Privacy and Personal Information Protection Policy

1. Introduction, Purpose, and Scope

  1. This policy explains how personal information is collected, used, communicated, and retained within the Clinique Chiro-Santé (the Clinic) to ensure compliance with legal requirements relating to the protection of personal information.

2. Collection, Use, Communication, Retention, and Destruction of Personal Information

Collection

Purposes of Collection. The Clinic collects and uses the personal information necessary for the exercise of its activities, notably:

  • From its patients,
    • The date the file was opened;
    • The patient's name at birth, address, telephone number, date of birth, and gender;
    • A brief description of the reasons for each consultation;
    • Radiographs, if applicable, and the results of all other patient examinations performed or requested by the chiropractor;
    • The diagnosis of the patient's condition;
    • A description of the professional services rendered and their date;
    • The recommendations made to the patient;
    • Annotations, correspondence, and other documents relating to the professional services rendered to the patient;
    • Financial information relating to the payment of fees.
  • From its employees, suppliers, and business relations,
    • First name;
    • Last name;
    • Professional title;
    • Business telephone number;
    • Cell phone number, if applicable (if provided by the person concerned);
    • Professional email address;
    • Personal email address, if applicable (if provided by the person concerned);
    • Professional postal address;
    • Financial information relating to the payment of salaries or fees.

The Clinic may collect any other personal information transmitted by a person through its contact form on its website or an email address of the clinic or the chiropractor.

Cookies

3. Purpose of the collection and means by which we collect personal information

We use the personal information collected only to achieve the objectives described below.

To enrich your browsing experience, our website uses cookies. These are small text files that are stored on your device when you browse our site. They allow us to collect information such as pages visited, duration of the visit, and your language preferences. This data helps us analyze trends, optimize our site, and offer you personalized content.

You can choose to accept or refuse cookies using our consent banner. It is also possible to enable and disable the use of cookies by changing your preferences in your browser settings. However, please note that disabling cookies may limit certain functionalities of our website.

3.1 Definition of the different cookies used

3.1.1 Functional cookies

These cookies are necessary for the proper functioning of the website. They are usually created in response to actions you have taken on the website, such as saving your privacy preferences or filling out forms. These cookies do not store any information that can personally identify you.

3.1.2 Statistical cookies

These cookies collect information about how you use the website, the pages you have visited, and the links you have clicked on. This data allows us to measure and improve the performance of the website. The data is anonymized and cannot be used to identify you.

3.1.3 Marketing cookies

These cookies can be placed on the website by our advertising partners or by the integration of social media sharing features. They can be used by these companies to build a profile of your interests to offer you personalized advertisements on other websites.

We encourage you to regularly consult the privacy policy of these social networks, as it may be subject to changes, to understand how your data is used via these cookies. It is important to note that most of these social networks are based outside of Canada.

3.1.4 Security cookies

To prevent fraud and protect our systems, the website forms can be protected by Google ReCaptcha technology. This tool, which uses cookies, collects data on how a user interacts with the website. How the user navigates the site with their mouse, how they click between content, the time they take to perform tasks, and the device they use are some examples of the data collected. Analyzing this data allows the tool to determine the likelihood that the user is a robot or not. This data may be shared with other products and services of the American company Google.

  • The Clinic uses the services of Square and Clover to accept your payments. The clinic collects, uses, retains, discloses, and protects your personal information, including your payment information, in accordance with the most recent version of its privacy policy. This personal information may include transaction data, information relating to your identity, as well as information concerning your online activity. By making the payment, you consent to the collection, use, retention, and disclosure of your personal information by the clinic. You also consent to your personal information collected by the clinic being transferred outside of Quebec, including to the United States or elsewhere in the world in a manner compliant with applicable laws. It could also be disclosed in accordance with applicable laws. You have the right to request the destruction and rectification of your personal information collected by the clinic according to the terms of its privacy policy.
  • The Clinic uses the services of Stratego Informatique to host the files of its patients. The Clinic retains, discloses, and protects personal information in accordance with the most recent version of its privacy policy and in accordance with the terms and conditions provided for in the contract concluded with the Clinic. This personal information may include your full name, as well as your email, as well as any information mentioned in article 2a. of this policy. You have the right at any time to request the rectification and withdrawal of your personal information kept by the Clinic according to the terms of its privacy policy.
  • Method and source of collection. Personal information is generally collected by the Clinic directly from the persons concerned and with their consent. The Clinic may collect personal information without the knowledge and consent of the person concerned in limited circumstances authorized by the Act respecting the protection of personal information in the private sector.

Communication

  • General. The Clinic does not communicate any personal information it holds to a third party without the consent of the person targeted by the personal information except if :
    • It concerns business contact information whose communication is reasonable within the framework of its activities;
    • The transmission of the information without notifying the person concerned is required for the Clinic (or the chiropractor) to comply with its legal obligations;
    • The transmission of the information without notifying the person concerned is required to avoid serious prejudice to the person targeted by the information.
  • Communication to a supplier of the Clinic (or the chiropractor). The Clinic cannot communicate personal information to a service provider unless the processing of personal information is governed by an appropriate contract approved by the person responsible for the protection of personal information.
  • Communication outside of Quebec. The Clinic generally does not communicate personal information outside of Quebec. If this is the case, and before communicating personal information outside of Quebec (including in another Canadian province), the Clinic must ensure that the personal information communicated will benefit from adequate protection.

Retention and destruction

  • The computerized personal information held by the Clinic is kept in a database protected by reasonable IT and organizational security measures.
  • The Clinic retains the personal information it holds for a duration of seven years after its last use unless a different retention period is provided by law.
  • After the expiration of their retention period, the personal information is destroyed unless limitations on the IT level force its retention or unless it is transmitted to a person or organization that will use it in a de-identified form for study, research, or statistical purposes.

4. Security of Personal Information

  • The Clinic takes reasonable security measures to protect the personal information under its responsibility.
  • Limited access. Members of the Clinic staff can only access the personal information they need in the exercise of their functions.
  • Physical security measures.. The staff of the Clinic takes the necessary measures to protect the physical documents that contain personal information.
  • Technological security measures. The staff of the Clinic must notably comply with the following security measures :
    • Encrypt documents that contain lists of personal information;
    • Use a password to access the databases containing personal information and;
    • Change passwords on a regular basis.
  • Administrative security measures. The Clinic implements the following security measures :
    • Any person having access to personal information held by the Clinic must sign a confidentiality commitment;
    • The staff receives training in awareness of information security risks.

Access to Personal Information and Rectification

  • The personal information collected by the Clinic is accessible at its principal place of business. The person concerned by this information can access it on request online at the address info@drhirosante.com or by mail.
  • The Clinic responds to the requests of persons who wish to access the personal information that the Clinic holds about them, by giving them access to this information, by rectifying it when it is inaccurate or incomplete, by ensuring its portability if applicable, by destroying it when its retention is no longer necessary, or by de-indexing it.
  • A person concerned by personal information held by the Clinic can ask it to :
    • Confirm the existence of the information and transmit a copy, to them or to any person they authorize;
    • Rectify the inaccurate, incomplete, equivocal information or those that are collected, communicated, or kept in a way that is not authorized by this policy or by a law;
    • Delete outdated or irrelevant information.

5. Governance

Responsible for the protection of personal information

  • Dr Étienne Lefebvre, président is responsible for the protection of personal information at the Clinic (or the chiropractor). He can be contacted at the email address info@drchirosante.com

Roles and Responsibilities of Staff Members

  • All employees of the Clinic are required to comply with this policy, as well as applicable laws, regulations, and contractual obligations when they process, use, or communicate personal information held by the Clinic.

6. Complaints

  • Anyone may file a complaint regarding the protection of personal information held by the Clinic by contacting the person responsible for the protection of personal information at the email or postal address mentioned in paragraph 21 of this policy.
  • The person responsible for the protection of personal information must respond to the complainant within 30 days of receiving a complaint.
  • Confidentiality Incidents

Procedure for Handling Confidentiality Incidents

  • In the event of a confidentiality incident, the Clinic or the chiropractor is committed to
    • identifying the cause of the incident;
    • remedying the incident;
    • reducing the risks of harm being caused; and
    • preventing new incidents of the same nature from occurring.

Confidentiality Incident Registry

  • The person responsible for the protection of personal information keeps a registry of confidentiality incidents.

7. Questions

  • Any questions relating to this policy should be sent to the person responsible for the protection of personal information of the Clinic, at the email address info@drchirosante.com, or at the postal address :
    4080, boulevard Le Corbusier, suite 203
    Laval (QC)
    H7L 5R2

Policy Date : 11/05/2025

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