1.
PURPOSE AND SCOPE
Vigilance Santé (hereinafter “Vigilance” or “we”) takes great care
to protect the Personal Information (as defined below) provided to us.
The purpose of this policy is to establish and describe
- Vigilance’s obligations regarding the collection, use, communication, retention, and destruction of Personal Information;
- the scope of the consent given by individuals concerned by this information and the ways in which they can exercise their rights; and
- the security and governance measures in place to protect the privacy of these individuals.
The Policy applies to the direct collection of Personal Information concerning the users of the
website https://www.vigilance.ca/
(hereinafter: the “Website”) by Vigilance.
This Policy does not apply to Personal Information related to patients or other individuals that is
communicated by a USER while using INFORMATION ASSETS (as defined in the Terms and Conditions of
Use of Information Assets, available here: https://store.vigilance.ca/legal-documents#terms-conditions-of-use).
If you have any questions or concerns about this information, please refer to the Privacy Policy – Information Assets, available here: https://www.vigilance.ca/legal-documents#data-privacy-policy. For the
sake of clarity, the latter applies regardless of the method of access to the INFORMATION ASSETS, whether by the web portal or Windows portal.
2.
COLLECTION OF PERSONAL INFORMATION
“Personal Information” refers to any information that relates to a natural person and can be used to
identify them, either directly or indirectly.
We only collect Personal Information about you that is necessary to establish, manage, and maintain
our relationship with you and provide the best possible service. Depending on the circumstances, we
may collect the following Personal Information about you:
- Name and language of correspondence
- Email address
- Phone number
- Mailing address
- Profession
- Licence number
- Website usage data and browsing history
- Any request you may send us (for processing and archiving purposes)
We may collect Personal Information on the Website, either directly or through forms (e.g.,
technical support, general information). More generally, we may collect information when you
communicate with one of our employees or representatives by email, on the phone, or in person.
3.
CONSENT
Your consent to the collection, use, and communication of your Personal Information must be clear,
free and informed. It must be given for the specific purposes and objectives identified in the
following section of this Policy.
Depending on the nature and sensitivity of your Personal Information, your consent may be express
(i.e., given verbally, in writing, or electronically) or implied (e.g., when you provide Personal
Information voluntarily). Where Personal Information is sensitive, we will ensure that your consent
is expressly given.
BY USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, USE, COMMUNICATION, AND RETENTION OF YOUR
PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. PLEASE READ IT CAREFULLY.
If you do not consent, please do not use the Website. Except where otherwise provided by law, you may
withdraw your consent at any time upon reasonable notice. Please note that if you choose to withdraw
your consent to the collection, use, and communication of your Personal Information, certain
features of our Website may no longer be available to you, or we may no longer be able to offer you
certain services.
4.
PURPOSES FOR THE USE OF PERSONAL INFORMATION
We may use your Personal Information for the following purposes:
- Website management, planning, and improvement
- Analyzing the use of the Website, including the use of specific features
- Developing and improving the Website based on your searches, activity, and choices
- Identifying and correcting Website anomalies
- Responding to your emails and technical support requests
- Communicating information to clients about changes and improvements to our services
Your personal information will not be used for purposes other than those listed above, except with
your consent or as required or permitted by law.
5.
UNDERTAKINGS AND GOVERNANCE MEASURES
We have security measures in place to ensure the protection of your personal information.
Specifically, we undertake to
- implement protection measures to protect the personal information we collect, use, communicate,
retain, hold or destroy;
- implement the physical, administrative, and technological measures necessary to prevent
unauthorized persons from gaining direct or indirect access to Personal Information;
- ensure that only our employees, mandatary, and contractors who are authorized to consult
Personal Information have access to it and that they consult only the Personal Information
necessary for the performance of their duties; and
- ensure that our employees, mandatary, and contractors who have access to Personal Information
are
subject to confidentiality undertakings and guidelines with sanctions in the event of a breach
of their obligation of confidentiality.
6.
COMMUNICATION OF PERSONAL INFORMATION
To whom may we communicate Personal Information?
Whenever we need to communicate your Personal Information, we will endeavour not to disclose
more information than is necessary under in the circumstances.
We recognize that, except in the cases and subject to the conditions described below, the
communication of your Personal Information to a third party requires your consent. However,
we may, without your consent, communicate your Personal Information where permitted or
required by law. Below is a description of the parties to whom we may communicate your
Personal Information, for what purposes, and the measures taken to protect such information
during transmission.
Recipient | Purpose | Measures |
---|
Subcontractors and mandatary | We sign contracts with subcontractors and mandatary to provide you with a service
and/or improve existing services.
| Subcontractors and mandatary sign a contract that requires them to
- only use the Personal Information necessary to provide a service;
- refrain from disclosing or communicating Personal Information without our
consent;
- implement strict security measures;
- allow us to audit these measures;
- notify us immediately of any confidentiality incident; and
- destroy Personal Information at the end of the contract.
|
Another party in a business transaction Such a transaction is defined as the sale or lease of all or part of our company
or its assets, a change in its legal structure by merger or otherwise, the
obtaining of a loan or other form of financing by it, or the taking of a
security interest to secure one of its obligations (hereinafter “Business
Transaction”). | To carry out a Business Transaction. | The party signs a contract requiring them to
- use only the Personal Information necessary to carry out the Business
Transaction;
- implement strict security measures;
- refrain from disclosing or communicating Personal Information without our
consent;
- notify us immediately of any confidentiality incident; and
- destroy the Personal Information if the Business Transaction is not carried
out or if the Personal Information is no longer required to carry out the
Business Transaction
|
Lawful authorities | To comply with an order or decision of a court, including a valid search warrant, or
of a regulatory authority, we may be required to provide Personal Information.
|
The laws governing these authorities require them to put in place measures to
respect and preserve the confidentiality of your Personal Information.
We generally refuse to grant access if a request is not legally binding.
|
Our lawyers or attorneys | To ensure our defense or assert our rights, we may, in certain cases, disclose your
Personal Information.
| Both the law and the letters of mandate we sign obligate our lawyers and other legal
advisors to protect the confidentiality of all our communications with them.
|
Where may we communicate Personal Information?
To fulfill the purposes set out in section 4 of this Policy, we may communicate Personal
Information outside of Quebec, particularly to parties in other Canadian provinces.
Before communicating Personal Information outside of Quebec, we will conduct a Privacy Impact
Assessment, which will take into account the following factors:
- The sensitivity of the Personal Information
- The purpose for its use
- The protection measures in place
- The legal framework applicable in the state where the Personal Information will be communicated.
We will proceed with the communication only if this assessment demonstrates that the
Personal Information will have adequate safeguards, in keeping with generally recognized
privacy principles. In addition, this communication will be the subject of a written
contract that takes into account all the conclusions of the assessment, as well as the
measures taken to mitigate the identified risks.
7.
RETENTION OF PERSONAL INFORMATION
We retain your Personal Information only for as long as necessary to fulfill the purpose for which it
was collected, to meet legal retention requirements, and for as long as necessary to protect our
legitimate business interests.
We reserve the right to establish Personal Information destruction policies from time to time. Upon
request, we can inform you of the amount of time your Personal Information will be retained.
If you request the destruction of your Personal Information, we will use reasonable efforts to comply
with your request as soon as possible. Your Personal Information will be deleted within thirty (30)
days following your request.
8.
YOUR RIGHTS
ALL REQUESTS FROM USERS OR OTHER INDIVIDUALS CONCERNED WHOSE INFORMATION IS TRANSMITTED TO
US UNDER A SERVICE CONTRACT MUST BE ADDRESSED TO THE USER PRIVACY OFFICER. EXCEPT TO INFORM YOU OF THE SOURCE
OF SUCH PERSONAL INFORMATION, WE DO NOT RESPOND TO SUCH REQUESTS. WE LIMIT ITS USE TO THAT WHICH
IS NECESSARY TO FULFILL THE CONTRACT WITH OUR CLIENTS AND RECTIFY OR DELETE THE INFORMATION
ACCORDING TO THEIR INSTRUCTIONS AS SPECIFIED IN THE PRIVACY POLICY – INFORMATION ASSETS.
- The right to be informed of the use, communication, retention, and destruction of your Personal Information. This is what this Policy is meant to achieve.
- The right to access your Personal Information to obtain, where appropriate, more details on how we use, communicate, retain, and destroy such information.
- In some cases, you may object to, restrict, or withdraw your consent to such operations by giving reasonable notice by email to the email address provided at the end of this Policy.
- The right to have your Personal Information corrected if it is inaccurate or misleading and to have it completed if it is incomplete.
- The right to have your Personal Information deleted subject to our legal obligations.
- The right to be informed of a confidentiality incident involving your Personal Information and that may cause you serious harm. To this end, we maintain a register of all confidentiality incidents and assess the harm they may cause.
You may exercise these rights by sending an email to the email address provided at the end of this
Policy. We will respond to any request within 30 days of receipt, except where the law permits an
extension of that time.
Any rectification or deletion of Personal Information will be communicated to third parties to whom
such information has been communicated.
If we refuse to furnish or correct your information, we will provide you with the reasons for the
refusal, the applicable sections of the law, and information about your remedies, all subject to the
limitations of the law.
If we refuse to rectify your Personal Information, we will allow you to place written comments in
your file regarding the Personal Information for which rectification has been refused. We will also
retain the Personal Information that has been the subject of an access request for as long as
necessary to allow you to exhaust any remedies provided by law.
9.
COOKIES
When you visit our Website, we may use a feature of browser software called a “cookie” to collect
information anonymously and establish your user profile. A cookie is a small text file with a unique
identification number that identifies your browser (but not you) to our computers each time you
visit our Website. We use these cookies to customize our Website based on your preferences and to
compile statistics on your activity. The information collected may include the following:
- Your computer’s Internet Protocol (IP) address
- Your geolocation
- The operating system you’re using
- Your language preference
- The date and time you access our Website
- The previous website you visited that provided you with a link to our Website
- The content you viewed and downloaded from our Website and the number of visits
Generally, the cookies we use fall into three categories:
Technical:
Technical cookies are used throughout the browsing experience to facilitate the use of our
Website. For example: a technical cookie may be used to remember your username to facilitate
your login or to remember your preferences or options you have chosen.
Analytics:
These cookies are anonymous and are used to collect statistics on the use of our Website.
Advertisement:
These cookies may be placed by the Website or by other sites displaying advertisements or
announcements. These cookies collect information anonymously and build up your visitor profile.
If you wish, you can set your browser to notify you when you receive cookies or to refuse them. You
can erase cookies from your computer’s hard drive, block the creation of cookies, or receive a
warning before a cookie is stored.
In doing so, however, your use of our Website may be affected and you may no longer have access to
all its features. Please refer to My Ad Center
and the Network Advertising Initiative, as well as
your browser’s instructions or help section, to learn more about cookies.
10.
PRIVACY OFFICER
If you have any questions about this Privacy Policy or the way in which we handle your Personal
Information, or to exercise your rights, please contact our Privacy Officer by email or by mail at
the following coordinates:
- Privacy Officer
- 202-440 Notre-Dame
- Repentigny (Quebec)
- J6A 2T4
Or by e-mail: rprp@vigilance.ca
Please provide sufficient detail in all correspondence to enable us to identify the information you
wish to access or have corrected, if applicable. We recommend that you keep your e-mails secure.
Please note that we may ask you to verify your identity before responding to your request.
11.
CHANGES TO THE POLICY
Vigilance reserves the right to modify the content of this Policy at any time. Any changes will
appear on our Website and will be brought to your attention when you log in. We recommend that you
print a copy of this Policy for your records and review this section of our Website periodically.