privacy policy
Privacy Policy
At Clinique Médicale Step, we consider the respect of everyone’s right to privacy as a fundamental value. That’s why we place great importance on preserving and ensuring the protection and confidentiality of the personal information you entrust to us. Respecting privacy and protecting personal information are essential to us. This Policy aims to inform you of the reasons and the way Clinique Médicale Step, or anyone acting on our behalf, will collect, use, and disclose your personal information.
By accessing Clinique Médicale Step’s website and Services, you consent to us collecting, using, disclosing, and retaining your personal information in accordance with this privacy policy (hereinafter referred to as the “Policy”).
Governing Law
This privacy policy shall in all respects be governed by and interpreted, construed and enforced in accordance with the laws of the Province of Quebec and the laws of Canada applicable therein.
Personal Information and Personal Health Information
Personal Information is any information which relates to a natural person, allowing that person to be identified. All Personal Information is considered confidential information and will be handled in accordance with relevant legislation.
Personal health information is a form of Personal Information and includes all registration, diagnostic, treatment, health service, and care information, obtained in any format (oral or recorded) that allows an individual, living or deceased, to be identified either directly or indirectly. Personal health information is highly confidential information and can include, but is not limited to:
- Any information relating to the physical or mental health of the individual, including the health history of an individual’s family.
- Any Personal Information that is contained in a file with health information is considered personal health information.
- Records of any form pertaining to any aspect of a health service program for the individual.
- Any material, biological or otherwise, taken from the individual.
- Individual identifiers including a health card number, payments coverage, or substitute decision-makers.
Collection, Use and Disclosure of Personal and Personal Information
Clinique Médicale Step uses and discloses Personal and Personal Health Information for purposes consistent with such Personal Information’s collection.
Access to private, sensitive, and confidential information, including user’s Personal Information, is restricted to authorized employees with legitimate business reasons. We require all our employees to abide by Clinique Médicale Step’s privacy standards. Our employees understand the importance of keeping your information private. For this reason, our employees are required to agree to a confidentiality agreement that prohibits the disclosure of any user information to unauthorized parties.
Employees are strictly prohibited from accessing or disclosing Personal Information without authorization. All employees are expected to always maintain the confidentiality of Personal Information and failure to do so will result in appropriate disciplinary measures including dismissal.
Clinique Médicale Step will never rent or sell the personal information or personal health information it collects. Clinique Médicale Step will never disclose personal or personal health information to third parties except as contemplated in this privacy policy or as otherwise permitted by law. Further, Clinique Médicale Step will never disclose Personal Information to third parties, except as required by law or upon demonstrated lawful authority, or as set out in this Privacy Policy.
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your Personal Information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so.
Your Personal Information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights or to investigate suspicion of unlawful activities. We may release certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of ourselves and others.
Should Clinique Médicale Step conduct market or product research, it will never use Personal nor Personal Health Information; rather, it would fully anonymize information, meaning that it would render it unlikely to be traced back to an individual.
Collection of Consent and User Withdrawal
Clinique Médicale Step relies on the consent for the collection, use and disclosure of Personal Information and Personal Health Information.
Users may withdraw their consent at any time however doing so may prevent you from benefiting from our services, in whole or in part. Withdrawal also may not be retroactive, such as data used in the evaluation of Clinique Médicale Step’s services.
Usage and Aggregate Data
Clinique Médicale Step collects usage information from users to our services. The purpose of this collection is to understand how a user can access and use the services to enhance and optimize our services. Usage information and data could include but is not limited to the user’s device type, device identifier, IP address, browser type, operating system, duration of use, number of messages sent or received, and times at which the application was accessed and used. In addition, Clinique Médicale Step will collect aggregate data about a group or category of services or users. This information, as well as the Personal Information collected, enables Clinique Médicale Step to analyze trends, administer Clinique Médicale Step’s services and products, troubleshoot, enhance, and improve Clinique Médicale Step’s services.
Clinique Médicale Step maintains the right to inform our users about any change that may affect information collected or stored. We may be required to comply with a court order or governmental regulatory requirement or disclose information in connection to legal proceedings. If required to do so, we will make every effort to notify the relevant parties about the proceedings.
Clinique Médicale Step reserves the right to use the contact information of users for the purposes of communications regarding any aspect of a user’s account or corresponding services and products. Users will have the option to participate or opt out of optional communications (e.g., marketing, press, events) while mandatory communications (e.g., security updates, product announcements/revisions) will go out to all active users.
Data Retention
Clinique Médicale Step reserves the right to reject, suspend, alter, remove, or delete data if it breaches our terms and conditions or that it is necessary to protect us or others where we have reasonable grounds for believing that a criminal act has been committed, or if required to do so by law.
Clinique Médicale Step processes and stores the user’s messages, logs, contact data, and other related information in order to provide Clinique Médicale Step’s services to the user. Data will be stored indefinitely in a secure and private manner or deleted as per direction from the user as allowable by operational needs and relevant law. Clinique Médicale Step maintains security/privacy policies and procedures to ensure every step is taken to maintain the integrity of the data in our care.
Control of User Data
Clinique Médicale Step takes reasonable steps to protect information collected from users to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction.
Clinique Médicale Step has appointed a Designated Privacy Contact who acts as Privacy and Security Officer (PSO) responsible for information system monitoring and information security policy and procedure management. The PSO is responsible for compliance with Clinique Médicale Step’s privacy program including:
- Undertaking privacy impact assessment and threat and risk assessments on a regular basis; and
- Adopting policies and procedures based on privacy impact assessment and threat and risk assessments to mitigate all identified risks, updated as necessary.
If you have questions or comments about the Policy or our practices regarding the protection of personal information, including how we use your personal information, or if you want to know how to exercise your rights regarding the processing of your personal information, including making a complaint, please contact our Privacy Officer:
Clinique Médicale Step
Attn: Privacy Officer
5757 boul. Cavendish, Suite 300
Cote St.-Luc, QC, H4W 2W8
514-307-5757
admin@cliniquestep.ca
We may make changes to this Privacy Policy from time to time. We always indicate the date of the last modifications. If the changes are significant, we will publish a highlighted notice on our website or communicate with you to inform you, subject to applicable laws.
Privacy Policy in effect as of: June 01, 2024
Last updated: June 01, 2024