COMFY privacy policy

1. Corporate identity and application

This policy applies to information under the control of Two Rivers Digital in connection with:

• the COMFY pages on the public Two Rivers Digital website at www.tworiversdigital.ca/solutions/comfy and our hosted demonstration at comfy-youth.powerappsportals.com;
• product inquiries, demonstrations, procurement, implementation, training and support relating to COMFY; and
• other correspondence voluntarily sent to Two Rivers Digital about COMFY.

This policy does not govern information controlled by a Customer in the Customer's Microsoft environment. That information is subject to the Customer's policies, agreements and legal obligations. If this policy conflicts with a written agreement between Two Rivers Digital and a Customer, the written agreement governs to the extent of the conflict.

Two Rivers Digital administers this policy in accordance with applicable Canadian privacy and anti-spam law, including the Personal Information Protection and Electronic Documents Act where it applies and Canada's anti-spam legislation.

2. Definitions

Customer means an organization that acquires or evaluates COMFY, contracts Two Rivers Digital for related professional services, or requests information about the product.

Personal information means information about an identifiable individual.

Business contact information means a person's name, job title, work address, work email address or work telephone number used to communicate with that person about their work.

Customer data means information stored by a Customer in its own instance of COMFY or Microsoft Power Platform. COMFY means the Crisis Online Management for Youths.

3. Customer data and the installed application

COMFY is installed in the Microsoft tenant and Dataverse environment selected and controlled by the Customer. Customer records are stored in the Customer's Microsoft Dataverse and Power Pages environment. The base application does not automatically transmit those records to, host them in or store them in a Two Rivers Digital system. Customer-authorized support access, map requests and configured integrations are described separately below.

The installed application has no publisher telemetry, Two Rivers Digital analytics service, advertising tracker, external Two Rivers Digital application database or automatic export of Customer data. Installation does not grant Two Rivers Digital access to Customer users, records, files or youth-service information.

A Customer controls its users, security roles, data location, retention, deletion, backup and privacy obligations. Requests concerning Customer data must be directed to that Customer. Two Rivers Digital cannot access, correct, export or delete Customer data unless the Customer separately provides specific access or information for an authorized service engagement.

If a Customer voluntarily includes personal information in a support request or separately grants access for an authorized service engagement, that information is handled only for the requested service, under the Customer's instructions and the applicable agreement. This is separate from automatic collection through the installed COMFY application.

4. Information received directly by Two Rivers Digital

Two Rivers Digital may receive business contact information and correspondence when a person voluntarily contacts us, requests product information or a demonstration, participates in procurement, or works with us on implementation, training or support.

We use that information only to respond to the request; provide and administer the requested product information or services; manage the corresponding business relationship; maintain security; establish, exercise or defend legal rights; and satisfy contractual or legal obligations.

The COMFY product page is an information website. Our contact form receives the business contact details and inquiry text that you choose to submit. It is not a youth intake, care or payment service. The hosting provider may automatically process limited network and security information, including IP address, request time, browser information and requested pages, necessary to deliver and protect the website.

Two Rivers Digital demonstrations are for fictional service records only. They must not be used for real youth-service requests, clinical records or sensitive personal information. Our hosted demonstration uses a Two Rivers Digital Microsoft environment. When you register or sign in, it may receive account and profile details, authentication identifiers and activity records. Test requests, messages, bookings, feedback and locations that you submit are stored in that demonstration environment and may be accessed by authorized Two Rivers Digital administrators to operate, support and secure the demo. Use an authorized evaluation identity and fictional service records; the demo is not monitored as a care or crisis service.

5. Consent and lawful authority

Two Rivers Digital obtains consent for the collection, use and disclosure of personal information where consent is required. Consent may be express or implied, depending on the circumstances and the sensitivity of the information. Where required for sensitive information, unexpected uses or disclosures, or meaningful residual risk, we seek express consent. We may handle information without consent where applicable law permits or requires it.

A person may withdraw consent on reasonable notice, subject to legal or contractual restrictions. Withdrawal does not affect handling that occurred lawfully before the withdrawal and may limit our ability to provide a requested service.

For a customer-operated youth service, the Customer must provide understandable, age-appropriate notices and determine the young person's capacity to consent under applicable law. A parent, guardian or other authorized representative must be involved where legally required, with their authority verified. Guardian access must not be assumed solely from a family relationship. The Customer is responsible for lawful authority for sensitive records, contact restrictions, disclosures and any permitted exceptions to consent. Contact the organization providing services about those decisions.

6. Disclosure and service providers

Two Rivers Digital does not sell, rent or trade personal information. We do not automatically receive Customer data through the installed COMFY application and do not use Customer data for advertising, profiling or marketing.

Information received directly by Two Rivers Digital may be disclosed only:

• to service providers acting for us under appropriate confidentiality and security obligations;
• to professional advisers who owe duties of confidentiality;
• as directed or authorized by the Customer or individual concerned;
• in connection with a proposed or completed corporate transaction, subject to applicable legal safeguards; or
• where disclosure is permitted or required by law, legal process, or the protection of people, rights, systems or services.

Microsoft provides the cloud infrastructure used for our website, hosted demonstration, email and business systems and processes information in that capacity. Customer deployments are governed by the Customer's Microsoft agreements, selected regions and configured services. Information handled by us or our service providers may be processed outside the Customer's province or Canada and may be subject to lawful access in those jurisdictions. The product name does not determine data residency.

7. Youth-service information and customer privacy responsibilities

Depending on the Customer's configuration, COMFY can hold client and guardian contact information, safe-contact instructions, consent and authority records, intake details, referrals, service involvement, appointment bookings, clinical notes, attachments, messages, feedback and staff activity. Location is recorded when supplied through the relevant workflow. These records may contain sensitive health, family or safeguarding information.

The Customer determines the lawful purposes and minimum information needed for service coordination, communications, scheduling, recordkeeping and authorized reporting. It must configure and validate identity, staff roles, portal permissions, contact restrictions and access controls; publish its own privacy notice; and manage its legal duties concerning consent, disclosures, retention and incidents. The base package does not send clinical records to an artificial-intelligence service.

8. Cookies, browser storage, maps and integrations

Microsoft sign-in and Power Pages use cookies or browser storage for authentication, session management and security. The installed staff workspace does not use browser storage as a fallback for live clinical records. A standalone local evaluation may store its fictional demonstration data in that browser until it is cleared. The COMFY product page does not install advertising or behavioural-analytics trackers.

When a COMFY map is displayed, the browser requests basemap tiles from Esri ArcGIS Online. These requests reveal the displayed map area and ordinary connection information such as IP address to that provider; client names, record identifiers and clinical notes are not included in the tile requests. Map pins and report details are rendered within COMFY. Opening an external directions link sends the destination shown in the confirmation to Google Maps and is subject to that provider's terms and privacy practices.

The Customer must assess map providers and any optional connectors, notifications, analytics or other integrations before enabling them, provide the necessary notices and obtain any required consent. Additional services may receive information according to their configuration and their own terms. Browser controls can restrict cookies or clear stored data, but doing so may prevent authentication or remove locally saved fictional demo records.

9. Retention, destruction and safeguards

Business contact information, correspondence, support records and hosted-demo account and test information received directly by Two Rivers Digital may be stored in our Microsoft 365, Dynamics 365, Dataverse or Power Pages environment. We retain it only for as long as reasonably necessary for the purpose for which it was received and for applicable contractual, legal, accounting or dispute-resolution requirements. It is then securely deleted, destroyed or deidentified, subject to applicable backup rotation and legal preservation requirements. Demonstration records may be reset or removed during evaluation. Customers set and administer their own schedules for service records, clinical notes, attachments, audit logs and backups.

Two Rivers Digital uses administrative, technical and physical safeguards appropriate to the sensitivity of information under our control. These safeguards include identity and access controls, role-based permissions, encrypted network connections, logging and procedures intended to prevent unauthorized access, use, disclosure, alteration or loss.

No method of transmission or storage is completely secure. If a breach affecting personal information under our control occurs, Two Rivers Digital will investigate, mitigate and provide notices or reports required by applicable law.

10. Access, correction and complaints

Subject to applicable legal exceptions, a person may request access to personal information under the control of Two Rivers Digital, ask how it has been used or disclosed, request correction of inaccurate information, withdraw consent, or make a complaint about our practices. We may take reasonable steps to verify identity before responding.

For information in a Customer's installed COMFY application, contact that Customer. Two Rivers Digital does not control those records and cannot process an access, correction, export or deletion request for them without the Customer's authorization. For your hosted-demo account or information you provided directly to us, contact our Privacy Officer using the details below.

If a concern is not resolved after contacting us, a person may contact the Office of the Privacy Commissioner of Canada or another privacy regulator with jurisdiction.

11. Canada's anti-spam legislation

Two Rivers Digital sends commercial electronic messages only with consent or another lawful basis. A commercial message sent by us will identify the sender and include a practical unsubscribe method where required by law. We process unsubscribe requests without delay and within the period required by law.

Two Rivers Digital does not use information entered in COMFY for marketing.

12. Third-party services, changes and governing law

Our website may link to third-party websites or services. Two Rivers Digital does not control and is not responsible for their privacy practices.

We may amend this policy from time to time. The revised policy will be posted on this page with a new effective date. Material changes affecting an active Customer relationship may also be communicated to the applicable business contact. Where a new purpose or disclosure requires fresh consent or other lawful authority, posting an updated policy does not replace that requirement.

This policy is interpreted under the applicable laws of Canada and Manitoba. It does not create rights or obligations beyond those provided by applicable law or a binding written agreement.

13. Corporate information and Privacy Officer

Questions, requests and complaints concerning information under the control of Two Rivers Digital should be sent to: