Groupe Forget - Polyclinique de l'Oreille
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PRIVACY POLICY

Last Update: September 2023

Your privacy and the protection of your personal information are of utmost importance to POLYCLINIQUE DE L’OREILLE INC. (“Polyclinique,” “our,” “we,” or “us“). When you contact us or use our website located at www.polycliniquedeloreille.com (the “Site“), Polyclinique ensures the implementation of effective control measures to protect the confidential nature of personal information under its care.

By providing us with Personal Information through our Site, by phone, by email, by mail, in person, or by any other means, you consent to the collection, use, and disclosure of your Personal Information in accordance with this Policy.

 

Personal Information includes information about you or that, when taken separately or combined with other data, can identify you. This information may include: given name, last name, title, email, postal address, phone numbers, financial or billing information, health information, marketing and communication preference information, information related to the use of our Site including technical information about visits, or any other personal information that you consider useful to provide to us (“Personal Information“). Generally, Personal Information does not include your professional contact details such as your work name, title, address, or work phone number.

 

This Policy on the protection of personal information (the “Policy“) outlines the Personal Information we may collect from you, the reasons for its collection, how we use it, and how we protect it. We also want to inform you about how we transmit it, for technical reasons, to other entities or companies. This policy also describes the choices you can make regarding how we collect, use, and protect your Personal Information, as well as the policy established to address complaints about the protection of your Personal Information. Some provisions of this policy may apply variably depending on specific circumstances. It is important to consider the particular situation to determine the applicability of the various elements of this policy.

 

1. WHAT INFORMATION DO WE COLLECT?

Connection, Usage, and Support Data

  • Connection data, which may include your IP address, the pages you visit, the date and time you used the Site, the address of the web page you visited before using the Site, the URL that directed you to our site, the type and settings of your browser, information about your device (such as brand, model, and operating system), browser configuration information, language preferences, unique identifiers, and cookies.
  • Usage data and analytics, which may include login frequency, functions you use, duration and time of use, as well as different types of activities undertaken by users.
  • General location information, such as IP address and the region in which you are located when you connect and visit the Site.
  • Customer support inquiries, issues, and general comments you choose to provide.

 

Surveys, Newsletters, Events, and Marketing Information

If you choose to participate in our surveys, contests, events, information requests, or sign up for our newsletter, we may collect information about you related to the survey, contest, information request, event, or newsletter distribution; your contact details, such as your name, email address, phone number; and general information about you that you choose to provide.

 

Use of Our Site or Interaction with Us via Email

When you browse our Site or interact with us via email, we collect information about you as described below, some of which is collected automatically:

  • When you use the Site’s page to make an information request or other, we may collect information about you, such as your name, first name, email address, specific request, and information related to your use of our Site.
  • Connection data, which may include your IP address, the pages you visit on the Site, the date and time of your visit to the Site, the address of the web page you visited before using the Site, the URL that directed you to our Site, the type and settings of your browser, information about your device (such as brand, model, and operating system), browser configuration information, language preferences, unique identifiers, and cookies.
  • Usage data and analytics, which may include login frequency, functions you use, duration and time of use, as well as different types of activities undertaken by users, and demographic information we may ask for, such as your gender and age.
  • General location information, such as IP address and the region in which you are located when you connect and use the Services.
  • If you wish to subscribe to our newsletters, obtain additional information about our services, sign up to receive information from us via email, register for an event, webinar, or contest, or download certain content, we may ask you to provide us with your contact details, such as your name, phone number, and email address, as well as some information about your needs or preferences.
  • Customer support inquiries, general comments you choose to provide.
  • Billing information and other payment information, including billing name and address, payment method details, such as credit card number, or bank account information.
  • Any other Personal Information provided.

 

Phone Calls

  • If you communicate with us by phone, we may record that call and ask you to provide your contact details, such as your name, date of birth, postal address, phone number, email address, billing information, and other payment information.
  • Additionally, you may be asked to provide any other Personal Information necessary for your care by one of our hearing health professionals, such as your health insurance number, medical test results, medical history, lifestyle habits, etc.

 

Visits to Our Offices

  • If you visit our offices, you may be asked to register as a visitor and provide your name, date of birth, postal address, email address, phone number, as well as the time and date of your arrival and future appointments if applicable.
  • Additionally, you may be asked to provide any other Personal Information necessary for your care by one of our hearing health professionals, such as your health insurance number, medical test results, medical history, lifestyle habits, etc.

 

IMPORTANT: If you provide us with Personal Information about other individuals, you declare that you have the authority to do so, and, if applicable, that you have obtained the necessary consent, and you acknowledge that this information may be used in accordance with this Policy.

 

2. WHY ARE YOUR INFORMATION COLLECTED AND HOW ARE THEY USED?

Polyclinique collects and uses your Personal Information to:

a) Provide you with services and information about the services offered;

b) Manage your record and communicate with you and maintain your customer account;

c) Process any payments you may be required to make, including payment of your bills;

d) Send information about the various services offered or information you have requested or to respond to your queries and questions;

e) Facilitate communication, including by collecting information about your device data and phone number;

f) Communicate with you (via phone, alert, email, mail, or otherwise) and provide you with additional information about our services, surveys, and offer our customer service;

g) Help us learn more about your needs, preferences, and interactions with our Site and services offered; and

h) Conduct statistics, market research, and performance analysis to help us evaluate our services, measure our performance, and improve the experiences and services we offer. Polyclinique will not use your Personal Information for purposes other than those indicated in the Policy.

 

Polyclinique strives to limit the collection of Personal Information to what is strictly necessary to accomplish the purposes for which they are collected. We will not disclose or use your Personal Information for purposes other than those stated, but note the following clarifications and exceptions:

  • Law enforcement: We may share your Personal Information to respond to law enforcement requests, court orders, or other legal proceedings, or if we believe such disclosure is necessary to investigate, prevent, or respond to illegal activities, fraud, physical threats, or as required by any other applicable law or regulation and to the extent necessary to protect the property, interests, and rights of Polyclinique.
  • Archival service: We may share your Personal Information with a company engaged in document retention for general informational value.
  • Our employees and authorized service providers (“Authorized Personnel”): Authorized Personnel may have access to your Personal Information to assist us in providing services to you. Authorized Personnel access and use this Personal Information in accordance with our instructions, only if they need to know such information, and under strict confidentiality and security obligations. Be aware that we ensure that our Authorized Personnel handle this information with the necessary discretion and diligence and comply with this Policy and applicable legal and regulatory requirements.
  • Business transaction: Polyclinique may be involved in (1) the sale or lease of all or substantially all of its business and/or assets, (2) changes in its legal structure through merger or otherwise, (3) a transaction to obtain a loan or other form of financing, and (4) any other similar transaction (individually and collectively, the “Transaction”). In connection with this Transaction, we may assign or disclose your Personal Information to the current or potential contracting organization, but we will require this organization to agree to protect the confidentiality of your Personal Information in a manner consistent with this Policy.
  • Aggregated statistics and reports: We freely use data in an anonymous form, for example, for statistical, analytical, calibration, management, and quality improvement purposes related to the Site and the services offered thereon, or for the development or provision of other services by Polyclinique or for the benefit of all users of the Site in general. However, Polyclinique guarantees that such aggregated and anonymized data will never be able to identify you in any way or contain Personal Information.
  • Explicit consent: Polyclinique may also disclose your Personal Information if you request or expressly consent to it.

 

3. CONSENT

In general, Polyclinique will obtain the necessary Personal Information directly from you, with your consent, subject to exceptions provided by law. Personal Information will only be used for the purposes for which it was collected unless we obtain your consent.

 

We may also collect Personal Information from third parties or publicly accessible records as permitted by law or if we have obtained the necessary consent. Polyclinique will not collect, use, or disclose Personal Information without your consent unless authorized or required by law.

 

Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal restrictions, to withdraw your consent regarding the use of Personal Information already collected by contacting our Privacy Officer at the contact information provided in clause 14. Refusal to provide information or the withdrawal of your consent could prevent us from providing or continuing to provide our services or information about them.

 

In addition, we provide “opt-out” or “unsubscribe” instructions in our electronic communications to allow you to opt out of future electronic communications.

 

4. ACCESS, CORRECTION, AND UPDATING OF PERSONAL INFORMATION

You have the right to access your Personal Information and obtain copies of it. You also have the right to update, correct, and rectify any Personal Information that you believe is inaccurate or incomplete. To do so, please submit a written request to the Privacy Officer at the address indicated in clause 14, who will respond to you in writing within 30 days from the date of receipt of any such request.

 

If you wish to obtain copies of your Personal Information, we may require you to pay a minimal fee, which will be disclosed to you in advance, simply to cover the costs of transcription, reproduction, and/or transmission.

 

5. YOUR PERSONAL INFORMATION AND THIRD PARTIES

Our Site may reference, integrate with, or link to third-party websites. These third-party websites (“Third-Party Sites“), whose links are provided to you for your convenience, are not under our control. These Third-Party Sites are governed by their own privacy policies and may collect your Personal Information. Third-Party Sites are not developed, sold, or designed by Polyclinique. Therefore, Polyclinique does not guarantee and is not responsible for the collection, use, storage, and disclosure of your Personal Information by Third-Party Sites. This Policy does not apply to the practices of third parties, and Polyclinique assumes no responsibility for your use of these Third-Party Sites or your access to Third-Party Sites through our Site. By using our Site, or accessing Third-Party Sites through our Site, you release Polyclinique from any liability for the actions, practices, and omissions of these third parties. Please review the policy of each Third-Party Site you visit. We do not rent or sell your Personal Information to third parties.

 

Furthermore, by using our Site, becoming a customer, contacting us by phone, email, in person, etc., you grant Polyclinique the right to share your Personal Information with third-party service providers that we deem acceptable and that will use this information to assist us in responding to your requests and performing services. Please note that we will only share the Personal Information necessary for the use of these third-party services, solely for the purpose of providing you with the services, and we will ensure that these third-party providers agree to keep this information confidential and secure.

 

Service providers retain the information they need to perform the functions for which they were appointed, and we do not allow these third parties to use or disclose Personal Information for their own marketing or other purposes. At no time will Polyclinique sell or trade your Personal Information for payment.

 

6. TRANSFER OF PERSONAL INFORMATION ABROAD

Please note that your Personal Information is currently hosted in Quebec.

 

In the future, we may engage third-party service providers to process, manage, and host Personal Information on our behalf, which may be located abroad. Therefore, it is possible that some Personal Information about you may be transferred to another province or country and may be subject to the laws of that province or country.

 

However, we ensure that Personal Information we have under our care, including Personal Information entrusted to a service provider, whether located in Canada or abroad, is protected. Our policies and practices for the protection of Personal Information require that a written commitment be signed by the service provider to comply with its obligation to maintain the confidentiality and security of the Personal Information entrusted to it. This includes the implementation of robust and effective security measures, as well as a prohibition on disclosing your Personal Information to others in accordance with applicable legislation in the province of Quebec regarding the protection of Personal Information.

 

7. PROTECTION OF PERSONAL INFORMATION

We take appropriate measures to ensure the confidentiality of Personal Information and to protect Personal Information against loss, unauthorized access, disclosure, copying, use, or unauthorized modification, taking into account, in particular, the sensitivity of the information and the purposes for which it is intended.

 

Polyclinique uses commercially reasonable and appropriate physical, electronic, and management procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.

 

In addition, the Personal Information we hold is only accessible to individuals who are authorized to access and consult it when necessary in the performance of their duties.

 

To do this, we ensure, among other things, that access to our offices and computer equipment is restricted, that our staff is trained, and that our agents and service providers with access to Personal Information sign confidentiality agreements and implement equivalent security measures.

 

Please note, however, that since no mechanism offers maximum security, the use of the Internet to transmit, create, or host Personal Information always carries some risk.

 

If you believe that your Personal Information has been compromised, we invite you to contact our Privacy Officer at the contact information provided in clause 14 of this Policy.

 

8. MINORS

Our Site is designed for use by individuals aged 18 and over. Polyclinique does not knowingly collect Personal Information from children under the age of 18.

 

If a minor under the age of 14 wishes to use our Site, the collection of Personal Information from such a minor cannot occur without the consent of the parent or legal guardian. If we learn that we have unintentionally collected Personal Information from individuals under the age of 14 without obtaining the consent of the parent or legal guardian, we will ensure that this information is deleted from our records as soon as possible. If you are the parent or legal guardian of a minor under the age of 14 and you are aware that your minor child has provided Personal Information, please contact our Privacy Officer at the contact information provided in clause 14 of this Policy so that we can take the necessary actions.

 

9. RETENTION PERIOD

With the exception of non-identifiable and anonymized information that Polyclinique may retain indefinitely and in any reasonable location, Polyclinique will host and retain your Personal Information for the duration necessary for the purposes set out in this Policy and to ensure compliance with our legal and regulatory obligations. You may withdraw or modify your consent regarding our use of your Personal Information at any time, or request that we delete it permanently, subject to conditions imposed by law.

 

If you would like to learn more about the retention period of your Personal Information, please contact our Privacy Officer at the contact information provided in clause 14 of this Policy.

 

10. ELECTRONIC COMMUNICATIONS (EMAILS)

Your email address may be used to send you occasional electronic communications. At any time, you can ask us to stop sending you electronic communications by contacting the Privacy Officer of Polyclinique at the contact information provided in clause 14 of this policy or by using the “unsubscribe” instructions at the bottom of these communications, if applicable.

 

11. COOKIES AND OTHER TRACKING TECHNOLOGIES ON OUR SITE, THROUGH OUR SERVICES, AND IN EMAIL COMMUNICATIONS

We use common information collection tools, such as usage data collection tools, cookies, and similar technologies, to automatically collect information that may contain Personal Information from your computer or mobile device when you browse our Site, use our Services, or interact with emails we have sent you.

 

By accessing and browsing our Site and using our Services, you consent to the use of cookies in accordance with the terms of this Policy. You can control and manage cookies in various ways. Please note that deleting or blocking cookies may negatively impact your user experience, and certain parts of our Site may no longer be fully accessible.

 

Most browsers automatically accept cookies, but you can choose to accept or decline cookies through your browser’s controls, often found in the “Tools” or “Preferences” menu of your browser. You can find more information on how to change your browser settings or block, manage, or filter cookies in your browser’s help file or on websites such as www.allaboutcookies.org.

 

12. CHANGES TO THIS POLICY

Polyclinique reserves the right to make changes to this Policy at any time. These changes will be posted on the Site and will take effect immediately upon posting. We will take reasonable steps, if necessary, to inform users of the Site and our services of any significant changes. When we make changes to this Policy, we will revise the “last updated” date at the beginning of this Policy.

 

You can contact our Privacy Officer at the address or numbers provided in clause 14 of this Policy to obtain an up-to-date copy of the Policy.

 

13. TERMS OF USE OF THE SITE AND SERVICES

The terms of use of the Site and Services, available at www.polycliniquedeloreille.com, contain important provisions that disclaim and exclude the liability of Polyclinique and other persons regarding your use of the Site and Services, as well as provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute regarding your use of the Site and Services. Each of these provisions also applies to any dispute that may arise in connection with this Policy and the collection, use, storage, and disclosure of your Personal Information, and they have the same force and effect as if they had been reproduced verbatim in this Policy.

 

14. QUESTIONS, COMMENTS, COMPLAINTS, AND PRIVACY OFFICERS

Polyclinique is responsible for the Personal Information under its custody or control, and has designated a Privacy Officer to ensure compliance with this Policy and applicable privacy laws.

 

If you have any questions, comments, concerns, or complaints about this Policy and Polyclinique‘s privacy practices, we invite you to contact our Privacy Officer at the following coordinates:

 

Privacy Officer

For comments, questions, or complaints, please do not hesitate to contact the Privacy Officer. You can reach her in one of the following ways:

 

Marie-Eve Bergeron, LL.B. and D.D.N.
Polyclinique de l’Oreille

 

By mail: 9293 Thimens Street, Pierrefonds, Quebec, H8Y 0A1
By phone: 514-353-0001 ext. 10255 / 514-353-7001 ext. 10255
By email: confidentialite@polycliniquedeloreille.com
By fax: 514-353-0029

 

You also have the option of filing a written complaint with the Commission d’accès à l’information – Direction de la Surveillance at the following address: 900-2045 Stanley Street, Montreal, Quebec, H3A 2V4, or by email at cai.communications@cai.gouv.qc.ca.