Centas Med Inc. (“Centas”, “we”, “us”, “our”) greatly values privacy. That is why Centas has implemented this personal information privacy policy (“Policy”) with the purpose of providing a framework as to how Centas is to handle Personal information.

This Policy, which should be read in conjunction with our
Terms of Use
describes our practices regarding privacy and the protection of Personal information, including how we handle, collect, use and disclose your Personal information (defined below).

By visiting or using www.CentasMed.com (the “Website”) or using any of our Services (as defined below), you agree that we can process, collect, use, transfer, disclose and retain your Personal information in accordance with the terms of this Policy. If you do not agree to abide by and be bound by the Policy, you may not visit, access or use the Website or the Services or share your Personal information with us.

This Policy does not apply to the Personal information of Centas employees, representatives and consultants, or to any other person affiliated with Centas, as well as to any information that does not constitute Personal information as defined by law.

1. DEFINITIONS

The following words and expressions, when appearing with a capital letter in the Policy, bear the meaning attributed to them hereinafter, unless implicitly or explicitly stated otherwise in the text:

“Personal information” means any information that relates to a physical person and allows that person to be identified, as defined by the Loi sur la protection des renseignements personnels dans le secteur privé (Quebec – Act to protect personal information in the private sector) or by any other equivalent legislation in other jurisdictions Generally speaking, information relates to a physical person and allows that person to be identified when it reveals, directly or indirectly, something about the identity, characteristics (for example, the abilities, preferences, psychological tendencies, predispositions, mental abilities, character and behaviour of the person in question) or activities of that person, regardless of the nature of the medium or the form in which the information is accessible (written, graphic, audio, visual, computerized or other).

“Privacy officer” means the person who is responsible for implementing this Policy and whose contact information is set out in section 2 of the Policy.

“Services” refers to the Website and its functionality as well as all related services offered online or in person by Centas, including but not limited to our newsletter, e-consult services, customer service, documentation made available to you and services provided when you visit one of our clinics to obtain care and services.

2. PRIVACY OFFICER

Questions relating to the Policy and Centas’s procedures in terms of privacy may be addressed to our Privacy officer at the following addresses and phone number:

By phone: 

By email: privacy@centasmed.com (addressed to the Privacy officer)

By mail: 6600 Blvd. Decarie, Suite 210 Montreal, Quebec H3X2K4

3. CHANGE IN POLICY

We reserve the right to update and modify this Policy at any time in accordance with the applicable law. In the event of a change, we will post the revised version of the Privacy Policy and update the last update date at the top of this page. We encourage you to review our Privacy Policy when you visit the Website to stay informed as to how we handle Personal information. If you do not agree with the updated terms of the Privacy Policy, we encourage you to stop using our Website and Services. Your continued use of our Website or Services following the posting of any changes to the Policy constitutes acceptance of those changes.

4. PROCESSING OF PERSONAL INFORMATION

4.1. Collection of Personal information

As part of our activities, we may handle different types of Personal information, including the information listed below:

  • contact information, such as your first and last name, postal address, e-mail address, telephone number, date of birth;
  • information relating to your customer account on the Website, such as your user name, password, age, gender, preferred language(s), city of residence, health insurance number and photo of your health insurance card, preferred language and the name and address of your local pharmacy;
  • information about products or services, such as your appointments and information about the Services we have provided to you;
  • information relating to transactions and payment, such as the method of payment used, the date and time, the payment amount, the billing postal code, your address and other related information;
  • information you choose to provide or share with us, for example, when you fill out a form, complete surveys or contact one of our employees or representatives, as well as your preferences and interests;
  • information collected automatically when you use the Website and our Services, including:
    • login information and other information about your activities on the Website, such as your IP address, the pages you visit, the time and date of your visits, the type of browser you use, the operating system of your device and other hardware and software information;
    • geolocation data, such as your IP address, a precise or approximate location based on your IP address or the GPS of your mobile device (depending on your device and browser settings);

In each case, such Personal information is processed in accordance with the legitimate and necessary purposes listed in Article 3.2 below.

4.2. Use of Personal information

We may use your Personal information for the legitimate purposes described below:

  • to operate, administer, maintain, monitor, develop, improve and provide all the features of our Website, including e-consult appointments;
  • to provide you with Services and to ensure the proper functioning of the Website;
  • to improve our Services and develop new Services and Website features;
  • to send you messages, updates, security alerts and account notifications for marketing and business development purposes, if you have previously consented to the processing of your Personal information for such purposes;
  • to answer your questions and provide you with assistance when necessary;
  • to manage a waiting list, an appointment, a membership, a survey or other functionality of the Website or our Services;
  • to collect notices, comments, questions, requests and complaints regarding our Services and Website;
  • to perform research and analysis relating to our business and Services;
  • to detect and prevent fraud, error, spam, abuse, security incidents and other harmful activities;
  • to send you communications as required by law;
  • to reorganize or change the structure of our business;
  • for any other purpose permitted or required by law.

Please note that we do not use the information we collect to draw any inferences or interpretations.

4.3. Communication of Personal information

We may communicate your Personal information to our employees, contractors, consultants, agents, service providers and other trusted third parties (collectively, “Service providers”), who require such information to assist us in operating our Website, conducting and protecting our business, or serving you, provided that such Service providers have previously agreed in writing to protect the confidentiality of your Personal information in accordance with applicable laws and our information governance program. We do not sell, trade or otherwise disclose your Personal information to third parties, subject to exceptions provided by law or unless we have obtained your prior consent.

4.3.1. Service providers and other third parties

Although we try to avoid disclosing your Personal information to third parties, some products and services offered through Centas may be provided or performed by service providers on our behalf. In order to provide you with the products or services you seek, we may need to communicate or transfer information about you to these third parties in various situations. We have set out below the circumstances in which sharing information may take place:

  • Google Analytics – We use Google Analytics to analyze the audience and traffic of the Website. See their
    privacy policy
    ;

We establish written contracts with our Service providers before disclosing your Personal information to them and we only provide them with the Personal information they need to perform their duties. As part of these contracts with our Service providers, we are committed to ensuring that the principles set out in this Policy are observed, and these Service providers are required to use Personal information as directed by us and only for the purposes for which it was provided. In addition, these Service providers provide us with sufficient assurances that they will implement appropriate security measures that are consistent with the sensitivity of the Personal information being processed or communicated. When our Service providers no longer require your Personal information, we require them to destroy this data in an appropriate manner.

4.3.2. Compliance with legislation, responding to legal requests, preventing harm and protecting our rights

We may disclose your Personal information when we believe that such disclosure is permitted, necessary or appropriate, including:

  • to comply with requests from public and government authorities, including public and government authorities outside your country of residence;
  • to protect our business;
  • to comply with legal proceedings;
  • to protect our rights, privacy, safety, property, or those of our affiliates, yours, or those of third parties;
  • to allow us to enforce available recourses or limit the damages we may suffer; and
  • to comply with applicable laws, including laws outside your country of residence.

4.3.3. Commercial transactions

We may share, transfer or communicate, strictly in accordance with this Policy, your Personal information in the event of the sale, transfer or assignment, in whole or in part, of Centas or our assets (for example, as a result of a merger, consolidation, change in control, reorganization, bankruptcy, liquidation or any other business transaction, including as part of the negotiation of such transactions). In such cases, we will notify you before your Personal information is transferred and is governed by a different privacy policy.

4.4. Consent

We will only use your Personal information for the purposes for which it was collected in accordance with this Policy. We will seek your consent before using your Personal information for purposes other than those set out herein, subject to exceptions provided by the law, including when the new proposed use is consistent with the purpose for which the Personal information was originally collected.

Whenever possible, Centas obtains consent directly from the individual in question for us to collect, use and communicate their Personal information. However, if you provide us with Personal information about other individuals, you must ensure that you have duly notified them that you are providing us with their information in addition to having obtained their consent to such disclosure.

4.5. Retention of Personal information

We retain your Personal information only for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. If you would like more information about the periods during which your Personal information will be retained, please contact our Privacy officer.

In addition, any medical clinic doing business with Centas remains responsible for keeping, in accordance with applicable laws and regulations, all elements required in the electronic medical record of its users/patients, notwithstanding this Policy. Centas will keep user/patient data for as long as the clinic so requires. Upon written request from any clinic doing business with Centas, Centas agrees to delete the data of any medical clinic making such a request and/or of its users/patients.

5. YOUR RIGHTS

As a person subject to this Policy, you may exercise the rights set out below by sending a written request by e-mail or by mail to the attention of our Privacy officer at the contact information provided in section 2 of the Policy:

  • You have the right to be informed of the Personal information we have collected about you, and information about the purposes for which we have used and are using your Personal information;
  • You have the right to request a paper copy of the documents containing your Personal information, subject to the exceptions provided by applicable law;
  • You have the right to have the Personal information we have about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
  • You have the right to request the deletion of your Personal information if the collecting of such information is not permitted by law;
  • You have the right at any time to withdraw or change your consent to our processing of your Personal information, subject to applicable legal and contractual restrictions. In some instances, withdrawing your consent may result in Centas