Privacy Policy
1. SCOPE OF THE POLICY
a. Purposes of this Policy
In the face of new challenges and dangers related to preserving the security of personal information arising from online commerce, it is necessary to pay particular attention to the protection of privacy. That's why, at Doctr, we take the protection of your Personal Information (as defined below) seriously and are committed to respecting the confidentiality of the information we collect.
Doctr undertakes to respect, in accordance with this Policy and applicable federal and provincial laws in force in the province of Quebec, the obligations relating to the collection and processing of your Personal and Confidential Information, obtained while operating its business, so that everyone can benefit from and safeguard their privacy.
In doing so, Doctr wishes to ensure the accuracy, security and confidentiality of your Personal Information, and will not collect, use or disclose your Personal Information other than in accordance with the Policy and applicable laws.
We collect your Personal Information as part of our corporate mission to provide telehealth services, including, but not limited to, Doctr Service Coordinator, Doctr Wait Times, Doctr Nurse Service, Doctr Telemedicine Service, Directory and One- Cardless Punctual Services (hereinafter the "Services"). We, as an intermediary, aim to facilitate access to healthcare professionals. The Services are available on our Platform. We may also collect your Personal Information to suggest or provide you with additional recommendations, services and/or products tailored to your needs and reflecting the aforementioned mission.
This Policy complies with Canada's Privacy Act (R.S.C., 1985, c. P-21) and Quebec's Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1) (collectively referred to as the "applicable privacy legislation").
b. Application of this Policy
By browsing the Platform or subscribing to our email publications, you, as a User, agree to the terms and conditions of this Policy. You agree that your Personal Information collected by filling out an online form, submitting information, requesting to be contacted, uploading content to the Platform, and/or requesting other Services, may be transmitted to competent and authorized Doctr personnel.
By browsing the Platform, accepting this Policy or providing us with Personal Information after having had the opportunity to review this Policy or any supplemental notice, you agree that your Personal Information will be treated in accordance with the Policy and the supplemental notice, if any.
We only collect Personal Information that is reasonably necessary for the provision and management of our Services and operations. We collect your Personal Information in a variety of ways. For example, we collect it directly from you, from Third-Party Providers or when you visit our Platform.
The Policy applies to you in all situations where you interact with Doctr and we collect information about you, including when you visit our Platform, use our Services or communicate with us by any means.
The Policy describes the Personal Information that Doctr may collect from its Users during its activities.
The Policy also describes, among other things, how Doctr handles, stores and/or destroys your Personal Information, the purposes for which it is collected, how it is used and the circumstances in which it may be transferred to third parties. The Policy details your rights regarding the collection, transfer, use, retention and disclosure of your Personal Information.
In addition, the Policy describes the procedures by which you may access, update or correct your Personal Information, as well as the options available to you regarding the protection of your privacy.
c. Third-Party Providers
Doctr will only disclose to third-parties whose participation is strictly necessary to provide the Services and/or to maintain our commercial relationship with you, as the case may be, including but not limited to doctors as part of the Doctr Telemedicine Service, clinics or medical appointment scheduling platforms as part of the Doctr Service Coordinator or any other company practicing in the healthcare field selected by the User when using the Platform, and only the information necessary for these purposes (the aforementioned third parties are hereinafter collectively referred to as the "Third-Party Healthcare Providers") as well as the commercial providers who help us operate our technological systems, applications and infrastructure, and implement our internal procedures and advertising and marketing strategy (the "Commercial Providers") (the Third-Party Healthcare Providers and the Third-Party Commercial Providers are hereinafter collectively referred to as the "Third-Party Providers"). Only Personal Information that is strictly necessary for each Third-Party Provider's services will be communicated to them by Doctr.
In some cases, at the time of collection of your Personal Information, we may provide you with additional information regarding the processing of your Personal Information. We may also, in some cases, obtain specific consent from you regarding the use or disclosure of your Personal Information.
By providing Doctr with your Personal Information, you authorize Doctr to use and disclose your Personal Information to Third-Party Providers, as appropriate, in connection with the provision of the Services, the management of our contractual relationship, our business relationship with you, and in accordance with this Policy and as permitted or required by law, as well as implicitly, if circumstances indicate.
d. Additional consents and withdrawal
Doctr will seek your consent before using your Personal Information for purposes other than those covered by your initial consent under the Policy.
In addition, you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please be aware, however, that without your consent, Doctr may not be able to provide or continue to provide you with certain Services or information that may be useful to you.
If you provide Doctr or its Third-Party Providers with information, personal or otherwise, about another individual or entity, you acknowledge that you have the necessary authorization to do so and/or that you have obtained all necessary consents from such third party to allow us to collect, use and disclose its information, personal or otherwise, for the purposes set forth in this Policy.
YOU ACKNOWLEDGE AND AGREE, WITHOUT RESERVATION, THAT YOU ARE SOLELY AND ENTIRELY RESPONSIBLE FOR COMPLYING WITH THE PROVISIONS OF THIS SUBSECTION, AND THAT DOCTR SHALL IN NO EVENT BE LIABLE FOR THE LACK OF PRIOR AUTHORIZATION AND/OR CONSENT ON THE PART OF SUCH THIRD-PARTY.
To withdraw your consent or stop receiving communications of personal information, please contact us as indicated in section 2 below.
2. PRIVACY OFFICER
Please feel free to contact Doctr's Privacy Officer with any questions, comments or concerns you may have regarding the Policy, how we treat your Personal Information, or to exercise your rights regarding your Personal Information. Our Privacy Officer can be contacted at:
By email: legal@doctr.ca ; or
By post:
WISE GUYS TECHNOLOGIES INC. – Officer in charge for the protection of personal information
200-4388, #622, Saint Denis Street, (H2J 2L1),
Montreal, Quebec, Canada
The Officer in charge will contact you within thirty (30) days of receiving your communication.
3. ROLES AND RESPONSIBILITIES OF DOCTR’S PERSONNEL
Within Doctr, we have assigned the following roles and responsibilities:
Privacy Officer
(i) the implementation of privacy policies and procedures within Doctr;
(ii) train our staff on privacy policies and obligations;
(iii) keep a register of incidents relating to the confidentiality of personal information;
(iv) assess the possible consequences of a privacy incident;
(v) notify the “Commission d'accès à l'information du Québec” in the event of a privacy incident likely to cause serious harm; and
(vi) participate in the detection of confidentiality risks and notify the persons responsible in the event of a confidentiality incident.
Operations Manager
(i) ensure that all employees have signed the confidentiality agreement and that it is recorded on the server;
(ii) ensure that employee access rights to the server are monitored;
(iii) ensure that all Third-Party Providers have a privacy policy and comply with it; and
(iv) help identify risks of confidentiality breaches and notify those responsible in the event of a confidentiality incident.
Administrative personnel
(i) the collection of Personal Information from Users;
(ii) obtain consent for the use of Users' Personal Information;
(iii) sign and abide by the confidentiality agreement; and
(iv) participate in the identification of risks of confidentiality breaches and inform those responsible in the event of a confidentiality incident.
Doctr – Training its employees (the "Employees")
(i) explain the clauses of the confidentiality contract when new employees are hired, and reiterate them every year thereafter;
(ii) periodically remind Employees of confidentiality requirements at annual meetings; and
(iii) raising awareness of the need to report confidentiality incidents.
4. DEFINITION OF PERSONAL INFORMATION
“Personal Information" refers to information that is specifically associated with a natural person, such as yourself, that can be used to identify that person, either on its own or in combination with other information that Doctr may have access to. Information that has been rendered anonymous or arranged in such a way that it can no longer be used to identify a specific individual does not constitute Personal Information. For example, an individual’s office mailing address is not Personal Information in and of itself, except when it is mentioned in conjunction with other information about the individual, or when its mere mention reveals Personal Information about the individual.
5. WHAT PERSONAL INFORMATION DO WE COLLECT?
Doctr collects the following Personal Information from the User:
(i) Information about your identity and contact details, such as your first and last name, email address, gender indicated on the health insurance card, date of birth, telephone number and home address;
(ii) Information relating to the search for an appointment with a healthcare professional, such as the reason for the search for a medical consultation, the medical service sought, a photo of the medical referral when the User needs to see a specialist, availability for an appointment, the Quebec Health Insurance Plan card number or equivalent in other Canadian provinces;
(iii) Information relating to your health, in addition to that set out in paragraph (ii) above, such as current medication, previous surgeries, changes in habits or general state of health, weekly consumption of cigarettes, alcohol or drugs, allergies, diet, last time you ate, any other information enabling Doctr to understand the situation;
(iv) If applicable, information relating to the health of a child in the User's care, such as the reason why the User wishes to use the Doctr Nurse Service, behaviour or events prior to the injury or illness, vaccinations and their date, possible contamination of the environment, school or daycare, current or possible allergies, medication or antibiotics currently taken or taken in the last month, medical conditions of the child in the User's care, eating habits and sanitary habits ;
(v) Information about your location, including your country, region and city and the distance you are willing to travel for the Services, if applicable;
(vi) Demographic data, anonymous information, for example the time spent on a page of the Platform by a User, and pseudonymous data;
(vii) Information extracted from the synchronization with a Third-Party Service Provider, such as Google Analytics, Google Ads, Google Tag Manager and Meta, our Third-Party Providers who help us understand the User's behavior on the Platform;
(viii) Information collected automatically when you visit our Platform, such as the type of device used, the type of browser used and/or the operating system, the site(s) visited when you arrive on the Platform;
(ix) Information collected by what the User writes on the Platform chat;
(x) Information and statistics about your user behavior, including sales, purchases and other relevant performance and accounting information; and
(xi) Information about the Services you have purchased from Doctr.
Please note that the information collected in paragraphs (iii) and (iv) is collected solely for the purposes of Doctr Nurse Service and Doctr Telemedicine Service that may result therefrom.
6. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Doctr may collect Personal Information from the User in the following ways:
(i) When you register Personal Information on the Platform;
(ii) When you fill in the form to obtain Doctr Nurse Service or a contact form;
(iii) When you make an appointment request on the Doctr;
(iv) When you contact us by telephone, chat, email, Facebook or other means of communication; or
(v) When you fill out a form to participate in a contest, inventory request, promotion or opinion survey. By completing such a form, you authorize us to collect your Personal Information. No Personal Information of a medical nature will be collected in this way.
7. FROM WHOM DO WE COLLECT YOUR PERSONAL INFORMATION?
We generally collect Personal Information in the following ways:
a. Directly from you or, if you are a minor, from the person with parental authority, or, if applicable, form your guardian or attorney.
The Platform is designed for use by persons of legal age as defined in the Province of Quebec. Doctr does not knowingly collect Personal Information from persons under the age of eighteen (18), except where such information has been provided by the person having parental authority, as provided below.
The User may provide us with Personal Information directly through our Platform, which is the most recommended means, and by email.
In certain cases, in particular when the User is a minor or under legal guardianship, Personal Information may be provided to us by the person who has parental authority over the minor User, or by his or her legal guardian or proxy, as the case may be.
For example:
(i) We collect your Personal Information when you fill out our registration form or when you update your Personal Information or import content onto the Platform, to provide you with the Services you request.
(ii) We collect your Personal Information when you complete any of the following forms on the Platform: Doctr Service Coordinator appointment request form (whichever is applicable to your situation), telemedicine consultation order form, contact form, nurse consultation forms (whichever is applicable to your situation), support form, or newsletter form.
(iii) When you request the Doctr Telemedicine Service, we collect the personal information necessary to put you in contact with the Third-Party Provider. Doctr cannot be held responsible for any event subsequent to the User being put in contact with the Third-Party Provider and the User's use of a telemedicine platform offered by the Third-Party Provider is subject to the privacy policy of the provider of the Website in question.
(iv) When you use a chat service on the Platform to chat with a Doctr representative (in this case, you must at all times comply with the instructions communicated via the chat service interface and in our Terms of Use, regarding the nature of the information you are authorized to share and you must avoid providing Personal information where prohibited).
b. Via the Platform
i. Automatic collection
Cookies are files created by a website to record information about a device's browsing on the website. They enable certain information to be collected during exchanges between a device and a server.
We use the information collected in this way to adapt the Platform to your preferences, to compile statistics on your consultation and use of our Platform and our electronic communications, such as our newsletters, to improve them, and to present you with advertising from Doctr with the help of our partners.
The information collected through Cookies is mainly the following:
(i) Location;
(ii) Domain name;
(iii) IP address;
(iv) User analysis, performance and behavior;
(i) Advertising/redirection; and
(v) User's language(s) ;
Most cookies do not reveal your identity. They are collected solely due to the technological requirements inherent to Internet browsing. Most browsers automatically accept cookies, but it is generally possible to modify this behavior. However, if you choose to refuse Cookies, you may not be able to identify yourself or use certain functions of the Platform.
The use of this information allows us to improve the Services, personalize your experience and better track your past use.
In addition to the methods described above, we may also collect information through the use of Cookies or similar technologies, particularly during your visits to our Platform. These methods enable us to collect various types of information, including the pages you visit, the emails you read and other information.
For example:
(i) We may know information about your device, such as its type.
(ii) We may know the type of browser and operating system you are using.
(iii) We may know which links and call-to-action buttons Users click on in emails sent by Doctr.
ii. User behavior
In addition to the automatic collection described above, we may also collect information using Cookies or similar technologies, when you visit our Platform. These methods enable us to collect different types of information, including the pages you visit, the emails you read and other information.
This information is also used to:
(i) Understand how you use the Services without following you in particular;
(ii) Identify the User;
(iii) Find out more about the User's preferences and purchasing habits;
(iv) Maintain a record of services that interest the user without specifically tracking you;
(v) Handle Users' requests and orders and answer their questions;
(vi) Understand how the Platform and Services are used by Users without specifically tracking you;
(vii) Develop new services and offers; and
(viii) Carry out market and performance studies to evaluate customer service, measure performance, improve the experience offered to the User and the products offered.
For example:
(i) When the User logs into their Account on the Platform;
(ii) Some demographic data about you may be collected via Google Analytics, Google Ads, Google Tag and Meta;
(iii) We may use your geographic location to determine whether we can offer you our Services;
(iv) We use the language of your web browser to determine the display language of the Platform when you visit it; and
(v) Subject to applicable laws, we may use the pages you visit on the Platform to show you personalized advertisements on the External Websites of our Third-Party Providers, where applicable.
8. HOW DO WE USE COOKIES?
We use technologies such as Cookies or pixels to perform various functions on our Platform.
Cookies are automatically stored on your electronic devices, allowing you to connect to the Platform later and enabling Doctr to personalize the Platform in order to provide you with the Services in the most appropriate manner.
The Cookies we use include, but are not limited to, the following:
(i) Cookies, which are small text files stored on your computer when you visit a website, so that certain information can be saved between visits, such as your access data or your choice of language. Cookies enable you to log in quickly when you visit our Platform; and
(ii) Pixels, which are small image files containing information about you, such as your IP address, that may be downloaded when you visit a website or open an email. This enables us to understand your online behavior, control the delivery of our emails and present you with personalized advertising. These tools also enable our Third-Party Provider tracking tools to collect information, such as your IP address, and transmit it to us as anonymous aggregate data (which prevents us from identifying you). The information compiled and presented as aggregated data is the result of a synthesis and does not include any personal identifiers.
We use Google Analytics, a service that uses Cookies, to analyze your use of our Platform, to generate reports on the activities of Platform Users and to offer other services related to the use of the Platform and the Internet. This information is not passed on to anyone else in a form that could identify you.
There are several types of Cookies, some of which expire when the User closes the browser and have no further effect, while others may be retained. The User may deactivate Cookies at any time. In this case, Doctr does not guarantee optimal operation of the Platform.
You can also prevent cookies from being saved by configuring your Internet browser. However, if you choose the latter option, you may not be able to take full advantage of the Platform.
9. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
We use your Personal Information to provide you with our Services, to manage our business, to communicate offers and information that may be of interest to you, to improve your overall experience as a Platform User and for other purposes permitted or required by law.
Specifically, we use your Personal Information for the following purposes:
a. To provide you with our Services
Information relating to the User is collected as part of the interaction that may be established between the User and the Platform for the provision of our Services, and more specifically for the following purposes:
(i) To create, use and manage User accounts on the Platform;
(ii) To verify the User's identity;
(iii) To establish and maintain a commercial relationship with the User;
(iv) To provide Services to the User;
(v) To secure the Platform ;
(vi) To develop, improve, market or provide the Platform and our products and services;
(vii) To enable appointments to be made with Third-Party Providers on behalf of the User;
(viii) To understand the User's use of the Platform; and
(ix) To improve the Platform, its functionalities and the Services.
In addition, Personal Information collected by Doctr herein is accessible only to authorized, necessary and competent Employees, as defined by Doctr.
I, THE USER, CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE DOCTR TO PROVIDE ITS SERVICES TO ME.
b. To manage our operations
We use your Personal Information for a number of purposes in connection with our business and operations, in particular to:
(i) Manage and/or improve the Platform and facilitate its use;
(ii) Manage relations with Users and any resulting commercial relations;
(iii) Maintain backups of our databases and keep records;
(iv) Allow you to participate in surveys or, if applicable, promotions, chats, seminars or workshops;
(v) Monitor and investigate incidents ;
(vi) Establish, exercise or defend legal claims, whether in a judicial proceeding or in an administrative or extrajudicial proceeding for the protection and vindication of our legal rights, your legal rights and the legal rights of others; and
(vii) Meet our legal and regulatory obligations under applicable privacy legislation.
I, THE USER, CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ALLOW DOCTR TO MANAGE ITS ACTIVITIES.
c. To enable us to communicate with you
We use your Personal Information to communicate with you in various ways:
(i) Send by email newsletters and bulletins;
(ii) Inform you in a variety of ways (for example, by email, telephone, text message or direct mail) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you; and
(iii) To provide the User with personalized advertisements on our Services, which we believe may be of interest to the User.
If you no longer wish to receive our commercial emails, please follow the unsubscribe procedure included in each email.
I, THE USER, CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ALLOW DOCTR TO CONTACT ME.
10. WHAT HAPPENS IF YOU DO NOT CONSENT TO THE COLLECTION OF YOUR PERSONAL INFORMATION?
You may, at any time, refuse the collection of your Personal Information.
Please note, however, that except for certain Cookies, which are not necessary for the provision of the Services, we will not be able to provide the Services offered without having access to your Personal Information.
You can refuse or personalize Cookies, at any time, via the cookie bar that appears on your screen when you access the Platform, if applicable.
11. WHO OUTSIDE DOCTR MAY HAVE ACCESS TO YOUR PERSONAL INFORMATION AND HOW DO WE SHARE IT?
Doctr staff and, with your written or oral consent and if necessary, our Third-Party Providers, may have access to your Personal Information.
We may share your Personal Information with our Third-Party Providers and other third parties - with your consent or where permitted by applicable law - for the purposes described in this Policy and in accordance with applicable privacy legislation and under Quebec's Act respecting the sharing of certain health information. We do not sell your Personal Information, except in connection with the sale or transfer of some or all of our business.
We do not disclose your Personal Information to persons or entities outside Doctr, except as described below:
a. Third-Party Providers whose intervention is necessary to provide you with the Services
We may disclose Personal Information to our Third-Party Providers. These Third-Party Providers help us provide our Services, conduct our business, operate our technology systems, applications and infrastructure, and implement our internal procedures and advertising and marketing strategy. For example, they provide us with data hosting, email deployment, marketing, sales and Personal Information processing or analysis services. We may also subcontract to third parties certain Services that we provide to our customers, including the User.
For example:
(i) We use the services of several companies, depending on the type of data to be stored, including, but not limited to, Amazon Web Services, to have servers and databases to ensure the operation of the Platform. This data is hosted in Canada or the United States.
(ii) We use verification services to ensure the identity of Users.
(iii) We use the IT services of several companies to ensure the operation and security of the Platform. The companies differ according to the data to be secured.
(iv) We use the services of the company Google, in particular Analytics, Google Ads, to have databases and to be able to improve the Platform. This data is hosted in the United States.
(v) We use a chat system developed directly on the Platform to offer you a service that allows you to chat live with a Doctr representative.
(vi) We use the services of Mailgun and Odoo, an email service provider, to send you our newsletter and share your email address with them for this purpose.
(vii) We use the services of Google Ads and Meta, suppliers accompanying us in our advertising campaigns, to improve the presentation of our services. To this end, we share your email address, telephone number and name with them.
(viii) We use the services of Third-Party Providers to ensure compliance with applicable laws and regulations.
(ix) We use the services of Stripe, an online payment platform, to facilitate payment for the Services.
The User may use third-party services in connection with certain Services. In no event will Doctr be liable for any damages arising from such third-party services. For information on the conditions of use of these services, we invite the User to consult their respective websites.
Any Third-Party Provider that receives or has access to information is required to protect such information and to use it only to perform the services they provide to the User or to Doctr, unless otherwise specified or permitted by law. We enter contracts with such third parties in which the obligations to protect the information disclosed to them are as protective as our commitment to you under this Policy or under applicable data protection laws.
BY USING DOCTR'S SERVICES, YOU CONSENT TO THE TRANSIT OF YOUR PERSONAL INFORMATION THROUGH THE SYSTEMS OF THIRD-PARTY PROVIDERS WHO ENABLE US TO PROVIDE OUR SERVICES.
b. Purchaser of Doctr in the event of a sale or transfer or in connection with certain other securities transactions
We may decide to sell or transfer all or part of our business or to a third party, merge with another entity, insure our assets, or proceed with any other financing or strategic corporate transaction (including insolvency or bankruptcy proceedings), restructuring, stock sale or other change of control of Doctr. In such a case, the information transferred as an asset of Doctr will be subject to the same safeguards as those in this Policy.
YOU CONSENT TO THE DISCLOSURE OF YOUR PERSONAL INFORMATION WHERE NECESSARY FOR THE PURPOSES OF SUCH TRANSACTION.
c. Other third parties, where required or permitted by applicable law
Applicable privacy legislation permits or requires the collection, use or disclosure of Personal Information without consent in limited circumstances (for example, to investigate or prevent suspected or actual illegal activity, including fraud, or to assist law enforcement or government agencies). These circumstances include specific situations authorized or required by law, as well as situations where it is necessary to do so to protect us or our Employees, Users or others. In such circumstances, we will disclose only as much Personal Information as is reasonably necessary to fulfill the purposes for which it is to be disclosed.
Please note that under Canadian federal and provincial laws applicable in the province of Quebec (for example, the Quebec Public Health Act), Doctr may be required to disclose your personal information to authorized persons.
For example:
(i) We may disclose information we hold to protect a person or group of people when there is reasonable cause to believe that there is a serious risk of death or serious physical harm to the person or group, such as a disappearance or an act of violence, including an attempted suicide, and the nature of the threat inspires a sense of urgency. The information may then be communicated to the person or persons exposed to this risk, to their representative or to any person likely to come to their help. Only the information necessary for the purposes of the communication will be communicated; and
(ii) We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for the prevention, detection or repression of crime or legal offences when such information is required for the purposes of a prosecution for an offence under a law applicable in Quebec.
Finally, we may communicate information to a police force when it is necessary for the planning or execution of an intervention adapted to the characteristics of a person or situation, in any of the following cases:
(i) the police force intervenes, at our request, to provide us with assistance or support as part of the services we provide to an individual; (ii) we act in coordination or partnership with the police force as part of mixed psychosocial and police intervention practices.
d. Other third parties, with your consent
Unless otherwise specified in this Policy, Personal Information provided by the User will not be transferred to third parties without the User's consent. We may, with your express or implied consent, and in compliance with applicable privacy legislation, communicate or disclose your Personal Information to persons or entities outside Doctr.
We do not allow third parties to collect your Personal Information on our Platform without your consent. Doctr prohibits and is not responsible for the resale or use by third parties of opt-ins obtained through the Platform. If you have agreed to share your contact details with partner organizations, we will share them with them. We do not sell or rent your Personal Information without your consent.
In addition, Doctr may also republish or re-share your feedback and first and last name when you post content related to Doctr on Social Media, Google reviews, the App Store, Google Play or any other platform where information is public. In addition, by clicking on an external link located on the Platform, you may access External Websites that have their own privacy policies. You are therefore advised to consult them, as you will be subject to them.
12. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We store your Personal Information in our offices, with our archiving service and on our computer servers. Unless otherwise required by applicable law, we retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected. The length of time may vary depending on the nature of the information and any ethical obligations.
The User's Personal Information will not be retained beyond the purposes for which it was collected. Doctr respects the retention period established by this Policy, which complies with applicable privacy and deontological legislation, where applicable.
Unless otherwise provided by law, the User may retrieve his or her information at any time prior to deletion of their Account. The deletion of Personal Information takes place when the User deletes their Account, except for Personal Information required to be retained under deontological obligations. The User will then have thirty (30) days to recover their data, failing which Doctr will permanently delete it. The deletion of certain data such as Quebec health insurance card, health status, reason for medical consultation and any photos that may have been provided are deleted by Doctr thirty (30) days after Doctr has made an appointment for the User. No request for access to Personal Information after thirty (30) days following the deletion by the User of his account on the Platform will be entertained by Doctr. The deletion of Personal Information must be the subject of an email or paper request addressed to the person responsible for the protection of personal information, in accordance with the contact details mentioned in article 2 of this Policy.
13. WHAT ARE THE RISKS INVOLVED IN PROCESSING YOUR PERSONAL INFORMATION?
Doctr undertakes to maintain a high level of security to ensure the confidentiality of the User's transactions to protect the User's Personal Information from unauthorized access, use or disclosure.
Given the risks inherent in the use of computer systems, however, we cannot ensure or warrant the security and confidentiality of any information you transmit or provide to us, and you do so at your own risk. If you have reason to believe that Personal Information has been compromised, please contact our Privacy Officer in accordance with this Policy. If a password is used to protect the User's Account and Personal Information, it is the User's responsibility to keep the password confidential.
Doctr undertakes not only to keep a register of confidentiality incidents but also to put in place internal practices to limit or prevent the consequences of a confidentiality incident involving Personal Information.
A confidentiality incident can be:
(i) Unauthorized access to Personal Information;
(ii) Unauthorized use of Personal Information;
(iii) Unauthorized disclosure of Personal Information; or
(iv) The loss of Personal Information or any other failure to protect such information.
In the event of a privacy incident involving personal information held by Doctr, Doctr will notify you and the “Commission d'accès à l'information du Québec” of any privacy incident that presents a risk of serious harm.
14. IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE QUEBEC?
Some of your Personal Information may be transferred outside Quebec. In this case, the servers of Third-Party Providers whose intervention is necessary to provide our Services are located in other Canadian provinces and territories and in the United States.
Prior to any transfer of your Personal Information outside Quebec, Doctr performs a privacy impact assessment specific to the proposed transfer. Doctr ensures that the safeguards in place are adequate to protect the Personal Information being transferred. More specifically, Doctr will not share your Personal Information with third parties located in jurisdictions that do not offer a similar level of protection for Personal Information as Quebec.
15. WILL YOU RECEIVE MARKETING EMAILS AND NEWSLETTERS FROM DOCTR?
Doctr will only contact you if you have given us your explicit consent to do so.
If the User has not subscribed to our newsletter, does not have a business relationship with Doctr or has never used one of our Services, the User will not receive any email from Doctr without their prior consent.
If you prefer not to receive promotional information from us or if you do not want us to use your Personal Information to enhance your User experience, please let us know by contacting us at the contact details set out in section 2 above.
Please remember to include your full name and the email address you used when registering or purchasing. The processing of an email or postal request may be delayed, and you may continue to receive communications from Doctr in the meantime.
Doctr complies with the requirements of the Canada’s anti-spam legislation (S.C. 2010, c. 23) (hereinafter the "CASL").
The User understands that they may expressly or tacitly consent to receive messages from Doctr.
“Express consent" is consent explicitly requested from the User, which must be stated in clear and simple terms and must include the purposes for which consent is requested, the prescribed information identifying the person requesting consent and, if requested on behalf of another person, the prescribed information identifying that person, as well as any other information specified by the regulations adopted under CASL.
The User hereby understands and accepts that they are giving "tacit consent" in the case of current business or private relationships, in particular when the User publishes their email address without mentioning that they do not wish to receive unsolicited commercial electronic messages, or when the message is sent in the other circumstances provided for by the regulations established under the present law.
For the purposes of this Policy and CASL, the following definitions apply:
(i) “Current business relationship”" is a business relationship established between at least two parties, such as a purchase or lease during the two years preceding the date on which the communication is sent, an investment offer, a barter, a contract in force or expired during this period, or a request made during the six months preceding the date on which the message is sent; and
(ii) "Current private relationship" is defined as a relationship between at least two parties other than a commercial relationship, such as a gift, donation, volunteer work or membership, as defined by the applicable regulations, during the two years preceding the date on which a communication is sent.
To unsubscribe from our electronic communications mailing list, simply contact our Privacy Officer at the coordinates indicated in section 2 of this Policy.
16. HOW CAN YOU CHANGE YOUR CHOICES CONCERNING THE PROTECTION OF YOUR PERSONAL INFORMATION?
You may always withdraw your consent to the use of your Personal Information for purposes other than those necessary to provide our Services, without affecting the Services you receive from Doctr.
For example, you can always choose not to receive marketing communications from Doctr.
You have several options to choose from:
a. Indicate your choices when registering, logging in or by contacting us directly at any time
You can always indicate your choice not to receive marketing messages from Doctr by email by clicking on the “Unsubscribe” hyperlink in any email you receive or via the settings in the mobile application.
Please note that even if you have indicated your choice not to receive marketing messages from us, we may still contact you regarding a Service in accordance with applicable law (for example, to send you a customer service message). In addition, please note that it may take up to thirty (30) business days to register a change of preference in all our files.
b. Change the browser settings on your device
We use technologies to enhance your user experience and present you with offers, including personalized advertising. Thanks to technologies such as Cookies, for example, our Platform recognizes you when you use it or return to it and can therefore offer you a seamless experience. You can remove or disable some of these technologies at any time using your browser and by customizing your options in the Cookies bar. However, if you do so, you may not be able to use some of the features of our Platform.
17. HOW DO WE PROTECT AND STORE YOUR PERSONAL INFORMATION?
The security of your information is important to Doctr and we are committed to protecting your privacy through a series of administrative, physical and technical safeguards. We retain the appointment list and user account until the User requests deletion of their data in accordance with the right to deletion set out in Article 18 g) of this Policy. With the exception of these two pieces of information, we retain your Personal Information only for as long as is necessary to provide you with our Services, to manage our business and to comply with our legal, regulatory and deontological obligations.
The Personal Information that Doctr collects is stored in a secure environment. Doctr has adopted appropriate measures to preserve the confidentiality of Personal Information and to protect it against loss or theft, as well as against unauthorized access, disclosure, copying, use or modification, taking into account, among other things, the sensitivity of the information and the purposes for which it is used. In addition, Doctr requires each Employee, agent or representative of Doctr to comply with this Policy.
a. Protective measures in place
To protect your Personal Information, we use administrative, technical and physical safeguards. Our goal is to prevent unauthorized access, loss, misuse, disclosure or alteration of the Personal Information in our possession. We ensure that access to your Personal Information is limited at all times to those Doctr employees and agents who are authorized by law to have access to it and whose involvement is necessary to provide the Service you wish to receive. We also apply these safeguards when disposing of or destroying your Personal Information.
Doctr is also committed to maintaining a high level of security to ensure the confidentiality of your transactions and to protect Personal Information from unauthorized access, use or disclosure.
For example, we use the following measures:
(i) SSL (Secure Sockets Layers) protocol;
(ii) Protected access to servers and computers;
(iii) Firewall;
(iv) Canadian server;
(v) Encryption/ Encryption of data at rest;
(vi) Use of password-protected data networks;
(vii) Internal privacy policies and confidentiality agreements with employees; and
(viii) Regular updating of safety measures.
Doctr undertakes to comply at all times with applicable privacy legislation in connection with its activities and to take all useful and necessary measures to detect and prevent negligence, fraud and theft of your Personal Information. However, although Doctr takes reasonable precautions, Doctr cannot guarantee that fraud or theft of your Personal Information will not occur.
b. Where we store your Personal Information
Doctr's Platform is hosted on several private servers and the servers of the hosts on which Doctr maintains its Platform are located in Canada or the United States, depending on the type of data.
Depending on the type of Personal Information, this is hosted on private servers located in Canada or the United States.
We take all reasonable security measures, which may include imposing contractual obligations on our Third-Party Providers, to protect your Personal Information wherever it is used or stored.
Unless we are legally required or contractually obliged to keep your Personal Information in Canada, it may be transferred outside Canada, as described in this Policy. For example, some of our Third-Party Providers may access, process or store your Personal Information outside your province or territory or outside Canada for the purposes of the services they provide to us. In such event, Personal Information is governed by the laws of the jurisdiction in which it is used or stored, including any laws permitting or requiring disclosure to governmental authorities or agencies, courts and law enforcement authorities in that jurisdiction. Doctr ensures that Third-Party Providers are in jurisdictions that provide a level of protection for Personal Information consistent with the laws applicable in Quebec.
c. How long we keep your Personal Information
We retain your Personal Information for as long as necessary to provide you with our Services, to manage our business and to comply with our legal, regulatory and deontological obligations. When we no longer need your Personal Information, we securely destroy it or make it anonymous (so that it can no longer be used to identify you).
We do not retain your Personal Information beyond thirty (30) days once you have deleted your Account on the Platform.
d. Destruction of your Personal Information
Personal Information is destroyed in accordance with the rules set out in applicable privacy legislation.
In certain circumstances, you have the right to obtain the deletion of your Personal Information as soon as possible. These circumstances are as follows:
(i) Personal Information is no longer required for the purposes for which it was collected or processed;
(ii) You withdraw your consent to processing based on consent;
(iii) You object to the processing under certain rules of the applicable privacy legislation;
(iv) The processing is carried out for direct marketing purposes; and
(v) Personal Information has been processed unlawfully.
However, there are exclusions to the right to deletion. General exclusions include cases where processing is necessary:
(i) For the exercise of the right to freedom of expression and information under applicable laws;
(ii) To comply with a legal obligation under applicable law; or
(iii) To establish, exercise or defend legal rights.
18. WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL INFORMATION?
You have the right to obtain confirmation as to whether or not we are processing your Personal Information and, when we do, to access the Personal Information in question, as well as certain additional information. This additional information includes details of the purposes of the processing, the categories of Personal Information concerned and the recipients of the Personal Information. Provided that the rights and freedoms of others are not affected in doing so, we will provide you with a copy of your Personal Information.
Applicable privacy legislation gives you various rights in relation to your Personal Information. To exercise any of these rights, please contact our Privacy Officer using the contact information provided in section 2 of this Policy. In addition, for more information on the protection of your Personal Information and your related rights, you may contact the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec.
- Privacy Commissioner of Canada: www.privcom.gc.ca
- Commission d'accès à l'information du Québec: www.cai.gouv.qc.ca
a. Right of access
This is the right to ask whether we hold Personal Information about you and, if so, to request access to that Personal Information. To the best of our ability, we will provide access to information in a timely manner. However, for security reasons, we may need to verify the identity of the requester.
b. Right to rectification
This is the right to request rectification of any incomplete or inaccurate Personal Information we hold. You may change your Personal Information by contacting our Privacy Officer at the contact details set out in section 2 of this Policy and on our Platform, at any time, by accessing your Account settings.
c. Right to withdraw of Consent
This is the right to withdraw your consent to the disclosure or use of Personal Information held by us, subject to applicable privacy legislation.
However, Doctr may no longer be able to provide you with certain Services if you withdraw your consent. Doctr will then explain the impact of this withdrawal to help you make your decision.
You may withdraw your consent to the collection and processing of your Personal Information by contacting our Privacy Officer at the contact details set out in section 2 of this Policy. Deleting your Account on the Platform is also a way in which you can withdraw your consent to the processing of your data.
d. Right to refusal of access
This is the right to request that a particular stakeholder or category of stakeholders not have access to one or more pieces of information that you have identified as Personal Information.
e. Right to lodge a complaint
This is the right to lodge a complaint in relation to this Policy with our Privacy Officer via the contact details set out in section 2 of this Policy, as well as the complaints procedure. If you are not satisfied with the way we have handled your Personal Information or if you believe that there has been a violation of applicable privacy legislation, you may file a complaint with the Commission de l'accès à l'information du Québec. To file a complaint, please use the appropriate form available on the Commission d'accès à l'information du Québec website.
f. Right to data portability
This is the right to request that your Personal Information be communicated to you or transferred to another entity in a structured and commonly used technological format.
g. Right to Erasure
This is the right to have your Personal Information deleted without undue delay in certain circumstances. These circumstances are as follows:
(i) Personal Information is no longer required for the purposes for which it was collected or processed;
(ii) You withdraw your consent to processing based on consent;
(iii) You object to the processing under certain rules of the applicable privacy legislation;
(iv) The processing is carried out for direct marketing purposes; and
(v) Personal Information has been processed unlawfully.
However, there are exclusions to the right to erasure. General exclusions include situations where processing is made necessary:
(i) For the exercise of the right to freedom of expression and information;
(ii) To comply with a legal obligation, including an deontological obligation; or
(iii) To establish, exercise or defend legal rights.
As mentioned in section 16 c) hereof, Doctr respects the retention period established by this Policy, which complies with applicable privacy legislation. Accordingly, and unless otherwise provided by the regulatory framework, the deletion of Personal Information will be effective thirty (30) days after the processing of the request for deletion of Personal Information by the Privacy Officer or Doctr will provide you with written notice that additional time is required to respond to your request.
In addition, deletion of Personal Information takes place when the User makes a request in writing to the email address referred to above in section 2 of the Policy. Doctr reserves the right to refuse the User's request if the User continues to use the Platform or Doctr's Services in a manner that does not comply with the retention period established by the Policy, which complies with applicable privacy legislation. Accordingly, and unless otherwise provided by law, the deletion of Personal Information will be effective thirty (30) days after the processing of the request for deletion of Personal Information by the Privacy Officer.
19. HOW CAN I ACCESS MY PERSONAL INFORMATION?
Applicable privacy legislation gives you the right to request access to and correction of the Personal Information we hold about you, subject to legal restrictions. Upon request, we will provide you with access to your Personal Information within thirty (30) days of receiving your request. Access to Personal Information is free of charge, but reasonable fees may be charged for transcription, reproduction or transmission of such information.
It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed of any changes to your Personal Information. It is your responsibility to provide accurate, truthful and complete information. If you notice any errors in your Personal Information or if you need to update it, please notify our Privacy Officer as indicated below.
Doctr, subject to certain exceptions, may inform you of your Personal Information, how it is used and whether it has been shared with Third-Party Providers. You will also have access to this information for any modification or deletion.
Your request to consult, verify, correct or withdraw your consent to the use of your Personal Information, or your request to access, correct or delete any Personal Information you have provided to us, must be made by contacting our Privacy Officer at the contact information indicated in section 2 of this Policy. Please be sure to include your full name and the email address you used when registering. Processing of an email or postal mail request may be delayed and you may continue to receive communications from Doctr in the interim.
Doctr will acknowledge receipt of your request in writing and may ask you to confirm your identity before providing you with this information. In principle, access to this information is free, but if you request a copy or transmission of your information, we may charge you a reasonable fee. Doctr will inform you of the amount in advance and give you the opportunity to withdraw your request. Doctr will provide you with access to your Personal Information within thirty (30) days of receipt of your request or will inform you in writing that additional time is required to respond to your request.
In some cases, we may not be able to provide you with access to all or part of your Personal Information. If we are unable to do so, or if the law does not authorize us to do so, we will provide you with an explanation and indicate the other measures available to you.
20. WHAT IF THE POLICY IS AVAILABLE IN SEVERAL LANGUAGES?
In the event of a problem of definition or interpretation between the French and English versions of the terms of this Policy, the French version shall prevail.
21. AMENDMENT OF THIS POLICY
We may change this Policy from time to time. Any changes to this Policy will be effective when we post the revised Policy on this web page. If we make material changes to the Policy, we will post a notice on our Platform or contact you by email to notify you, if required by law.
By continuing to use our Services and/or the Platform, the User agrees to this Privacy Policy as updated from time to time. If you do not agree to any changes to our Policy, you must stop using our Services and Platform. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The last update date indicated at the bottom of this Policy is the date of its entry into force.
However, in the event of application of the Consumer Protection Act (CQLR, c. P-40.1) (the “CPA”), Doctr will notify current Users of the Platform thirty (30) days prior to the effective date of the amendment. This notification will be made by sending an email, informing the User of the possibility of consulting the details of the amendments on the Doctr Platform. If the User refuses these modifications and wishes to terminate its relationship with Doctr, it will have thirty (30) days following the entry into force of the amendments to send a notification to Doctr and terminate, without cost or penalty, its obligations to Doctr, and will have to cease all use of the Platform.
22. APPLICABLE LAW AND COMPETENT COURTS
The Platform and its content, this Privacy Policy and your use thereof are all governed by the laws of Quebec and Canada applicable therein, without giving effect to any principles of conflict of laws.
You agree that all questions and disputes concerning the Platform and your use of it shall first be brought before a mediator and, in the absence of a compromise, decided by the competent judicial courts of the district of Montreal.
Notwithstanding any attribution of jurisdiction and applicable law, where the User is a consumer within the meaning of the CPA, then any dispute relating to this Policy shall be governed by the laws of the Province of Quebec, and shall necessarily be brought before a court of competent jurisdiction pursuant to the rules of the Code of Civil Procedure of Quebec.
23. WHO DO I CONTACT IF I HAVE QUESTIONS ABOUT THE PROTECTION OF MY PERSONAL INFORMATION?
If you have any questions about how we handle your Personal Information, we invite you to contact our Privacy Officer at the contact details set out in section 2 of this Policy.
Last updated on November 11, 2024.