal health information or other confidential or sensitive information in your emails to us.

Last Update: July 22, 2025

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