Service Privacy PoLicy


Last Updated: April 17, 2019

Layla Care Inc. (“Layla”, “we” or “us”) values the relationship it has with its clients and is committed to protecting their Personal Information (as defined below in Section III, “Definitions”) in accordance with applicable laws. When used herein, the term “client” means any individual who is receiving or has signed up or requested to receive the Layla Services (defined below).

I. Background

Layla is not itself a healthcare provider. Included in the services that Layla provides is the provision of assistance to individuals to find, choose, and facilitate access to therapists based on individuals’:
• current situation and goals for therapy;
• Insurance coverage considerations;
• scheduling and logistical preferences; and
• therapist preferences

(the “Layla Services”).

Therapists found and suggested by Layla for clients based on the above criteria are referred to in this Privacy Policy as “Therapists”. Therapists are service providers to and not employees of Layla. Layla’s selection of a Therapist is a suggestion only. The Therapists are solely responsible for the services that they provide and Layla is unable to guarantee the Therapist’s services. Clients are free to accept or reject such suggestion.

By receiving the Layla Services, you acknowledge that you have read and understood this Privacy Policy, and you agree and consent to the collection, use, and disclosure of your Personal Information in accordance with the terms set out below. If you do not agree with this Privacy Policy, you must not supply your Personal Information to us.

II. Application of Privacy Policy

This Privacy Policy describes Layla’s Personal Information management policies and practices, including how Layla collects, uses and discloses Personal Information in the course of providing the Layla Services.

This Privacy Policy applies to Personal Information collected by Layla from individuals in the course of providing the Layla Services.

This Privacy Policy does not cover:
• Personal Information provided by clients to a Therapist directly or indirectly through the Therapist’s employees or agents;
• use of Layla’s website https://www.layla.care and all webpages of that website, any other websites, digital properties, audio offerings, mobile applications and/or mobile enabled sites that are owned and/or operated by Layla and that do not have a separate terms and conditions (collectively, the “Layla Website”). A separate privacy statement, which can be found at www.layla.care/web-privacy-policy, applies to the Layla Website. This Privacy Policy is in addition to and not in substitution for the privacy policy that applies to the use of Layla’s Website; and
• any third party websites, including any websites linked from the Layla Website.  Clients are responsible for reviewing the privacy policies (if any) of any such third parties. Layla has no control over, and disclaims any and all responsibility for, the content, privacy policies or practices of any such third-party websites.

III. Definitions

“collect” means to gather, acquire, receive or obtain Personal Information by any means from any source, and “collection” has a corresponding meaning.
“consent” means voluntary agreement to the collection, use and/or disclosure of Personal Information for identified purposes.  Consent can be either “express” or “implied” and can be provided directly by the individual or by an authorized representative. “Express” consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Layla.  “Implied” consent is consent that can reasonably be inferred from an individual’s action or inaction.
“disclose” means to release or make available Personal Information that is in the custody or control of Layla to another person who is not using the Personal Information as an agent of Layla, and “disclosure” has a corresponding meaning.
“Personal Information” means information about a specific, identifiable individual, regardless of form, including, for example, name, date of birth, address, and medical history, but does not include, for example, information related to a person in their professional (work) capacity.
“use” means to handle or deal with Personal Information that is in the custody or control of Layla, and includes transferring the information to an agent acting on behalf of Layla.

IV. Collection of Personal Information by Layla

Layla may collect the following Personal Information from clients:
• name, contact information (including home address and email address), date of birth, medical history (including diagnoses and medication history), religious affiliation(s), gender, employment status, family physicians and other healthcare providers, and certain other Personal Information about the client
• credit card information and/or bank account information (where provided to us for the purposes of paying for the Layla Services); and
• other identifying information about the client that we did not request but that is provided by the client or any other person authorized to provide such information on the client’s behalf.

Please refer to Section V of this Privacy Policy for information regarding how Personal Information is used by Layla.

We will always collect Personal Information by fair and lawful means.  We may collect Personal Information from clients directly and/or from third parties, where we (and/or those third parties) have obtained the client’s consent to do so, or as otherwise required or permitted by applicable law.

Generally, however, we collect Personal Information directly from clients when they voluntarily provide it in the course of accessing the Layla Services. For example, Personal Information will be collected when a client:
• completes a client profile / intake form; and
• communicates with representatives of the Layla, via telephone, email or mail.

In any event, we limit our collection of Personal Information to that which is necessary to fulfill the purposes identified in this Privacy Policy. We collect, use and disclose client’s Personal Information only in accordance with this Privacy Policy.

Therapists will not disclose client’s Personal Information to Layla, and Layla will not collect Personal Information from Therapists.

V. How We Use Client’s Personal Information

We use client’s Personal Information for the following purposes:
• to plan and monitor the Layla Services;
• for quality control purposes;
• for billing purposes;
• to communicate with Therapists and their agents (as defined by applicable privacy legislation) about the client in order to determine whether the client will be matched with the Therapist and if so, to provide the Therapist with information to assist in their provision of services (e.g. psychotherapy, counselling) to the client; and
• to de-identify it (i.e. make it so that it is no longer identifies a client). Layla may use de-identified information (i.e. information that is no longer Personal Information) for any reason it determines appropriate.

From time to time and in addition to the Therapists, we may retain third party individuals or companies act as service providers to assist us in the provision of the Layla Services, or to perform certain tasks related to our business operations such as to provide audit, legal, consulting, operational or other services to us. Any such service providers will be subject to any restrictions and conditions that are necessary to enable Layla to continue to provide the Layla Services in accordance with applicable law.

VI. Access to Client’s Personal Information

Client’s Personal Information will be accessible to Layla’s employees and third party service providers, including the Therapists, on a “need-to-know” basis (i.e. where the employee or service provider requires such information for a purpose described above in Section V). However, prior to gaining access to Personal Information, we require all of our employees and third party service providers to enter into agreements with us under which they are bound to abide by applicable law (including privacy laws), this Privacy Policy and our other related policies and procedures.

VII. Disclosure of Personal Information

Layla will maintain the client’s Personal Information in strict compliance with this Privacy Policy, including by only disclosing Personal Information in accordance with applicable laws.

We identify to whom, and for what purposes, we may disclose Personal Information, at the time we collect such information from the client to whom it relates and obtain such client’s consent to such disclosure except as required or permitted by applicable law. For example, in accordance with section 7(2)(b) of PIPEDA, Layla may - without the knowledge or consent of the client - use the client’s Personal Information for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual.  In the event that we are required by applicable law to disclose a client’s Personal Information without their consent, we will aim to disclose only the specific information that is required in the circumstances and unless prohibited by applicable law from doing so, will inform the client about the disclosure.

VIII. Security and Safeguards

Information that we collect is stored on servers located in Canada. Layla uses standard security procedures and practices and other reasonable means appropriate to the nature of the Personal Information to protect it from theft, loss or unauthorized access, use (including modification and copying), disclosure or destruction.

IX. Retention of Personal Information

We will use, disclose or retain Personal Information that clients provide to us for as long as necessary to fulfill the purposes for which that Personal Information was collected, and as permitted or required by applicable law.

X. Changes to our Privacy Policy

Layla may, in its sole and absolute discretion, change this Privacy Policy from time to time. Layla will post a copy of the Privacy Policy as changed on the Layla Website. The top left hand corner of the Privacy Policy will contain the date on which the Privacy Policy was last updated.

clients should review the Privacy Policy from time to time. A client’s continued use of the Layla Services constitutes his/her agreement to abide by the Privacy Policy as changed.  If, at any point, a client objects to any term of the Privacy Policy, his/her sole recourse shall be to cease using the Layla Services.

We will make a copy of the most recent Privacy Policy available on the Layla Website. Anyone may also request a copy of the Privacy Policy currently in effect at any time by contacting us via the contact information listed below in Section XI.  

XI. Access, Correction, or Other Requests

Our Chief Privacy Officer can be contacted as follows: Email: contact@layla.care, Telephone: 1.888.695.2952

Clients have the right to request access to the Personal Information we have collected about them. Clients may request their Personal Information by submitting a written request to our Chief Privacy Officer. If you believe there is a mistake in your Personal Information you have the right to request that it be corrected, by sending a request to our Chief Privacy Officer.  If you have any other questions about this Privacy Policy or our privacy-related practices and procedures, please contact our Chief Privacy Officer.