Pointe-Claire | Mile-Ex 
Privacy Policy
Introduction
Clinique Médicale 360 Inc. (the “Clinic”) is subject to the application of the Act Respecting the Protection of Personal Information in the Private Sector. Accordingly, the Clinic is responsible for ensuring the protection of the personal information it holds and for complying with this legislation.
This policy (the “Policy”) is intended to ensure the protection of personal information and to govern the manner in which the Clinic collects, uses, discloses, retains, protects, and destroys such information when an individual uses our website or conducts business with the Clinic.
Scope and Definitions
This Policy applies to all Clinic personnel at every level of the organization.
Personal information is defined as any information or combination of information relating to a natural person that allows that person to be identified, including, but not limited to, name, address, email address, telephone number, gender, banking information, health insurance number, medical information, biometric data, ethnic origin, language, membership status at the Clinic, etc.
This Policy applies to all personal information managed by the Clinic, whether relating to prospective or current clients, employees, suppliers, or any other individual.
Responsibilities of the Clinic
We are responsible for the personal information in our possession.
The individual responsible for the protection of personal information oversees the implementation of this Privacy Policy and the related processes and procedures required to protect such information. Every member of our staff who handles or has access to personal information, or who is involved directly or indirectly in its management, has been duly informed of the obligation to protect personal information and manage it in accordance with this Policy.
Collection, Use and Disclosure
The Clinic collects various types of personal information in the course of providing medical services to individuals.
The Clinic limits the collection, use, and disclosure of personal information to the purposes identified. Personal information may only be accessed by authorized individuals and solely for the purposes for which they have been authorized.
The Clinic applies the following general principles regarding the collection, use, and disclosure of personal information:
Consent
- As a general rule, the Clinic must obtain the consent of the individual concerned before collecting personal information from third parties, disclosing it to third parties, or using it for secondary purposes. However, the Clinic may act without consent in certain circumstances and under conditions permitted by law.
- When the Clinic collects personal information concerning individuals under the age of 14, consent must be obtained from the holder of parental authority or the legal guardian, unless the collection is clearly for the benefit of the minor, in the opinion of the Clinic’s professionals.
Collection
- The collection of personal information is limited to what is necessary to achieve the purpose for which it is collected. Generally, personal information is collected directly from the person requesting services or becoming an employee of the Clinic.
- At the time of collection, the Clinic informs the individual concerned of the following:
- The purposes for which the personal information is collected;
- The means by which the personal information is collected;
- The rights of access and correction provided by law; and
- The right to withdraw consent to the use and disclosure of personal information.
- In certain cases, personal information may be received by the Clinic through third parties, particularly in the case of results from external medical examinations.
- The Clinic may collect personal information from third parties without the consent of the individual concerned where:
- It is in the interest of the individual and it is not possible to collect the information from the individual in a timely manner; or
- It is necessary to ensure the accuracy of the information.
Use
The Clinic may only use an individual’s personal information for the purposes identified in this document or for any other purpose indicated at the time of collection. If the Clinic wishes to use the information for another reason or purpose, new consent must be obtained from the individual concerned, and such consent must be expressly obtained where sensitive personal information is involved.
However, in certain circumstances permitted by law, the Clinic may use personal information for secondary purposes without the individual’s consent, for example:
- When such use is clearly for the benefit of the individual;
- When necessary to prevent or detect fraud; or
- When necessary to evaluate or improve security and protection measures.
Disclosure
- As a general rule, and unless otherwise provided in this Policy or required by law, the Clinic will obtain the consent of the individual before disclosing personal information to a third party. Furthermore, where consent is required and sensitive personal information is involved, the Clinic will obtain the individual’s explicit consent prior to disclosure.
However, in certain cases specifically provided by law, the Clinic may disclose personal information without the individual’s consent.
Cookies and Their Use
When you visit our website, clinique360.com, we may automatically collect certain information through cookies. A cookie is a small file that requests permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or informs you when you visit a particular website.
Cookies allow web applications to respond to you as an individual. Through cookies, the web application can tailor its operations to your preferences. The different types of cookies are as follows:
Necessary – Necessary cookies are essential for the proper functioning of the website. This category includes only cookies that ensure basic functionalities and security features of the website. These cookies do not store any personal information.
Functional – Functional cookies help perform certain functionalities such as sharing website content on social media platforms, collecting feedback, and other third-party functions.
Analytics – Analytics cookies are used to understand how visitors interact with the website. These cookies provide information on metrics such as number of visitors, bounce rate, traffic source, etc.
Performance – Performance cookies are used to understand and analyze key website performance indicators in order to provide visitors with a better user experience.
Advertising – Advertising cookies are used to provide visitors with relevant advertisements and marketing campaigns. These cookies track visitors across websites and collect information to deliver personalized advertising.
Other – Other unclassified cookies are those currently being analyzed and not yet categorized.
Cookies may be accepted, customized, or refused through the cookie consent banner. Most web browsers automatically accept cookies, but you can usually modify your browser settings to refuse cookies if you prefer. Refusing cookies may prevent you from fully enjoying the website.
Retention and Destruction of Personal Information
The Clinic will retain personal information only for the period necessary to fulfill the purposes for which it was collected. This period may vary depending on the individual and the reasons for their interaction with the Clinic.
The Clinic ensures that personal information is destroyed or anonymized at the end of the retention period or when the information is no longer required. Destruction of information by the Clinic will be carried out securely to ensure the protection of such information.
Data Security
The Clinic undertakes to implement reasonable security measures to protect the personal information in its possession. Access to personal information is restricted so that only employees who require access are authorized to access it.
Rights of Access, Correction and Withdrawal of Consent
To exercise their rights of access, correction, or withdrawal of consent, individuals must submit a written request to the person responsible for the protection of personal information at the Clinic. Individuals may request access to their personal information in order to make corrections.
They may request that the dissemination of personal information cease or that any hyperlink associated with their name be de-indexed if the dissemination of such information violates the law or a court order. They may also request that the hyperlink be re-indexed when certain legal conditions are met.
Subject to applicable legal and contractual restrictions, individuals may withdraw their consent to the disclosure or use of the information collected.
Individuals may request from the Clinic the personal information collected about them, the categories of persons within the Clinic who have access to it, and the retention period.
Complaint Handling
Any complaint must be submitted in writing to the person responsible for the protection of personal information.
The individual must provide their name, address, email address, telephone number, and the reason for the complaint, including sufficient detail to allow the Clinic to assess it. The person responsible for the protection of personal information may request any additional information deemed necessary to evaluate the complaint.
The Clinic will handle all complaints confidentially within 30 days following receipt of the complaint or following receipt of any additional information deemed necessary by the person responsible for the protection of personal information.
The complaint will be reviewed and a response will be sent to the complainant by email. If the complaint cannot be processed within this timeframe, the complainant will be informed of the reasons justifying the extension, the status of the processing, and the reasonable time required to provide a final response.
Each complaint constitutes a separate file, including the complaint itself, the analysis and supporting documentation, and the response sent to the complainant.
Person Responsible for the Protection of Personal Information
This Policy is approved by the person responsible for the protection of personal information at the Clinic.
For any request, question, or comment regarding this Policy, please contact the person responsible by email.
Charles-Olivier Cloutier, Executive Vice-President
1 Holiday Avenue, Suite 100
Pointe-Claire, Quebec H9R 5N3
514-375-2705, ext. 108
Amendments to the Policy
The Clinic reserves the right to amend this Policy at any time. Any changes will take effect immediately upon publication on the website: https://www.clinique360.com.