PRIVAMED CLINIC (2025) INC POLICY REGARDING THE PROTECTION OF PERSONAL INFORMATION

The protection of your personal information is a priority for us. In accordance with Law 25 (An Act to modernize legislative provisions as regards the protection of personal information in Québec), we are committed to ensuring transparency, security, and respect for your privacy in the management of the data we collect.

We collect and process personal information for specific and legitimate purposes, including providing patient services, responding to your requests, managing appointments and communications, ensuring portal security, and improving our services.

This Personal Information Protection Policy (hereinafter the “Policy”) sets out how PRIVAMED CLINIC (2025) INC collects, uses, discloses, retains, and destroys your personal information. For ease of reading, we may use the terms “we” or “the clinic” from time to time in this Policy.

We may provide you with additional information regarding the processing of your personal information, in certain cases, at the time the information is collected. We may also obtain your specific consent in certain cases with respect to the collection, use, disclosure, and retention of your personal information.

This Policy applies to personal information we collect, regardless of the means used, whether in person, by telephone, or via our website.

By accepting this Policy or by providing us with personal information after having had the opportunity to review this Policy or any supplementary notice, you agree that your personal information will be processed in accordance with this Policy and any supplementary notice.

ABOUT US

Below is our complete identification information:

PRIVAMED CLINIC (2025) INC
5955 boulevard Marie-Victorin
Brossard, Québec
J4W 2M2

You have the right at all times to access, rectify, and withdraw your personal information. To exercise these rights or for any questions related to our privacy policy, you may contact our Personal Information Protection Officer at the following address:

me.langlais@privamed.com

Or by mail at the address indicated above.

Within PRIVAMED CLINIC (2025) INC, roles and responsibilities have been assigned as follows:

As the clinic operator, the General Director, Ms. Marie-Ève Langlais, ensures that personal information protection rules are implemented within the clinic and understood by all staff members.

We raise awareness among our staff and professionals regarding the importance of protecting personal information, notably through guidance provided by the Collège des médecins du Québec, the Commission d’accès à l’information du Québec, and certain medical associations.

Important Definitions

In this Policy, the following terms mean:

“Confidentiality Incident”

  • Unauthorized access by law to personal information;
  • Unauthorized use by law of personal information;
  • Unauthorized disclosure by law of personal information; or
  • Loss of personal information or any other breach of its protection.

“Personal Information” or “Personal Information Data”
Any information relating to a natural person that allows that person to be identified, directly or indirectly.

How We Process Your Personal Information

Collection of Personal Information

In the course of its activities, PRIVAMED CLINIC (2025) INC collects various types of personal information. Consent for the collection of such data is generally obtained prior to collection, either implicitly or explicitly.

Personal information is usually collected directly from the individual requesting the service. In certain exceptional situations, personal information may be received from an authorized third party.

The personal information we collect includes, but is not limited to:

  • Name and contact information;
  • Home address;
  • Email address;
  • Parents’ first and last names;
  • Demographic data (gender, date of birth);
  • Billing information;
  • Health insurance number;
  • Medical records and notes;
  • Medical test results.

At the time personal information is collected, PRIVAMED CLINIC (2025) INC staff informs the individuals concerned of the following:

  • The purposes for which the personal information is collected;
  • The means by which the personal information is collected;
  • The persons who will have access to the personal information;
  • The right to withdraw consent for the use and/or disclosure of the personal information.

You may choose not to consent to the collection, use, and/or disclosure of personal information. You may withdraw your consent at any time by contacting the data protection supervisor at the address indicated above.

Use of Personal Information

The Clinic may use personal information for the following purposes:

  • To provide and maintain our medical services, including follow-up care;
  • To communicate with you by email, telephone, SMS, or other equivalent electronic means;
  • To provide you with news, special offers, and general information about other goods, services, and events we offer, unless you have opted out of receiving such communications.

Access to Personal Information

Personal information is stored using secure methods in appropriate software depending on the nature of the information. The software used and their purposes are described in the section below.

Access to personal information within the various software systems is restricted to users who require such access in the performance of their duties. Each access is protected by a unique password. All access rights are revoked promptly when an individual is no longer an employee or independent contractor of PRIVAMED CLINIC (2025) INC. Access management is administered by the information technology team.

We may share your personal information in the following situations:

  • With service providers: We may share your personal information with service providers in order to deliver the services you request. The service providers and their security measures are identified in Section 6 below.
  • With affiliated companies: We may share personal information with our affiliated companies, provided they comply with this Privacy Policy. Affiliates include our parent company and any subsidiaries or companies under common control.
  • With courts, authorities, and other bodies: In certain circumstances, we may be required to disclose personal information to courts, law enforcement authorities, or other bodies to comply with warrants, orders, legal obligations, or insurance requirements.

Personal information related to medical records is retained as long as necessary, in accordance with the rules of provincial medical regulatory bodies.

All other personal information is retained as long as required under applicable laws.

WHAT TECHNOLOGICAL PRODUCTS DO WE USE

Software NameProvider NamePurpose
MyleMedfar SolutionsMyle is an Electronic Medical Record (“EMR”) used in the context of the Clinic’s activities for the purpose of securely storing and encrypting patients’ personal information. The EMR itself is hosted in Québec in order to protect information assets. To learn more about the management of personal information by Myle, please consult: https://www.medfarsolutions.com/fr/politique-de-confidentialite/
ConvergeElavonConverge is a secure omni-commerce payment solution that allows the clinic to accept payments in clinic, online, by mobile phone, or by mail order / telephone order. Converge uses encryption and data tokenization to ensure the security of payment data. Converge is hosted in Canada in order to protect information assets. To learn more about the management of personal information by Converge, please consult: https://www.elavon.ca/fr-ca/solutions/payment-gateway/converge
Google Analytics ProductsAlphabet (Google)You may learn more about Google Analytics Products and how this entity processes data in its privacy policy and terms of use.
Google Advertising ProductsAlphabet (Google)Google Advertising Products are part of the IAB Transparency and Consent Framework and are subject to applicable policies. You may learn more about this partner and how it manages legitimate interest by consulting its Privacy Policy.
ComUnikComUnikIP business telephony, text messaging, and electronic fax services. Call management software and artificial intelligence tools. https://comunik.ca/politique-de-confidentialite/
GTOGTOYou may learn more about GTO products and services and how this entity processes data in its privacy policy: https://gtoinfo.ca/politique-de-confidentialite

SECURITY MEASURES AND INHERENT RISKS

We follow industry security standards to protect the information we collect and receive. We have implemented appropriate physical, technical, IT, and administrative safeguards to protect your personal information against confidentiality incidents. However, due to inherent risks associated with computer systems, we cannot guarantee absolute security or confidentiality. If you believe your personal information has been compromised, please contact us using the contact details provided in Section 1.

HOW AND UNDER WHAT CONDITIONS WE MAY DISCLOSE YOUR PERSONAL INFORMATION FOR PUBLIC SAFETY OR LAW ENFORCEMENT PURPOSES

In the event of a serious risk of death or serious injury

We may disclose personal information to protect a person or group if there are reasonable grounds to believe there is an urgent risk of death or serious injury, including disappearance or acts of violence such as attempted suicide.

Information may be disclosed to exposed persons, their representatives, or individuals capable of providing assistance. Only information necessary for the intended purpose will be disclosed.

Law Enforcement

We may disclose information to the Director of Criminal and Penal Prosecutions or law enforcement bodies when required for prosecution under Québec law.

We may also disclose information to a police force when necessary for planning or carrying out an intervention adapted to a person or situation, including:

1° when police intervene at our request to provide assistance;
2° when we act jointly or in partnership with police as part of mixed psychosocial and police intervention practices.

ARE YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE QUÉBEC?

We may transfer personal information to service providers as part of our operations. This may involve transfers outside Québec, for example via cloud services to ensure data redundancy and integrity.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

You have the following rights:

  • Access: The right to know whether we hold personal information about you and to access it.
  • Rectification: The right to correct incomplete or inaccurate information.
  • Withdrawal of consent: The right to withdraw consent for use or disclosure. In such cases, we may no longer provide healthcare services or employment.
  • Restriction or refusal of access: The right to restrict access by certain professionals.
  • Complaint: The right to file a complaint with our Privacy Officer or the Commission d’accès à l’information du Québec.
  • Portability: The right to receive your personal information in a structured, commonly used technological format or request its transfer to another organization.

To exercise these rights, contact our Privacy Officer as described in Section 1.

THIRD-PARTY SITES

This Policy does not apply to third-party websites or services accessible through our platforms. We are not responsible for their privacy practices.

DESTRUCTION OF PERSONAL INFORMATION

Personal information is destroyed in accordance with regulations of the Collège des médecins du Québec, Québec labour laws, and personal information protection laws.

HOW DO WE UPDATE THIS POLICY?

We may modify this Policy from time to time to reflect changes in our business processes or legal requirements.