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Privacy policy of Priveo Santé

Capitalized terms are defined in the Priveo Santé Terms of Use.
Please read them carefully.

1. Scope and Application

In the face of new challenges and dangers related to preserving the security of personal information arising from online business, it is necessary to pay particular attention to the protection of privacy.
That’s why Priveo Santé takes the privacy of your personal information seriously, and is committed to respecting your rights.

Priveo Santé is committed to respecting, in accordance with this privacy policy (“the Policy”) and applicable laws in force in Canada and Quebec, the obligations concerning the collection and processing of your personal and confidential information, obtained in the course of operating its business, so that everyone can benefit from the respect of their privacy.

The Policy applies to you in all situations where you interact with Priveo Santé and where we collect information about you, including when you visit our Website, when you use our services, for example in person at our clinics or when you communicate with us by any means.

In this context, Priveo Santé wishes to ensure the accuracy, security and confidentiality of your personal information, and not to collect, use or disclose your personal information other than in accordance with this Policy and applicable laws.

The Policy describes the information that Priveo Santé may collect in the course of its business, in any way, from you.

The Policy also describes, among other things, how Priveo Santé processes, stores and/or destroys your personal information, the purposes for which it is collected, how it is used and the circumstances in which it may be transmitted to third parties.

The Policy explains your rights regarding the collection, transfer, use, retention and disclosure of your personal information.

Finally, the Policy describes the ways in which you can access, update or correct your personal information and the choices available to you regarding the protection of your privacy.

You agree that your personal information collected when filling in any online form in order to, in particular, make contact, upload Content to the Website, or render other services, will be transmitted to the relevant and authorized personnel of Priveo Santé.
The latter will only communicate to third-party companies carrying out activities on our behalf, and whose participation is strictly necessary for the delivery of the Services and/or the maintenance of our commercial relationship with you, as the case may be, the information necessary for these purposes (the aforementioned third parties may hereinafter be collectively referred to as “Third-Party Providers”).

2. Roles and responsibilities of Priveo Santé staff

At Priveo Santé we have assigned roles and responsibilities as follows:

The Privacy Officer is responsible for:

  1. the implementation of confidentiality policies and procedures within Priveo Santé;
  2. training our staff on confidentiality policies and obligations;
  3. Maintain a record of incidents related to the confidentiality of personal information;
  4. assess the potential consequences of a privacy incident;
  5. notifying the Commission d’accès à l’information in the event of a personal information confidentiality incident that could cause serious harm; and
  6. Participate in identifying the risk of privacy breaches and notifying the responsible persons in the event of a confidentiality incident

The Director of Operations is responsible for:

  1. Ensure that all our employees have signed the confidentiality agreement and that it is recorded on the server;
  2. ensure that employees’ access rights to the server are controlled;
  3. ensure that all Third-Party Providers have and comply with a privacy policy for personal information; and
  4. Participate in identifying the risks of confidentiality breaches and notifying the persons responsible in the event of a confidentiality incident.

Administrative staff are responsible for:

  1. collect customers’ personal information;
  2. obtain consent to the use of personal information and scan it in the patient’s chart;
  3. sign and abide by the confidentiality agreement; and
  4. Participate in identifying the risk of privacy breaches and notifying the responsible persons in the event of a confidentiality incident.

Clinical staff are responsible for:

  1. Comply with the Privacy Policy;
  2. Participate in identifying the risk of privacy breaches and notifying responsible persons in the event of a confidentiality incident;
  3. Comply with their ethical standards.

Priveo Santé and its Professionals (“Employees”) by:

  1. explaining the clauses of the confidentiality contract when it is signed upon hiring and reminding them annually thereafter;
  2. periodically reminding employees of confidentiality requirements at annual employee meetings; or
  3. raising awareness of the reporting of confidentiality incidents.

3. Definition of Personal Information

Personal information is information that is specifically associated with a natural person and that can be used to identify that person, either as such, or by combining it with other information held by Priveo Santé or to which that person may have access.
Information that has been rendered anonymous or arranged so that it can no longer be used to identify a specific individual does not constitute personal information.
For example, the mailing address of an individual’s office is not personal information in itself, except when it is mentioned along with other information about the individual, or when its mere mention would reveal personal information about the individual.

4. What personal information do we collect?

We collect the following personal information:

  1. Information about your identity and contact information, such as your first and last name, date of birth, home address, telephone number, email address, gender, height and weight, health insurance number;
  2. Health-related information, such as your medical record, in whole or in part, a medical certificate including or not a diagnosis, answers to medical questionnaires given, the fact that you have consulted a doctor or other health professional, the date of the consultation or teleconsultation, your list of medications, prescriptions issued, medical results, email or chat attachments sent by the client, type of appointment booked, insurance data;
  3. Information about the particular services you have purchased from Priveo Santé, including on the Website, such as your appointment history, and the time and date of your past and future appointments, requests for Quotes made;
  4. Your payment information, such as the time and date of payment, the amount paid, the type of card used, the full name on the card, and your credit card number, if you make a purchase on the Website;
  5. Employees’ identity information: first and last name, date of birth, address, salary, telephone number, and social insurance number;
  6. Bank details for Employees;
  7. Information collected automatically when you visit our Website, such as visit or chat history, the time and date at which cookies have been accepted, and the preferences chosen.

5. How do we collect your personal information?

We collect your personal information in the following ways:

  1. by phone;
  2. by making an appointment on the Website;
  3. in person at the clinic;
  4. by email or the chat app;
  5. the contact form or submission available on the Website;
  6. via subscription to the newsletter, on the Website;
  7. via the clinic’s forms; and
  8. via the employment contract and the employee file for Employees

6. From whom do we collect your personal information?

We generally collect personal information as follows:

a.Directly to you or the person with parental authority if you are a minor or your guardian or representative, if applicable

You may provide personal information to us directly, such as in person at the clinic, through a teleconsultation, by mail, email, telephone, fax, or through the Website, including by booking an appointment or chat.

You can provide us with your personal information by filling out your employment contract and your employee file, for Priveo Santé employees.

Like what:

  1. When you come to a point of service to perform examinations, analyses or require treatment, we collect your personal information necessary to provide these services and to communicate the results, if applicable.
    We also collect your health information that results from the tests or examinations performed.
  2. When you participate in a teleconsultation session with a Professional, we collect the personal information necessary to provide you with the required health services and care.
    The use of a telemedicine platform is subject to the privacy policy of the provider of the Website in question. When you contact us by phone to make an appointment, we collect the personal information necessary to complete the booking of the appointment.
  3. We may record calls to our Customer Relations Centre for quality control purposes.
    In this case, we will notify you at the beginning of the call and you will not be asked for any sensitive personal information.
  4. We collect personal information related to a medical prescription when you submit it to us electronically or by hand.
  5. When you use a chat service on the Website to chat with a Priveo Santé representative (in this case, you must at all times comply with the instructions communicated via the chat service interface and in our Terms of Use, regarding the nature of the information you are authorized to share, and you must avoid providing personal information where prohibited).

b.Via other sources

From time to time, we may receive personal information from other sources.
In these cases, we only receive them with your consent or as required by law where permitted.

Like what:

  1. If you need to have a pre-employment medical exam, your employer may share information about you with us.

c.Via the Website

Cookies” enable us to collect certain information during exchanges between your computer and our server.
Cookies are files created by a Web site to record information about your computer’s navigation on the site.
They are automatically stored on your electronic devices, allow you to connect to the website at a later time and enable Priveo Santé to personalize the website.

This information is mainly the following:

  1. Domain name;
  2. IP address;
  3. Language of the User; and
  4. Browsing history.

Most Cookies do not allow us to know your identity.
It is only collected due to the technological requirements inherent in browsing the Internet.
Most browsers automatically accept Cookies, but it is usually possible to change this behavior.
However, if you choose to refuse Cookies, you may not be able to identify yourself or use certain features of the Website.

Using such information allows us to improve the Service, personalize your experience, and better track your past usage.

In addition to the methods described above, we may also collect information through the use of Cookies or similar technologies, such as when you visit our Website.
These methods allow us to collect various types of information, including the pages you visit, the emails you read, and other information.

Like what:

Most Cookies do not allow us to know your identity.
It is only collected due to the technological requirements inherent in browsing the Internet.
Most browsers automatically accept Cookies, but it is usually possible to change this behavior.
However, if you choose to refuse Cookies, you may not be able to identify yourself or use certain features of the Website.

Most Cookies do not allow us to know your identity.
It is only collected due to the technological requirements inherent in browsing the Internet.
Most browsers automatically accept Cookies, but it is usually possible to change this behavior.
However, if you choose to refuse Cookies, you may not be able to identify yourself or use certain features of the Website.

  1. We may use your location to determine in which language to display the Website when you visit it.
  2. Subject to applicable laws, we may use the pages visited on the Website to show you personalized advertisements on the External Sites of our Third-Party Partners.

We use the information thus collected to adapt the Website to your preferences, to compile statistics about your consultation and use of our Website and our electronic communications, such as our newsletters, in order to improve them, and to present you with advertising from Priveo Santé with the help of our partners.

The Cookies we use include, but are not limited to, the following:

  1. cookies, which are small text files that are stored on your computer when you visit a website, so that certain information can be saved between your visits, such as your access data or your choice of language.
    For example, cookies allow you to quickly log in when you visit our sites.
  2. Pixels, which are small image files containing information about you, such as your IP address, that can be downloaded when you visit a website or open an email.
    This allows us to understand your online behavior, monitor the delivery of our emails, and present you with personalized advertising.
    These tools also allow our third-party tracking tools to collect information, such as your IP address, and transmit it to us in the form of anonymized aggregate data (thus preventing us from identifying you).
    The personal information compiled and presented in the form of aggregated data is the result of a summary and does not include any personal identifiers.

We use Google Analytics and Plerdy, which are services that use cookies to analyze your use of our Website, to report on the activities of visitors to the Website for us, and to offer other services related to the use of the Website and the Internet.
This information is not provided to us in a form that identifies you.

There are several types of cookies, some of which expire when the User closes the browser and no longer have any effect, while others may be retained.
The User may deactivate cookies at any time.
In this case, Priveo Santé does not guarantee optimal operation of the Website.

7. How do we use Cookies?

We use technologies such as cookies or pixels that perform different functions on our Websites. More information on the use of these technologies can be found in the Cookie Policy.

This information is also used to:

  1. Understand how you use the Service but do not track you specifically;
  2. Keep a record of the services you are interested in and obtain information about you from current or future divisions or companies that are part of Priveo Santé;
  3. To process your requests and answer your questions;
  4. To keep in touch with you and provide you with personalized service at all times;
  5. Communicate with you (by email, mail or otherwise) and send you advertising materials or additional information about the services;
  6. Develop new products and services; and
  7. Conducts market research and performance research to evaluate customer service, measure performance, enhance user experience and improve services.

8. Why do we collect your personal information?

We use your personal information to provide you with our services, to manage our business, to provide you with offers and information that we believe may be of interest to you, to enhance your overall customer experience, and for other purposes permitted or required by law.

In particular, we use your personal information for the following purposes:

a.To provide you with our services

We use your personal information to provide you with our services and, in particular, for the following purposes:

  1. Verify your identity;
  2. To provide our services to our patients and clients;
  3. Allow you to book an appointment online or in person;
  4. To determine whether our products and services are appropriate for you;
  5. Administer your file, including your online portal, to better meet your needs; and
  6. To respond to your requests and questions.

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE PRIVEO HEALTH TO PROVIDE ITS MEDICAL CLINIC SERVICE

b.To manage our operations

We use your personal information for a number of purposes in the course of our business and operations, specifically to:

  1. To manage the Website and facilitate its use;
  2. To enable your participation in surveys or, if applicable, promotions, chats, seminars or workshops;
  3. Monitor and investigate incidents; and
  4. To comply with our legal and regulatory obligations.

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE PRIVEO HEALTH TO MANAGE ITS OPERATIONS

c.To allow us to communicate with you

We use your personal information to communicate with you in a variety of ways:

  1. Send you our newsletter;
  2. Inform you in various ways (e.g., by email, phone, text message, or direct mail) about our programs, products, services, special offers, promotions, contests, or events that may be of interest to you; and
  3. To provide you with personalized advertisements about our products or services, if we believe they may be of interest to you.

If you no longer wish to receive our commercial email messages, please follow the unsubscribe procedure in each such message.

I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ALLOW PRIVEO SANTÉ TO CONTACT ME

9. What happens if you do not consent to the collection of your personal information?

You may, at any time, refuse the collection of your personal information.

Please note, however, that, with the exception of Cookies, which are not necessary for the provision of services, we will not be able to provide the services offered at the clinic without having access to your personal information.

For an Employee, we will not be able to establish the employment relationship, in particular by establishing an employment contract, without having access to your personal information.

10. Who outside Priveo Santé may have access to your personal information and how do we share it?

The staff and Professionals of Priveo Santé and, with your written or oral consent and where necessary, our Third Party Providers, may have access to your personal information.

We may disclose your personal information to our Third-Party Providers and other third parties – with your consent or where otherwise permitted by law – for the purposes described in this Policy and in accordance with applicable law (e.g., under Quebec’s Act respecting the sharing of certain health information).
We do not sell your personal information unless we sell or transfer a portion of our business.

We do not share your personal information with individuals or companies outside Priveo Santé, except as indicated below:

a.Third-party service providers whose intervention is necessary to provide you with the service

We may share personal information with our Third-Party Providers.
These Third-Party Providers help us provide our services, conduct our business, operate our technology systems and applications and infrastructure, and implement our internal procedures and advertising and marketing strategy.
They provide us, for example, with data hosting, email deployment, marketing, sales, and processing or analysis of personal information.
We may also outsource certain services we provide to our customers to third parties, including laboratories and healthcare professionals.

Like what:

  1. In order to serve our customers, we may use third-party laboratories to perform certain tests and analyses;
  2. Our patient records are hosted with an electronic medical record (EMR) provider;
  3. We may use an email provider to send you our newsletter;
  4. We may use a service provider’s chat site to offer you a service that allows you to chat live with a Priveo Santé representative;
  5. We may use a provider for data storage and/or sending and receiving email;
  6. We may use a service provider’s Telemedicine Website to provide you with teleconsultations with a healthcare professional; and
  7. We may use online payment platforms offered by third parties in order to process payment for benefits.

By using the services of Priveo Santé, you consent to the transfer of your personal information through vendor systems that allow us to interact with various electronic medical records (EMRs).

b.The purchaser of Priveo Santé if Priveo Santé were sold or transferred, or in certain other corporate transactions.

We may decide to sell or transfer all or part of our business or to a third party, to merge with another entity, to insure our assets or to undertake any other financing or other strategic capital transaction (including insolvency or bankruptcy proceedings), restructuring, sale of shares or other change of control of Priveo Santé.
You consent to the disclosure of your personal information when required for the purposes of such a transaction.

c.Other third parties when required or permitted by certain laws

The law permits or requires the collection, use or disclosure of personal information without consent in specified circumstances (for example, to investigate suspected or actual illegal activities, to prevent such activities, including fraud, or to assist government and law enforcement agencies).
These circumstances include those where permitted or required by law and those where it is necessary to protect us, our Employees, customers or others.
In such circumstances, we disclose only the personal information that is reasonably necessary to fulfill the purposes for which it was disclosed.

Please note that under applicable laws of Quebec and Canada (for example, the Quebec Public Health Act and the Quarantine Act of Canada), emergency decrees issued pursuant to these laws, and ministerial orders, Priveo Santé may be required to disclose your personal information to authorized persons, including but not limited to the Institut national de santé publique du Québec (INSPQ) and the Public Health Agency of Canada (PHAC), and their authorized representatives and agents.

We may disclose personal information that we hold for the purpose of protecting an individual or group of individuals when there are reasonable grounds to believe that there is a serious risk of death or serious injury, including a disappearance or an act of violence, including a suicide attempt, threatens that person or group and the nature of the threat inspires a sense of urgency.
The information may then be communicated to the person(s) exposed to the risk, their representative or any person likely to assist them.
Only the information necessary for the purposes of the communication will be disclosed.

We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for preventing, detecting or suppressing crime or offences under the law when the information is necessary for the purposes of a prosecution for an offence under an applicable law in Québec.

Finally, we will be able to communicate information to a police force when it is necessary to plan or carry out an intervention adapted to the characteristics of a person or the situation, in any of the following cases:

  1. the police service intervenes, at our request, to provide us with assistance or support in the course of the services we provide to a person;
  2. We acted in consultation or in partnership with the police force in the context of mixed psychosocial and police intervention practices.

d.Other third parties, with your consent

In addition to the above purposes, we may, with your implied or express consent and in compliance with applicable law, communicate or disclose your personal information with persons or entities outside Priveo Santé.

Like what:

  1. With your consent or at your explicit request, we may share your information with your insurer, employer, etc.

11. How long do we keep your personal information?

We store your personal information at our offices, with our archive and on our computer servers.
Except where the law provides for a different retention period, we retain personal information only as long as necessary to fulfill the purposes for which it was collected.
The duration may therefore vary depending on the nature of the information.

12. What are the risks involved in processing your personal information?

However, given the risks inherent in the use of computer systems, we cannot ensure or warrant the security or confidentiality of any information you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us using the contact information provided in Section 2 of the Policy. If a password is used to protect the User’s account and personal information, it is the User’s responsibility to keep it confidential.

Priveo Santé is committed not only to keeping a register of confidentiality incidents, but also to implementing internal practices to limit or prevent the consequences of a confidentiality incident involving personal information.

A confidentiality incident can be:

  1. unauthorized access to personal information;
  2. unauthorized use of personal information;
  3. the disclosure of personal information not authorized by law; or
  4. the loss of personal information or any other breach of personal information.

In the event of a privacy incident involving your personal information held by Priveo Santé, Priveo Santé will notify you and the Commission d’accès à l’information du Québec of any privacy incident that presents a risk of serious harm.

13. Is your personal information transferred outside Quebec?

Some of your personal information may be transferred outside of Quebec. In this case, the servers of the Third-Party Providers whose intervention is necessary for the provision of services are located in other Canadian provinces or territories, the United States, the Netherlands and Germany.

Priveo Santé Prior to any transfer of your personal information outside Quebec, performs a privacy impact assessment specific to the proposed transfer. Priveo Santé ensures that the safeguards put in place are adequate to protect the personal information being transferred.

14. How can you change your choices regarding the protection of your personal information?

You can always withdraw your consent for your personal information to be used for purposes other than those that are absolutely necessary for the provision of our services, without affecting the services you receive from Priveo Santé.

For example: You can always refuse to receive advertising communications from Priveo Santé.

You have different options to make your choices:

a.Indicate your choices at the time of registration or by contacting us directly at any time

You can always indicate your choice not to receive e-mail marketing messages from Priveo Santé by clicking on “unsubscribe” in any e-mail you receive.

Please note that even if you have indicated that you have opted out of receiving marketing messages from us, we may still contact you in connection with a service in accordance with applicable law (e.g., to send you a customer service message). In addition, it may take up to 10 business days for a preference change to be recorded in all of our records.

b.Change your device’s browser settings

We use technologies to improve your customer experience and provide you with offers, including personalized advertising. By means of technologies such as Cookies, for example, our Website recognises you when you use or return to it, and can thus provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our Websites.

15. How do we protect and store your personal information?

The security of your information is important to us and we are committed to protecting your privacy through a range of administrative, physical and technical safeguards. We retain your personal information for as long as necessary to provide you with our services, to manage our business, and to comply with our legal and regulatory obligations.

Personal information collected by Priveo Santé is stored in a secure environment. Priveo Santé has adopted appropriate measures to preserve the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, communication, reproduction, use or modification, taking into account, in particular, the sensitivity of the information and the purposes for which it is to be used. In addition, Priveo Santé requires that all Employees, agents and representatives of Priveo Santé comply with this Policy.

a.Safeguards in place

To protect your personal information, we employ administrative, technical and physical safeguards. Our goal is to prevent unauthorized access, loss, misuse, disclosure or modification of the personal information in our possession. We ensure that access to your personal information is restricted at all times to those Priveo Santé employees and agents who are legally entitled to access it. We also use these safeguards when disposing of or destroying your personal information.

b.Where we store your personal information

We use all reasonable security measures, which may include imposing contractual obligations on our service providers, to protect your personal information wherever it is used or stored.

Unless we are legally required or contractually bound to keep your personal information in Canada, it may be transferred outside Canada, as described in Section 13. For example, some of our service providers may access, process or store your personal information outside your province or territory or outside Canada for the purposes of the services they provide to us. In such cases, personal information is governed by the laws of the jurisdiction in which it is used or stored, including any laws permitting or requiring disclosure to governmental authorities or agencies, courts and law enforcement authorities in that jurisdiction. Priveo Santé ensures that its Third-Party Providers are located in jurisdictions that provide a level of protection for personal information consistent with the laws applicable in Quebec.

c.How long we keep your personal information

We retain your personal information for as long as necessary to provide you with our services, to manage our business, and to comply with our legal and regulatory obligations (for example, healthcare providers must comply with legal retention obligations with respect to patient records). When we no longer need it, we securely destroy your personal information or anonymize it (so that it no longer identifies you).

d.Destruction of your personal information

Personal information is destroyed in accordance with the rules set out in the regulations enacted by the Collège des médecins du Québec, by the laws applicable in Québec with respect to human resources management and by the laws applicable in Québec for the protection of personal information.

16. What are your rights regarding personal information?

The law gives you various rights in relation to your personal information. To exercise any of these rights, please contact our Privacy Officer at the contact information provided in section 2 of this Policy.

  • Access: the right to ask whether we hold personal information about you and, if so, to request access to that personal information. To the extent of our means, we will provide access to information in a timely manner. However, as a security measure, we may need to verify the identity of the applicant.
  • Rectification: the right to request rectification of any incomplete or inaccurate personal information we hold.
  • Withdrawal of consent: the right to withdraw your consent to the disclosure or use of your personal information, subject to applicable legal and contractual restrictions. Priveo Santé may no longer be able to provide you with certain services if you withdraw your consent.
  • Restriction or denial of access: the right to request that a specific stakeholder or a member of a specified class of stakeholders not be given access to one or more pieces of information that you have identified.
  • Complaint: the right to make a complaint to our Privacy Officer as identified in section 1 in connection with this policy and the complaints procedure. If you are not satisfied with the way we have handled your personal information or if you believe that a violation of privacy laws has been committed, you may file a complaint with the Commission de l’accès à l’information du Québec. To file a complaint with the Commission, please use the appropriate form available on the Commission d’accès à l’information du Québec website.
  • Portability: You have the right to request that your personal information be shared with you or that it be transferred to another organization in a structured and commonly used technological format.

17. How do you access your personal information?

You have a right of access to the personal information we hold about you, subject to any restrictions provided by law. Upon request, we will provide you with access to your personal information within thirty (30) days of receipt of your request. Access to personal information is free of charge, but a reasonable fee may be charged for the transcription, reproduction or transmission of such information.

It is your responsibility to provide accurate, truthful and complete information. If you notice any errors in your personal information or need to update it, please notify us as set out below.

You may submit a request by contacting us using the contact information of the Privacy Officer at the beginning of the Policy.

18. How do I know if the Privacy Policy has been modified?

We may make changes to this Policy from time to time.
Any changes we make to this Privacy Policy are effective when we post the amended Policy on this web page.
If we make material changes to the policy, we will post a notice on our Website or contact you to notify you, where required by law.
By continuing to use our services after the amended Policy is posted, you indicate that you accept the changes to the Policy, subject to any additional requirements that may apply.
If you do not agree to any changes to our Policy, you must stop using our services.
It is your responsibility to ensure that you read, understand and agree to the latest version of the Policy.
The “Effective Date” at the top of this Policy is the date it was last updated.

19. Who should you contact if you have any questions about the protection of your personal information?

If you have any questions about the Policy, the way we process your personal information or to exercise your rights regarding your personal information, please contact the Privacy Officer:

Clinique Priveo Santé
Éric Latendresse – Privacy Officer
425-1435 boulevard Saint-Martin Ouest
Laval, (Québec) H7S 2C6
E-mail: [email protected]

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