Privacy Policy

Privacy Policy

Privacy Policy

February 10, 2023

February 10, 2023

February 10, 2023

YOUR PRIVACY IS IMPORTANT TO US

Nothing is more important to Homecoming than the protection of the data and information entrusted to us by our customers and users.  We fully understand that trust is difficult to achieve and easy to lose – particularly with someone’s private information. With this understanding, we specifically designed our application and all of our systems to ensure that we never lose your trust.

 

Homecoming will never sell the data it collects. We will only share de-identified, aggregated, and anonymized data with providers using the Homecoming platform to provide insight on treatment best practices, so we can continue to grow and learn as a community.

 

This Privacy Statement explains how Homecoming (an affiliate of Axis Mundi, Inc. --  collectively “Homecoming”) collects, processes and shares personal data about you when you visit our website or use our Services. If you have questions about these practices, please contact us using the contact details provided below.  Under some data protection laws, the person or entity that controls the purposes and means of processing personal data is known as a “data controller” and a person or entity that processes data on behalf of the data controller is known as a “data processor” or a “service provider.”  The person to which the data relates is known as the “data subject.” Each of these terms will be used throughout this Privacy Statement as defined herein.

 

The data Homecoming collects does not belong to us – it is instead entrusted to us so that we can provide our Services.  As such, you will always have the choice to stop providing us with data, to no longer allow us to share data or ask that we no longer retain your data.  These choices (and your right to be forgotten) may be exercised through our applications’ controls or by contacting privacy@homecoming.health.


WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement applies to Homecoming and to our affiliates and subsidiaries (“Homecoming” or “we”) when we collect, use and share data through our Homecoming products. References to our “Services” in this Privacy Statement include our public-facing website at www.homecoming.health (“Website”), Homecoming’s technology platform, and our Homecoming application (and any updates or variations thereto).  This Privacy Statement applies to personal data collected through the Services and not to any website or service that refers or links to a different privacy statement or privacy policy.


NOTICE TO END-USERS OF HOMECOMING SERVICES

When you use Homecoming Services, you are considered a data subject and Homecoming a data controller.  To provide the Services, Homecoming processes the data you provide. Because some of the data that you provide to Homecoming is sensitive personal information, Homecoming will not collect or process such data unless and until you have provided your express consent for that processing.  If you have questions about how Homecoming processes any of your personal data through the Homecoming application, please contact Homecoming at privacy@homecoming.health.


You must be at least 18 years old to use our Services and we do not knowingly collect, use, process, or disclose personally identifiable data from anyone under the age of 18.  None of our Services or products are directed to users under the age of 18 unless their parent or guardian consents.  Should we discover any user under the age of 18, we will immediately revoke their access and terminate their account.


At any time, you may ask us to inform you about the existence, use, and disclosure of your personal information and to give you access to that information. You may also question the accuracy and completeness of the information we have and ask that it be updated or changed. We will, of course, honor your requests unless we have, and provide you with, reasonable reasons why we cannot provide this information to you.


WHAT PERSONAL DATA DOES HOMECOMING COLLECT?

As noted above, Homecoming neither collects nor processes your personal data unless you consent. You may withdraw your consent at any time and, when we receive notice of your withdrawal, we will promptly stop collecting, processing, or using your data for any purpose.


When you use our Services, we collect information about you from a variety of sources. This includes data you provide to us directly, data we collect automatically (in a way similar to other services), data provided by your care providers as part of their services and information we infer from other sources. In all cases, our collection of data depends on your choices (described in more detail below).  Some of this data is collected once (for instance when you sign up for the Services) and other data may be collected on an ongoing basis as you continue to use the Services.


We do not ask for, access or track any location-based information (other than general geographic region information provided by your device). However, we may collect the region or area associated with the IP address assigned to your computer (if you are using our website at www.homecoming.health) or mobile device. 


INFORMATION YOU PROVIDE DIRECTLY.

We collect personal data you voluntarily and directly provide to us, including, for example:

  • Your registration/contact Information (username, password, and any image or photograph you choose to provide) when signing up for or using the Homecoming Platform. 

  • Information you choose to input into the features and activities on the Homecoming Platform (task completion, medical conditions, treatment results, well-being assessments,.

  • Contact information you provide to us in a webform when visiting one of the Websites; and

  • Information if you decide to provide us with feedback about the Homecoming application (for instance when you provide us with data for troubleshooting issues with the app).

You control what data you choose to provide directly to Homecoming in connection with the Services.  Please be aware that certain Services functionality may be impacted by this choice.  

 

INFORMATION COLLECTED AUTOMATICALLY.

When you use our Services or when you provide feedback about the Homecoming application, some information is collected automatically, for example:

  • Device information (model, operating system version, mobile network information, operating system and system settings, browser type, browser language, Internet Protocol (IP) address, country and time zone in which your device is located, and the Platform pages you viewed and how long you viewed them, and similar identifiers). Homecoming may associate some device information with your Homecoming account.

  • Mobile Application Information (application data and metadata stored on your device when permitted by your operating system settings).

  • When you choose to provide feedback about the Homecoming application, we may collect logging data (describing your experience with the application) solely for the purpose of assisting with troubleshooting and improving the application.


Also, as further described in the Cookie Notice our Websites and online services store and retrieve data using cookies set on your device.


INFORMATION PROVIDED BY YOUR PROVIDER

To provide the Services, we will ask your provider to share (with your consent) your full name, email address and information related to your scheduled appointments with their practice. 


We may link together different types of information we obtain from different sources, including linking it to data that identifies you. In such a case, Homecoming treats the linked information as your personal data and protects it as such.


When you are asked to provide personal data, you may decline.  You can also use app or device controls to prevent certain types of automatic data collection where available (including browser controls). If you choose not to provide or allow collection of information required for certain services or certain functionality, those services may not be available and/or may not function correctly. 


HOW DOES HOMECOMING USE COOKIES AND OTHER DATA COLLECTION TECHNOLOGY?

We use and may allow others to use cookies and similar technologies (e.g., pixels) to operate our public-facing Websites (including homecoming.health) and to help collect data on the website and on the application. Please read our Cookie Notice for more information on our use of cookies and how you can control them.


DO NOT TRACK

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have their online activity and behavior tracked. If a website that responds to a DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Homecoming, do not respond to DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in our Cookie Notice.


HOW DOES HOMECOMING USE PERSONAL DATA?

Homecoming uses personal data it collects only collected for the purposes described in this Privacy Statement or as otherwise disclosed to you. We use personal data to:

  • provide and deliver the Services (including securing, troubleshooting, bug fixing, improving, and personalizing those Services).  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include name, email address, and data you voluntarily provide to us.

  • to enhance your experience and enjoyment using our products.  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include data relating to your use of our Services so we can recommend a more relevant experience to you.

  • operate our business (including by improving our internal operations, securing our systems, conducting analytics, and detecting fraudulent or illegal activity).  This typically involves data automatically collected as described above.

  • provide customer support and respond to your questions. Again, this is most typically your name, login credentials, etc.

  • communicate with you about our products and services and those of our selected third-party partners so you can choose to sign up for those services. We may use your name and email address for this purpose; and

  • when you are signed up for and/or actively using the Services on the Homecoming Platform, communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners, or to request your feedback regarding our products and services. We use your name and some of your activity history for this purpose.


Homecoming may aggregate information collected though the Services and remove identifiers so that the information neither identifies nor can be used to identify any individual (“Aggregated Data”).  Because it cannot be used to identify any specific individual, Aggregated Data is not considered “personal data.”


HOW DOES HOMECOMING SHARE INFORMATION?

Homecoming will only share your data if you consent to that sharing (and you can always opt-out of future sharing).  We may provide de-identified or aggregated data to third parties – but that data will not be linked to you nor could you be re-identified from that data.  Upon obtaining consent, Homecoming may share personal data collected via the Homecoming Platform as follows:

  • Activities on the Homecoming Platform. We may share relevant personal data about you with the medical provider that provides you with access to the Homecoming application to enable them to continue to provide services to you, administer activities related to your treatment or to enable other activities and services you complete when you use the Homecoming Platform.  Homecoming requires any third party with which we share data to safeguard your data in a manner that fully complies with this Privacy Statement and applicable law. If you accept services offered by any third party, you may be asked to agree to their terms and conditions or enter into another agreement. When you do so, you are making your agreement with the Third-Party Well-being Provider, not with Homecoming.


Homecoming Services. Homecoming also shares personal data collected via the Services as follows:

  • In order to efficiently provide the Services, Homecoming may use cloud computing providers such as AWS or Microsoft Azure for web hosting, translation or data storage.  We may also use third parties to assist with bug fixes, troubleshooting, etc.  In order to use these services, Homecoming must share users’ personal data – but any third party with which we share personal data must agree to safeguard it in substantially the same manner as described herein and in accordance with all applicable laws.

  • Homecoming may share personal data with relevant third parties if Homecoming is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part), but your data will remain protected as described herein.

  • Homecoming will share personal data when you consent to such sharing.


We may disclose your personal information:

  • if we believe that disclosing this information is necessary to: (i) detect, prevent or address fraud and other illegal activity, or (ii) identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else.

  • in connection with any legal or other investigation, including an investigation related to a suspected breach of our Terms of Service.

  • when we genuinely believe that such disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar orders; or

  • if we genuinely believe that disclosure is needed to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to anyone or even threats of such emergencies


HOW DOES HOMECOMING PROTECT PERSONAL DATA?

Homecoming takes reasonable and appropriate precautions to protect information that we collect and process, but no system or electronic data transmission is completely secure, and we cannot guarantee that a security breach will not occur. We expect that you will use appropriate security measures to protect your personal data when using our Services.


You are responsible for maintaining the security of your account credentials for the Services. Please use a strong password, never share your password with anyone, and do not use the same password with other sites or accounts.  Homecoming will treat access to the Services through your account credentials as if authorized by you. If we become aware of  unauthorized access or disclosure that affects the security of your personal data, we will provide you with notice as required by applicable law.


TIME PERIOD FOR WHICH HOMECOMING RETAINS PERSONAL DATA

We retain personal data only as long as is necessary to fulfill the legitimate business need for which the personal data is collected (such as to provide you with the Services).  We may retain the data for a longer period to comply with legal obligations (e.g., tax, accounting), to resolve disputes, to enforce agreements and other, similar, purposes.


The criteria we use to determine how long to retain your personal data include:

  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Platform);

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);

  • Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).


When Homecoming no longer has a legitimate business need to process your personal data, we follow our information governance procedures and either delete your personal data or render it impossible to use to identify you. If we cannot delete or de-identify your personal data, then we will archive and protect it from any further use until deletion or de-identification is possible.


We may create anonymous information from your personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use and disclose anonymous information for any purpose and to any third party in our sole discretion.


YOUR CHOICES ABOUT PERSONAL DATA

If you would like to make a request to access, review, update, or delete your personal data,  please contact us at privacy@homecoming.health.  However, to the extent permitted by law, we reserve the right to decline requests where permitted by law or where we are unable to authenticate you as the person to whom the data relates. Please note that we often need to retain certain data for reasons such as recordkeeping and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which will not be removed.  We also reserve the right to charge a fee to comply with such requests.


You are responsible for entering valid information when creating your account, and for retaining access to any email account used to register. If you cannot access your email account, we may not be able to update or correct your personal information if you ask us to.

See the Cookies Notice for choices about cookies and other analytics and advertising controls.


When you contact Homecoming about accessing, updating, restricting or deleting your personal data, Homecoming will ask you for information to verify your identity. In your request, please clearly identify the personal data subject to your inquiry. We will comply with your request as soon as reasonably practicable.


CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (the “CCPA”), you have certain rights with respect to that information.  You also have the right to not be discriminated against for exercising rights set out in the CCPA.


Right to Know.  You have a right to request the following information:

  1. The categories and specific pieces of personal information collected about you.

  2. The categories of sources from which personal information is collected.

  3. The purposes for collecting, using, or selling personal information.

  4. The categories of third parties with which personal information is shared.

  5. The categories of personal information we have disclosed about you for a business purpose. Note that the CCPA defines “business purpose” broadly; and because we use service providers for a number of business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support), in the past 12 months we have disclosed for a business purpose data from each of the categories of personal information that we maintain.

  6. The categories of personal information we have “sold” about you (if any), for each category of third party to which the personal information was sold. See the “Right to Opt-Out” below for more information.


Please note that we have provided much of this information in this privacy statement.


Right to Request Deletion:  The CCPA also provides Californian residents the right to request that we delete personal information under certain circumstances, subject to a number of exceptions. These exceptions to deletion include when information is: (1) needed to complete the transaction for which it was collected or to provide goods or services requested by the consumer; (2) used in the context of the business relationship with the consumer; (3) required to perform a contract; (4) used to detect security incidents and protect against malicious, fraudulent or illegal activity; (5) needed to engage in scientific, historical, or statistical research in the public interest; (6) used solely for internal uses that are reasonably aligned with the expectations of the consumer; or (7) required to comply with a legal obligation or applicable laws.


Right to Opt-Out of Sale.  Homecoming does not sell your data for advertising or other purposes nor does it share data as defined by the CCPA.


California residents may make a make a request related to the right to know, a request to delete, or a request for further information about our compliance with the CCPA by e-mailing privacy@homecoming.health.


LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in Canada and the United States depending on the location of the end user. We choose these storage location(s) to help us operate efficiently and improve performance. The location of the data does not change how we process your personal data or our compliance with this Privacy Statement and applicable law.


CHANGES TO THE PRIVACY STATEMENT

The Effective Date is set forth at the top of this Privacy Statement. If we change this Privacy Statement, we will post the updated Privacy Statement and its Effective Date on this page. If we make material changes that reduce your privacy rights, we’ll will notify you in advance by sending you an email and/or by posting a notice in the Services at least 30 days prior to the change in either this Privacy Statement or how we handle your data to allow you to make an informed choice on whether you would like to continue.


HOW TO CONTACT HOMECOMING

If you have any questions, comments, or concerns for Homecoming or our Data Protection Officer, please contact us through our Customer Support Team at support@homecoming.health or write to us at:


Homecoming
Attention: Data Protection Officer

41 Noble Street

Toronto, Ontario, Canada


If you have a complaint concerning our privacy practices we will investigate your complaint and, if it is justified, we will take appropriate measures.  If you are not satisfied with our response to your complaint or concerns, we will also suggest to you additional avenues of recourse.

YOUR PRIVACY IS IMPORTANT TO US

Nothing is more important to Homecoming than the protection of the data and information entrusted to us by our customers and users.  We fully understand that trust is difficult to achieve and easy to lose – particularly with someone’s private information. With this understanding, we specifically designed our application and all of our systems to ensure that we never lose your trust.

 

Homecoming will never sell the data it collects. We will only share de-identified, aggregated, and anonymized data with providers using the Homecoming platform to provide insight on treatment best practices, so we can continue to grow and learn as a community.

 

This Privacy Statement explains how Homecoming (an affiliate of Axis Mundi, Inc. --  collectively “Homecoming”) collects, processes and shares personal data about you when you visit our website or use our Services. If you have questions about these practices, please contact us using the contact details provided below.  Under some data protection laws, the person or entity that controls the purposes and means of processing personal data is known as a “data controller” and a person or entity that processes data on behalf of the data controller is known as a “data processor” or a “service provider.”  The person to which the data relates is known as the “data subject.” Each of these terms will be used throughout this Privacy Statement as defined herein.

 

The data Homecoming collects does not belong to us – it is instead entrusted to us so that we can provide our Services.  As such, you will always have the choice to stop providing us with data, to no longer allow us to share data or ask that we no longer retain your data.  These choices (and your right to be forgotten) may be exercised through our applications’ controls or by contacting privacy@homecoming.health.


WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement applies to Homecoming and to our affiliates and subsidiaries (“Homecoming” or “we”) when we collect, use and share data through our Homecoming products. References to our “Services” in this Privacy Statement include our public-facing website at www.homecoming.health (“Website”), Homecoming’s technology platform, and our Homecoming application (and any updates or variations thereto).  This Privacy Statement applies to personal data collected through the Services and not to any website or service that refers or links to a different privacy statement or privacy policy.


NOTICE TO END-USERS OF HOMECOMING SERVICES

When you use Homecoming Services, you are considered a data subject and Homecoming a data controller.  To provide the Services, Homecoming processes the data you provide. Because some of the data that you provide to Homecoming is sensitive personal information, Homecoming will not collect or process such data unless and until you have provided your express consent for that processing.  If you have questions about how Homecoming processes any of your personal data through the Homecoming application, please contact Homecoming at privacy@homecoming.health.


You must be at least 18 years old to use our Services and we do not knowingly collect, use, process, or disclose personally identifiable data from anyone under the age of 18.  None of our Services or products are directed to users under the age of 18 unless their parent or guardian consents.  Should we discover any user under the age of 18, we will immediately revoke their access and terminate their account.


At any time, you may ask us to inform you about the existence, use, and disclosure of your personal information and to give you access to that information. You may also question the accuracy and completeness of the information we have and ask that it be updated or changed. We will, of course, honor your requests unless we have, and provide you with, reasonable reasons why we cannot provide this information to you.


WHAT PERSONAL DATA DOES HOMECOMING COLLECT?

As noted above, Homecoming neither collects nor processes your personal data unless you consent. You may withdraw your consent at any time and, when we receive notice of your withdrawal, we will promptly stop collecting, processing, or using your data for any purpose.


When you use our Services, we collect information about you from a variety of sources. This includes data you provide to us directly, data we collect automatically (in a way similar to other services), data provided by your care providers as part of their services and information we infer from other sources. In all cases, our collection of data depends on your choices (described in more detail below).  Some of this data is collected once (for instance when you sign up for the Services) and other data may be collected on an ongoing basis as you continue to use the Services.


We do not ask for, access or track any location-based information (other than general geographic region information provided by your device). However, we may collect the region or area associated with the IP address assigned to your computer (if you are using our website at www.homecoming.health) or mobile device. 


INFORMATION YOU PROVIDE DIRECTLY.

We collect personal data you voluntarily and directly provide to us, including, for example:

  • Your registration/contact Information (username, password, and any image or photograph you choose to provide) when signing up for or using the Homecoming Platform. 

  • Information you choose to input into the features and activities on the Homecoming Platform (task completion, medical conditions, treatment results, well-being assessments,.

  • Contact information you provide to us in a webform when visiting one of the Websites; and

  • Information if you decide to provide us with feedback about the Homecoming application (for instance when you provide us with data for troubleshooting issues with the app).

You control what data you choose to provide directly to Homecoming in connection with the Services.  Please be aware that certain Services functionality may be impacted by this choice.  

 

INFORMATION COLLECTED AUTOMATICALLY.

When you use our Services or when you provide feedback about the Homecoming application, some information is collected automatically, for example:

  • Device information (model, operating system version, mobile network information, operating system and system settings, browser type, browser language, Internet Protocol (IP) address, country and time zone in which your device is located, and the Platform pages you viewed and how long you viewed them, and similar identifiers). Homecoming may associate some device information with your Homecoming account.

  • Mobile Application Information (application data and metadata stored on your device when permitted by your operating system settings).

  • When you choose to provide feedback about the Homecoming application, we may collect logging data (describing your experience with the application) solely for the purpose of assisting with troubleshooting and improving the application.


Also, as further described in the Cookie Notice our Websites and online services store and retrieve data using cookies set on your device.


INFORMATION PROVIDED BY YOUR PROVIDER

To provide the Services, we will ask your provider to share (with your consent) your full name, email address and information related to your scheduled appointments with their practice. 


We may link together different types of information we obtain from different sources, including linking it to data that identifies you. In such a case, Homecoming treats the linked information as your personal data and protects it as such.


When you are asked to provide personal data, you may decline.  You can also use app or device controls to prevent certain types of automatic data collection where available (including browser controls). If you choose not to provide or allow collection of information required for certain services or certain functionality, those services may not be available and/or may not function correctly. 


HOW DOES HOMECOMING USE COOKIES AND OTHER DATA COLLECTION TECHNOLOGY?

We use and may allow others to use cookies and similar technologies (e.g., pixels) to operate our public-facing Websites (including homecoming.health) and to help collect data on the website and on the application. Please read our Cookie Notice for more information on our use of cookies and how you can control them.


DO NOT TRACK

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have their online activity and behavior tracked. If a website that responds to a DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Homecoming, do not respond to DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in our Cookie Notice.


HOW DOES HOMECOMING USE PERSONAL DATA?

Homecoming uses personal data it collects only collected for the purposes described in this Privacy Statement or as otherwise disclosed to you. We use personal data to:

  • provide and deliver the Services (including securing, troubleshooting, bug fixing, improving, and personalizing those Services).  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include name, email address, and data you voluntarily provide to us.

  • to enhance your experience and enjoyment using our products.  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include data relating to your use of our Services so we can recommend a more relevant experience to you.

  • operate our business (including by improving our internal operations, securing our systems, conducting analytics, and detecting fraudulent or illegal activity).  This typically involves data automatically collected as described above.

  • provide customer support and respond to your questions. Again, this is most typically your name, login credentials, etc.

  • communicate with you about our products and services and those of our selected third-party partners so you can choose to sign up for those services. We may use your name and email address for this purpose; and

  • when you are signed up for and/or actively using the Services on the Homecoming Platform, communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners, or to request your feedback regarding our products and services. We use your name and some of your activity history for this purpose.


Homecoming may aggregate information collected though the Services and remove identifiers so that the information neither identifies nor can be used to identify any individual (“Aggregated Data”).  Because it cannot be used to identify any specific individual, Aggregated Data is not considered “personal data.”


HOW DOES HOMECOMING SHARE INFORMATION?

Homecoming will only share your data if you consent to that sharing (and you can always opt-out of future sharing).  We may provide de-identified or aggregated data to third parties – but that data will not be linked to you nor could you be re-identified from that data.  Upon obtaining consent, Homecoming may share personal data collected via the Homecoming Platform as follows:

  • Activities on the Homecoming Platform. We may share relevant personal data about you with the medical provider that provides you with access to the Homecoming application to enable them to continue to provide services to you, administer activities related to your treatment or to enable other activities and services you complete when you use the Homecoming Platform.  Homecoming requires any third party with which we share data to safeguard your data in a manner that fully complies with this Privacy Statement and applicable law. If you accept services offered by any third party, you may be asked to agree to their terms and conditions or enter into another agreement. When you do so, you are making your agreement with the Third-Party Well-being Provider, not with Homecoming.


Homecoming Services. Homecoming also shares personal data collected via the Services as follows:

  • In order to efficiently provide the Services, Homecoming may use cloud computing providers such as AWS or Microsoft Azure for web hosting, translation or data storage.  We may also use third parties to assist with bug fixes, troubleshooting, etc.  In order to use these services, Homecoming must share users’ personal data – but any third party with which we share personal data must agree to safeguard it in substantially the same manner as described herein and in accordance with all applicable laws.

  • Homecoming may share personal data with relevant third parties if Homecoming is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part), but your data will remain protected as described herein.

  • Homecoming will share personal data when you consent to such sharing.


We may disclose your personal information:

  • if we believe that disclosing this information is necessary to: (i) detect, prevent or address fraud and other illegal activity, or (ii) identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else.

  • in connection with any legal or other investigation, including an investigation related to a suspected breach of our Terms of Service.

  • when we genuinely believe that such disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar orders; or

  • if we genuinely believe that disclosure is needed to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to anyone or even threats of such emergencies


HOW DOES HOMECOMING PROTECT PERSONAL DATA?

Homecoming takes reasonable and appropriate precautions to protect information that we collect and process, but no system or electronic data transmission is completely secure, and we cannot guarantee that a security breach will not occur. We expect that you will use appropriate security measures to protect your personal data when using our Services.


You are responsible for maintaining the security of your account credentials for the Services. Please use a strong password, never share your password with anyone, and do not use the same password with other sites or accounts.  Homecoming will treat access to the Services through your account credentials as if authorized by you. If we become aware of  unauthorized access or disclosure that affects the security of your personal data, we will provide you with notice as required by applicable law.


TIME PERIOD FOR WHICH HOMECOMING RETAINS PERSONAL DATA

We retain personal data only as long as is necessary to fulfill the legitimate business need for which the personal data is collected (such as to provide you with the Services).  We may retain the data for a longer period to comply with legal obligations (e.g., tax, accounting), to resolve disputes, to enforce agreements and other, similar, purposes.


The criteria we use to determine how long to retain your personal data include:

  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Platform);

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);

  • Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).


When Homecoming no longer has a legitimate business need to process your personal data, we follow our information governance procedures and either delete your personal data or render it impossible to use to identify you. If we cannot delete or de-identify your personal data, then we will archive and protect it from any further use until deletion or de-identification is possible.


We may create anonymous information from your personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use and disclose anonymous information for any purpose and to any third party in our sole discretion.


YOUR CHOICES ABOUT PERSONAL DATA

If you would like to make a request to access, review, update, or delete your personal data,  please contact us at privacy@homecoming.health.  However, to the extent permitted by law, we reserve the right to decline requests where permitted by law or where we are unable to authenticate you as the person to whom the data relates. Please note that we often need to retain certain data for reasons such as recordkeeping and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which will not be removed.  We also reserve the right to charge a fee to comply with such requests.


You are responsible for entering valid information when creating your account, and for retaining access to any email account used to register. If you cannot access your email account, we may not be able to update or correct your personal information if you ask us to.

See the Cookies Notice for choices about cookies and other analytics and advertising controls.


When you contact Homecoming about accessing, updating, restricting or deleting your personal data, Homecoming will ask you for information to verify your identity. In your request, please clearly identify the personal data subject to your inquiry. We will comply with your request as soon as reasonably practicable.


CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (the “CCPA”), you have certain rights with respect to that information.  You also have the right to not be discriminated against for exercising rights set out in the CCPA.


Right to Know.  You have a right to request the following information:

  1. The categories and specific pieces of personal information collected about you.

  2. The categories of sources from which personal information is collected.

  3. The purposes for collecting, using, or selling personal information.

  4. The categories of third parties with which personal information is shared.

  5. The categories of personal information we have disclosed about you for a business purpose. Note that the CCPA defines “business purpose” broadly; and because we use service providers for a number of business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support), in the past 12 months we have disclosed for a business purpose data from each of the categories of personal information that we maintain.

  6. The categories of personal information we have “sold” about you (if any), for each category of third party to which the personal information was sold. See the “Right to Opt-Out” below for more information.


Please note that we have provided much of this information in this privacy statement.


Right to Request Deletion:  The CCPA also provides Californian residents the right to request that we delete personal information under certain circumstances, subject to a number of exceptions. These exceptions to deletion include when information is: (1) needed to complete the transaction for which it was collected or to provide goods or services requested by the consumer; (2) used in the context of the business relationship with the consumer; (3) required to perform a contract; (4) used to detect security incidents and protect against malicious, fraudulent or illegal activity; (5) needed to engage in scientific, historical, or statistical research in the public interest; (6) used solely for internal uses that are reasonably aligned with the expectations of the consumer; or (7) required to comply with a legal obligation or applicable laws.


Right to Opt-Out of Sale.  Homecoming does not sell your data for advertising or other purposes nor does it share data as defined by the CCPA.


California residents may make a make a request related to the right to know, a request to delete, or a request for further information about our compliance with the CCPA by e-mailing privacy@homecoming.health.


LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in Canada and the United States depending on the location of the end user. We choose these storage location(s) to help us operate efficiently and improve performance. The location of the data does not change how we process your personal data or our compliance with this Privacy Statement and applicable law.


CHANGES TO THE PRIVACY STATEMENT

The Effective Date is set forth at the top of this Privacy Statement. If we change this Privacy Statement, we will post the updated Privacy Statement and its Effective Date on this page. If we make material changes that reduce your privacy rights, we’ll will notify you in advance by sending you an email and/or by posting a notice in the Services at least 30 days prior to the change in either this Privacy Statement or how we handle your data to allow you to make an informed choice on whether you would like to continue.


HOW TO CONTACT HOMECOMING

If you have any questions, comments, or concerns for Homecoming or our Data Protection Officer, please contact us through our Customer Support Team at support@homecoming.health or write to us at:


Homecoming
Attention: Data Protection Officer

41 Noble Street

Toronto, Ontario, Canada


If you have a complaint concerning our privacy practices we will investigate your complaint and, if it is justified, we will take appropriate measures.  If you are not satisfied with our response to your complaint or concerns, we will also suggest to you additional avenues of recourse.

YOUR PRIVACY IS IMPORTANT TO US

Nothing is more important to Homecoming than the protection of the data and information entrusted to us by our customers and users.  We fully understand that trust is difficult to achieve and easy to lose – particularly with someone’s private information. With this understanding, we specifically designed our application and all of our systems to ensure that we never lose your trust.

 

Homecoming will never sell the data it collects. We will only share de-identified, aggregated, and anonymized data with providers using the Homecoming platform to provide insight on treatment best practices, so we can continue to grow and learn as a community.

 

This Privacy Statement explains how Homecoming (an affiliate of Axis Mundi, Inc. --  collectively “Homecoming”) collects, processes and shares personal data about you when you visit our website or use our Services. If you have questions about these practices, please contact us using the contact details provided below.  Under some data protection laws, the person or entity that controls the purposes and means of processing personal data is known as a “data controller” and a person or entity that processes data on behalf of the data controller is known as a “data processor” or a “service provider.”  The person to which the data relates is known as the “data subject.” Each of these terms will be used throughout this Privacy Statement as defined herein.

 

The data Homecoming collects does not belong to us – it is instead entrusted to us so that we can provide our Services.  As such, you will always have the choice to stop providing us with data, to no longer allow us to share data or ask that we no longer retain your data.  These choices (and your right to be forgotten) may be exercised through our applications’ controls or by contacting privacy@homecoming.health.


WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement applies to Homecoming and to our affiliates and subsidiaries (“Homecoming” or “we”) when we collect, use and share data through our Homecoming products. References to our “Services” in this Privacy Statement include our public-facing website at www.homecoming.health (“Website”), Homecoming’s technology platform, and our Homecoming application (and any updates or variations thereto).  This Privacy Statement applies to personal data collected through the Services and not to any website or service that refers or links to a different privacy statement or privacy policy.


NOTICE TO END-USERS OF HOMECOMING SERVICES

When you use Homecoming Services, you are considered a data subject and Homecoming a data controller.  To provide the Services, Homecoming processes the data you provide. Because some of the data that you provide to Homecoming is sensitive personal information, Homecoming will not collect or process such data unless and until you have provided your express consent for that processing.  If you have questions about how Homecoming processes any of your personal data through the Homecoming application, please contact Homecoming at privacy@homecoming.health.


You must be at least 18 years old to use our Services and we do not knowingly collect, use, process, or disclose personally identifiable data from anyone under the age of 18.  None of our Services or products are directed to users under the age of 18 unless their parent or guardian consents.  Should we discover any user under the age of 18, we will immediately revoke their access and terminate their account.


At any time, you may ask us to inform you about the existence, use, and disclosure of your personal information and to give you access to that information. You may also question the accuracy and completeness of the information we have and ask that it be updated or changed. We will, of course, honor your requests unless we have, and provide you with, reasonable reasons why we cannot provide this information to you.


WHAT PERSONAL DATA DOES HOMECOMING COLLECT?

As noted above, Homecoming neither collects nor processes your personal data unless you consent. You may withdraw your consent at any time and, when we receive notice of your withdrawal, we will promptly stop collecting, processing, or using your data for any purpose.


When you use our Services, we collect information about you from a variety of sources. This includes data you provide to us directly, data we collect automatically (in a way similar to other services), data provided by your care providers as part of their services and information we infer from other sources. In all cases, our collection of data depends on your choices (described in more detail below).  Some of this data is collected once (for instance when you sign up for the Services) and other data may be collected on an ongoing basis as you continue to use the Services.


We do not ask for, access or track any location-based information (other than general geographic region information provided by your device). However, we may collect the region or area associated with the IP address assigned to your computer (if you are using our website at www.homecoming.health) or mobile device. 


INFORMATION YOU PROVIDE DIRECTLY.

We collect personal data you voluntarily and directly provide to us, including, for example:

  • Your registration/contact Information (username, password, and any image or photograph you choose to provide) when signing up for or using the Homecoming Platform. 

  • Information you choose to input into the features and activities on the Homecoming Platform (task completion, medical conditions, treatment results, well-being assessments,.

  • Contact information you provide to us in a webform when visiting one of the Websites; and

  • Information if you decide to provide us with feedback about the Homecoming application (for instance when you provide us with data for troubleshooting issues with the app).

You control what data you choose to provide directly to Homecoming in connection with the Services.  Please be aware that certain Services functionality may be impacted by this choice.  

 

INFORMATION COLLECTED AUTOMATICALLY.

When you use our Services or when you provide feedback about the Homecoming application, some information is collected automatically, for example:

  • Device information (model, operating system version, mobile network information, operating system and system settings, browser type, browser language, Internet Protocol (IP) address, country and time zone in which your device is located, and the Platform pages you viewed and how long you viewed them, and similar identifiers). Homecoming may associate some device information with your Homecoming account.

  • Mobile Application Information (application data and metadata stored on your device when permitted by your operating system settings).

  • When you choose to provide feedback about the Homecoming application, we may collect logging data (describing your experience with the application) solely for the purpose of assisting with troubleshooting and improving the application.


Also, as further described in the Cookie Notice our Websites and online services store and retrieve data using cookies set on your device.


INFORMATION PROVIDED BY YOUR PROVIDER

To provide the Services, we will ask your provider to share (with your consent) your full name, email address and information related to your scheduled appointments with their practice. 


We may link together different types of information we obtain from different sources, including linking it to data that identifies you. In such a case, Homecoming treats the linked information as your personal data and protects it as such.


When you are asked to provide personal data, you may decline.  You can also use app or device controls to prevent certain types of automatic data collection where available (including browser controls). If you choose not to provide or allow collection of information required for certain services or certain functionality, those services may not be available and/or may not function correctly. 


HOW DOES HOMECOMING USE COOKIES AND OTHER DATA COLLECTION TECHNOLOGY?

We use and may allow others to use cookies and similar technologies (e.g., pixels) to operate our public-facing Websites (including homecoming.health) and to help collect data on the website and on the application. Please read our Cookie Notice for more information on our use of cookies and how you can control them.


DO NOT TRACK

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have their online activity and behavior tracked. If a website that responds to a DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Homecoming, do not respond to DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in our Cookie Notice.


HOW DOES HOMECOMING USE PERSONAL DATA?

Homecoming uses personal data it collects only collected for the purposes described in this Privacy Statement or as otherwise disclosed to you. We use personal data to:

  • provide and deliver the Services (including securing, troubleshooting, bug fixing, improving, and personalizing those Services).  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include name, email address, and data you voluntarily provide to us.

  • to enhance your experience and enjoyment using our products.  We use data you provide, data automatically collected, and data from third parties for this purpose. This may include data relating to your use of our Services so we can recommend a more relevant experience to you.

  • operate our business (including by improving our internal operations, securing our systems, conducting analytics, and detecting fraudulent or illegal activity).  This typically involves data automatically collected as described above.

  • provide customer support and respond to your questions. Again, this is most typically your name, login credentials, etc.

  • communicate with you about our products and services and those of our selected third-party partners so you can choose to sign up for those services. We may use your name and email address for this purpose; and

  • when you are signed up for and/or actively using the Services on the Homecoming Platform, communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners, or to request your feedback regarding our products and services. We use your name and some of your activity history for this purpose.


Homecoming may aggregate information collected though the Services and remove identifiers so that the information neither identifies nor can be used to identify any individual (“Aggregated Data”).  Because it cannot be used to identify any specific individual, Aggregated Data is not considered “personal data.”


HOW DOES HOMECOMING SHARE INFORMATION?

Homecoming will only share your data if you consent to that sharing (and you can always opt-out of future sharing).  We may provide de-identified or aggregated data to third parties – but that data will not be linked to you nor could you be re-identified from that data.  Upon obtaining consent, Homecoming may share personal data collected via the Homecoming Platform as follows:

  • Activities on the Homecoming Platform. We may share relevant personal data about you with the medical provider that provides you with access to the Homecoming application to enable them to continue to provide services to you, administer activities related to your treatment or to enable other activities and services you complete when you use the Homecoming Platform.  Homecoming requires any third party with which we share data to safeguard your data in a manner that fully complies with this Privacy Statement and applicable law. If you accept services offered by any third party, you may be asked to agree to their terms and conditions or enter into another agreement. When you do so, you are making your agreement with the Third-Party Well-being Provider, not with Homecoming.


Homecoming Services. Homecoming also shares personal data collected via the Services as follows:

  • In order to efficiently provide the Services, Homecoming may use cloud computing providers such as AWS or Microsoft Azure for web hosting, translation or data storage.  We may also use third parties to assist with bug fixes, troubleshooting, etc.  In order to use these services, Homecoming must share users’ personal data – but any third party with which we share personal data must agree to safeguard it in substantially the same manner as described herein and in accordance with all applicable laws.

  • Homecoming may share personal data with relevant third parties if Homecoming is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part), but your data will remain protected as described herein.

  • Homecoming will share personal data when you consent to such sharing.


We may disclose your personal information:

  • if we believe that disclosing this information is necessary to: (i) detect, prevent or address fraud and other illegal activity, or (ii) identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else.

  • in connection with any legal or other investigation, including an investigation related to a suspected breach of our Terms of Service.

  • when we genuinely believe that such disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar orders; or

  • if we genuinely believe that disclosure is needed to protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to anyone or even threats of such emergencies


HOW DOES HOMECOMING PROTECT PERSONAL DATA?

Homecoming takes reasonable and appropriate precautions to protect information that we collect and process, but no system or electronic data transmission is completely secure, and we cannot guarantee that a security breach will not occur. We expect that you will use appropriate security measures to protect your personal data when using our Services.


You are responsible for maintaining the security of your account credentials for the Services. Please use a strong password, never share your password with anyone, and do not use the same password with other sites or accounts.  Homecoming will treat access to the Services through your account credentials as if authorized by you. If we become aware of  unauthorized access or disclosure that affects the security of your personal data, we will provide you with notice as required by applicable law.


TIME PERIOD FOR WHICH HOMECOMING RETAINS PERSONAL DATA

We retain personal data only as long as is necessary to fulfill the legitimate business need for which the personal data is collected (such as to provide you with the Services).  We may retain the data for a longer period to comply with legal obligations (e.g., tax, accounting), to resolve disputes, to enforce agreements and other, similar, purposes.


The criteria we use to determine how long to retain your personal data include:

  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Platform);

  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them);

  • Whether retention is advisable considering our legal position (such as for statutes of limitations, litigation or regulatory investigations).


When Homecoming no longer has a legitimate business need to process your personal data, we follow our information governance procedures and either delete your personal data or render it impossible to use to identify you. If we cannot delete or de-identify your personal data, then we will archive and protect it from any further use until deletion or de-identification is possible.


We may create anonymous information from your personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use and disclose anonymous information for any purpose and to any third party in our sole discretion.


YOUR CHOICES ABOUT PERSONAL DATA

If you would like to make a request to access, review, update, or delete your personal data,  please contact us at privacy@homecoming.health.  However, to the extent permitted by law, we reserve the right to decline requests where permitted by law or where we are unable to authenticate you as the person to whom the data relates. Please note that we often need to retain certain data for reasons such as recordkeeping and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases and other records may have residual data which will not be removed.  We also reserve the right to charge a fee to comply with such requests.


You are responsible for entering valid information when creating your account, and for retaining access to any email account used to register. If you cannot access your email account, we may not be able to update or correct your personal information if you ask us to.

See the Cookies Notice for choices about cookies and other analytics and advertising controls.


When you contact Homecoming about accessing, updating, restricting or deleting your personal data, Homecoming will ask you for information to verify your identity. In your request, please clearly identify the personal data subject to your inquiry. We will comply with your request as soon as reasonably practicable.


CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (the “CCPA”), you have certain rights with respect to that information.  You also have the right to not be discriminated against for exercising rights set out in the CCPA.


Right to Know.  You have a right to request the following information:

  1. The categories and specific pieces of personal information collected about you.

  2. The categories of sources from which personal information is collected.

  3. The purposes for collecting, using, or selling personal information.

  4. The categories of third parties with which personal information is shared.

  5. The categories of personal information we have disclosed about you for a business purpose. Note that the CCPA defines “business purpose” broadly; and because we use service providers for a number of business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support), in the past 12 months we have disclosed for a business purpose data from each of the categories of personal information that we maintain.

  6. The categories of personal information we have “sold” about you (if any), for each category of third party to which the personal information was sold. See the “Right to Opt-Out” below for more information.


Please note that we have provided much of this information in this privacy statement.


Right to Request Deletion:  The CCPA also provides Californian residents the right to request that we delete personal information under certain circumstances, subject to a number of exceptions. These exceptions to deletion include when information is: (1) needed to complete the transaction for which it was collected or to provide goods or services requested by the consumer; (2) used in the context of the business relationship with the consumer; (3) required to perform a contract; (4) used to detect security incidents and protect against malicious, fraudulent or illegal activity; (5) needed to engage in scientific, historical, or statistical research in the public interest; (6) used solely for internal uses that are reasonably aligned with the expectations of the consumer; or (7) required to comply with a legal obligation or applicable laws.


Right to Opt-Out of Sale.  Homecoming does not sell your data for advertising or other purposes nor does it share data as defined by the CCPA.


California residents may make a make a request related to the right to know, a request to delete, or a request for further information about our compliance with the CCPA by e-mailing privacy@homecoming.health.


LOCATION OF PERSONAL DATA

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in Canada and the United States depending on the location of the end user. We choose these storage location(s) to help us operate efficiently and improve performance. The location of the data does not change how we process your personal data or our compliance with this Privacy Statement and applicable law.


CHANGES TO THE PRIVACY STATEMENT

The Effective Date is set forth at the top of this Privacy Statement. If we change this Privacy Statement, we will post the updated Privacy Statement and its Effective Date on this page. If we make material changes that reduce your privacy rights, we’ll will notify you in advance by sending you an email and/or by posting a notice in the Services at least 30 days prior to the change in either this Privacy Statement or how we handle your data to allow you to make an informed choice on whether you would like to continue.


HOW TO CONTACT HOMECOMING

If you have any questions, comments, or concerns for Homecoming or our Data Protection Officer, please contact us through our Customer Support Team at support@homecoming.health or write to us at:


Homecoming
Attention: Data Protection Officer

41 Noble Street

Toronto, Ontario, Canada


If you have a complaint concerning our privacy practices we will investigate your complaint and, if it is justified, we will take appropriate measures.  If you are not satisfied with our response to your complaint or concerns, we will also suggest to you additional avenues of recourse.

Northstar Ethics Pledge

Homecoming has taken The North Star Ethics Pledge, a commitment to a set of principles for individuals working professionally in the field of psychedelics.

Your Privacy

We take data privacy and security seriously, and the protection of personal health information is our highest priority.

Northstar Ethics Pledge

Homecoming has taken The North Star Ethics Pledge, a commitment to a set of principles for individuals working professionally in the field of psychedelics.

Your Privacy

We take data privacy and security seriously, and the protection of personal health information is our highest priority.

Homecoming

Northstar Ethics Pledge

Homecoming has taken The North Star Ethics Pledge, a commitment to a set of principles for individuals working professionally in the field of psychedelics.

Your Privacy

We take data privacy and security seriously, and the protection of personal health information is our highest priority.

Homecoming