PRIVACY POLICY OF DOCTR
INTRODUCTION
With the advent of new communication tools, it is necessary to be mindful of privacy. That is why we, a company duly incorporated under the name “Les technologies Wise Guys Inc.”, doing business under the name “Doctr”, with its head office located at 4388 Rue Saint-Denis Suite 200 #622 (H2J2L1), in the city of Montreal, in the province of Quebec, in Canada (hereinafter referred to as “Doctr”), are seriously concerned about your rights and the privacy of your personal information.
Doctr undertakes to comply, in accordance with applicable laws, the obligations regarding the collection and processing of personal and confidential information obtained through of the operation of a business so that everyone can enjoy privacy.
The privacy policy hereof (hereinafter the “Policy”) describes the information we may collect from user, who are understood to be the end user or organization you represent or for whom you work (hereinafter the “User” or “Users”) through our activities, the purpose for which we collect them, the use we make of them, and the circumstances under which we can pass them on to third parties. In addition, the Policy hereof indicates the User’s rights regarding the collection, use and disclosure of their personal information. Doctr undertakes not to collect, use or disclose the User’s personal information other than in accordance with this Policy and the applicable laws in Canada and Quebec.
SCOPE OF THE POLICY
When the User browses one of our mobile application and use our online services by visiting our website (Doctr’s mobile application and website, hereinafter the “Platform”) or by subscribing to our email publication, they accepts the terms and conditions of this Policy. If the User continues to use the Platform after a new version of this Policy has been posted there, they hereby consent to the chances and will be bound to them.
The personal information we collect is necessary when we provide a service to the User or when carry out a transaction they have requested. By providing us with this information, the User consents to it being collected and used in the manner defined in this Policy.
Please be aware that you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. However, without your consent, Doctr may no longer be able to provide you with the Platform.
Finally, if you provide Doctr or its third-party Providers with Personal information about another individual or entity, you agree that you have the necessary authorization to do so and/or that you have obtained all necessary consents from that third party to allow us to collect, use and disclose their Personal information for the purposes set forth in this Policy.
To withdraw your consent or to stop receiving electronic communications from us, please contact our Privacy Officer at legal@doctr.ca.
COLLECTION OF PERSONAL INFORMATION
Personal information is information that is specifically associated with an individual and can be used to identify that individual, either directly or indirectly, i.e., by combining it with other information held by Doctr or its Third-party providers.
Doctr may acquire personal information from the User when they save personal information on the Plateform or, if necessary, by otherwise transmitting personal information, including by creating a User account and choosing a password, logging in as a registered User, requesting a service, providing information in their account or contacting us through phone, email or otherwise.
It is important that the personal information we hold about you be accurate and up to date. Please keep us informed of any change of your personal data. The law grants you the right to request access to the personal data we hold about you and to correct it.
We collect the following Personal information from the User, who expressly consents, upon registration or when requesting our Services:
– Last and first names;
– Age;
– Gender;
– Phone number;
– Personal address;
– Email address;
– Location;
– Reason for the medical consultation;
– Health status;
– Medical service sought;
– How far the User is willing to travel fo the services;
– A picture of medical reference when the User requires to meet with a specialist; and
– Availabilities for an appointment.
The User expressly consents to us collecting the following Personal information from him/her on behalf of third party providers (hereinafter “Medical third party”), when required for the service for which he/she uses the Platform, i.e., when it is necessary for the performance of the appointment scheduling service by Doctr :
– The Régime d’Assurance Maladie du Québec (RAMQ)’s card number or an equivalent card number in other provinces in Canada;
The Platform is designed for use by adults only as understood in the province of Quebec. Doctr does not knowingly collect personal information from persons under the age of eighteen (18).
The legal basis for Doctr’s processing of the User’s data may be one or more of the following:
– The User’s consent;
– When necessary for Doctr to fulfill its legal obligations;
– When necessary for the implementation of an agreement between the User and Doctr, or before entering into said agreement upon the User’s request;
– When necessary to safeguard the User or a third party’s vital interests;
– When based on a legitimate interest, such as:
o To ensure the security of the Platform, its network or its data;
o To prevent fraud;
o For commercial prospection operations towards the User; or
o For internal administrative management purposes.
For more information on the protection of your personal information and related rights, you can contact the Office of the Privacy Commissioner of Canada or the Quebec Privacy Commission.
• Office of the Privacy Commissioner of Canada : https://www.priv.gc.ca/en/
• Commission d’accès à l’information : https://www.cai.gouv.qc.ca/english/
COLLECT PURPOSE
We collect personal information from the User for the following purposes:
– Creating, using and managing User accounts on our Platform ;
– To establish and maintain a business relationship with the User;
– To provide uninterrupted service;
– To understand the use of the Platform;
– To secure the Platform;
– Analyze and improve the user experience;
– Communicate with the User;
– Develop, improve, market or provide the Platform and our products and services;
– Send offers and promotions tailored to Users;
– To enable the booking of appointments with Third Parties on behalf of the User;
– To maintain backups of our databases and retain records;
– To establish, exercise or defend legal claims, whether in a court of law or in an administrative or extrajudicial proceeding for the protection and enforcement of our legal rights, your legal rights and the legal rights of others
– To comply with applicable laws and regulations.
COLLECTION OF PERSONAL INFORMATION
The User’s personal information can be collected through forms, such as:
– Directly to the User through forms and communications, namely :
– Platform registration form;
– Opinion surveys;
– Contact form;
– Appointment request on the Doctr application;
– Phone;
– Direct chat on Doctr;
– Facebook’s messenger; and
– Email communications.
– Through the use of cookies
Doctr also uses cookies, as detailed in the “Automatically Exchanged Data” section. Doctr may also keep a record of products of interest to the User and acquire information about the User from current or future divisions or companies that are part of Doctr.
If the User does not subscribe to our newsletter, he will not receive any e-mail from Doctr, except in specific cases (e.g., tracking or expiring his subscription, followed by his free trial, participation in a contest, etc.).
PROMOTIONAL INFORMATION
Doctr will only contact you if you wish it to. If you prefer not to receive advertising information from us or if you do not want us to use your personal information to enhance your experience as a User, please let us know by contacting contact in the “Right of Opposition and Withdrawal” section.
Do not forget to include your full name and email address you used when you registered or made a purchase with us. There may be a delay in processing time for a request sent by email or mail, and you may continue to receive communications from Doctr in the meantime.
THIRD PARTY SERVICES
Doctr will be able to use third-party services for the management of its business and Platform. In no way is Doctr liable for any harm that may have come from these third-party services. To find out the terms of use of these services, we invite the User to consult their respective websites.
Any third party that receives or has access to information is required to protect that information and to use it only to perform the services they are providing to the User or Doctr, unless otherwise specified or permitted by law. We will ensure that such third parties are aware of our obligations under this Policy. We enter into 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.
AUTOMATICALLY EXCHANGED DATA
We collect certain information when exchanging between the User’s device and our server. As files created by a website and automatically added in the User’s electronic devices for the purpose of collecting information about his browsing activities, cookies allow the User to connect to the Platform for further use and allow Doctr to customize the Platform. These are mainly the following information.
– Domain name;
– IP Address;
– User language ;
– Analytics and performances – User’s behaviour; and
– Advertisement/redirection.
Most of the information transmitted automatically does not allow us to know the identity of the User. They are only collected because of the technological requirements inherent in Internet browsing. Most browsers automatically accept cookies, but it is usually possible to change this behaviour. However, if the User chooses to refuse cookies, he may not be able to identify himself or use certain functions of the Platform.
The use of such information allows us to improve the service, personalize the User experience and better track a request or order.
This information is also used to:
– Identify the User;
– To process the User’s requests and orders and answer their questions;
– Keep in touch with the User and provide him/her with a personalized Service at any time;
– To learn more about User preferences;
– To conduct market and performance research to evaluate the service to Users, measure performance, improve the experience provided to Users and improve products;
– To improve the User experience by analyzing User behavior; and
– To use Google Analytics, Google Ads and Amplitude.
These cookies are multiple, some expire when the User closes his browser and no longer have any effect while others can be retained. At any time, the User may deactivate cookies. In that case, however, Doctr does not guarantee the optimal performance of the Platform.
SHARING OF PERSONAL INFORMATION
Doctr places particular importance on the sharing of personal information. Situations where Personal Information may be shared include sharing with Third Parties and company partners, sharing with advertisers and/or advertisers, promotional offers, sharing with third party applications, websites or integrations on or using our products and law enforcement or legal requests. User’s Personal Information may be shared by Doctr to clinics and appointment scheduling platforms in order to schedule a medical appointment for User.
The categories of persons to whom User information may be transferred are as follows:
– Medical third-party to enable us to provide our services or meet your needs;
– Payment providers, to process User payments;
– Verification service providers, to verify the identity of Users;
– IT service providers, to ensure the operation and security of the Platform;
– Analytics service providers, to improve the Platform;
– Service providers to ensure compliance with applicable laws and regulations
– Business partners to organize advertising campaigns, contests, special offers or other events or activities related to Doctr or the Platform;
– Credit reporting agencies and fraud prevention agencies, including, without limitation, Equifax and its affiliates;
– Partners, government agencies and regulatory authorities, judicial bodies, partners, agents, attorneys or other representatives for the purpose of complying with legal obligations to which we are subject or for the purpose of establishing, exercising or defending legal rights, whether in a judicial proceeding or in an administrative or extrajudicial proceeding;
– To any other person as permitted and/or required by law.
The User understands that Doctr may at any time share his/her personal information in the event of a partial or total transfer of its business to a third party. In such a case, the information transferred as an asset of Doctr will be subject to the same safeguards as those in this Policy.
If the User does not want his or her personal information to be shared with third parties or partners, he or she may object at any time, as mentioned in the following section.
Doctr may, in the following cases, exceptionally communicate the User’s personal information without his/her consent:
– In the event of a legal obligation, including when a court order requires Doctr to disclose the User’s Personal Information; or
– When it is impossible to obtain the User’s consent and applicable privacy laws permit Doctr to disclose such Personal Information. This is particularly the case when the protection of the public interest so requires.
CONSERVATION
The User’s personal information will not be preserved beyond the reasons for its collection. Doctr abides by the conservation period provided by the Policy hereof, which is in accordance with Canada’s Privacy Act. Data deletion occurs when the User deletes their account. The User will then have thirty (30) days to recover his data, otherwise Doctr will delete it permanently. The deletion of certain data such as the The Régime d’Assurance Maladie du Québec (RAMQ)’s card number, the reason of the medical consultation and all the provided pictures shall be deleted by Doctr seven (7) days after the appointment is set up by Doctr for the User.
COMMUNICATIONS
The User’s data passes through servers located in Canada.
In some situations, user data may pass through servers outside of Canada. In that case, the servers in question are located in the following country: United States.
The User recognizes this and absolves Doctr of any responsibility for the consequences of such a transfer.
ACCESS, WITHDRAWAL AND OPPOSITION RIGHT
We are committed to offering the User a right to access, object and withdraw their personal information.
Doctr may, upon request and subject to certain exceptions, inform you of your personal information, how it is used and whether it has been disclosed to third parties. You may also have access to this information for any modification or deletion.
The right of objection is defined as the opportunity for Users to refuse to have their personal information used for certain purposes mentioned at the time of collection.
The right to withdraw is defined as the ability for Users to request that their personal information no longer appear, for example, in a mailing list.
The User is also entitled to request access to the personal information we have collected about him and to correct it as necessary by contacting the contact person, whose contact information will be found in the “Contact person” section below.
PROCEDURE FOR REQUESTS
To exercise your rights, you should write to Doctr’s Privacy Officer at legal@doctr.ca
Doctr will acknowledge your request in writing and may ask you to confirm your identity before providing you with this information. Access to this information will normally be provided free of charge, but if you request a copy or transmission of your information, we may charge a reasonable fee. Doctr will inform you of the amount in advance and give you the opportunity to withdraw your request.
If your request is complete and you substantiate your right of access, Doctr will provide you with access to your information within thirty (30) days of receipt of your request or provide you with written notice that additional time is required to fulfill your request.
PROTECTION AGAINST FRAUD AND THEFT OF YOUR PERSONAL INFORMATION
Doctr undertakes at all times to comply with the laws and regulations applicable to its business and to take all useful and necessary measures to detect and prevent negligence, fraud and theft of your personal information. However, although Doctr takes precautions, it cannot guarantee that no case of fraud or theft of your personal information will occur.
Doctr maintains a confidentiality incident log and will contact any User whose personal information is the subject of such an incident and presents a risk of serious harm.
ANTI-SPAM LEGISLATION
Doctr complies with the requirements of the Canadian Anti-Spam Act (CASL). The User understands that he may explicitly or tacitly consent to receive messages from Doctr.
The explicit consent is the consent asked to the User, which must be expressed in simple and clear terms, and must include the purposes for which the consent is sought, the regulatory information necessary to identify the person seeking for the consent and, if sought on behalf of another person, the regulatory information necessary to identify this person; as well as any other information specified by the regulations enabled by this law.
The User understands that they give their tacit consent through ongoing business or personal relations; when the User publishes his email address without stating that they do not wish to receive unsolicited commercial emails; or when the message is sent in other circumstances provided by the regulations enabled by this law.
a) For the purpose of this Policy, ongoing business relations refer to commercial relations set out between two persons such as a purchase or lease in the two years prior to the date of the message; an investment; bartering of an object; any contract that came in effect or expired during that time; or a request made in the six months prior to the date of the message.
b) For the purpose of this Policy, ongoing personal relations refer to relations set out between two persons other than business relations, such as a donation or a gift, a work executed as volunteer; and a subscription, within the meaning of the regulations; any of them occurring within the two years prior the date of the message.
To opt out of our email mailing list, just contact us legal@doctr.ca .
SECURITY
The personal information Doctr collects is stored in a secured environment. Doctr has taken appropriate measures to preserve the confidentiality of personal information and to protect it from loss or theft, as well as unauthorized access, communication, reproduction, use or modification, taking into account, in particular, their sensitivity and the purposes for which they are employed. In addition, Doctr requires that each Doctr employee, agent or representative comply with this Policy.
To ensure the security of the User’s personal information, Doctr employs, among other things, the following measures:
– SSL (Secure Sockets Layers) protocol
– Protected access to servers and computers;
– Firewall;
– Password-protected usage of data networks;
– Non-disclosure agreements with employees;
– Canadian server;
– Data encryption at rest; and
– Business Associate Agreement signed by Amazon AWS (HIPAA).
Doctr is thus committed to maintaining a high level of security by integrating the latest technological innovations to ensure the confidentiality of the User’s transactions in order to ensure the protection of his personal data and avoid they should not be accessed, used or disclosed without authorization.
However, as no mechanism provides maximum security, there is always a risk when using the Internet to communicate personal information. If a password is used to protect the User’s account and personal information, it is his responsibility to keep it confidential.
FRENCH AND ENGLISH LANGUAGE / LANGUE FRANÇAISE ET ANGLAISE
If the Policy is available in more than one language and a problem with its definition or interpretation occurs between the French version and any other version of the Policy, the French version shall prevail. / Si la Politique est disponible en plus d’une langue et qu’un problème de définition ou d’interprétation survient entre la version française et toute autre version de la Politique, la version française prévaudra.
APPLICABLE LAW AND COMPETENT VENUE
The Platform and its content are managed by Doctr from its offices in the province of Quebec in Canada. The Platform and its content, these Terms of Use and your use of it are all governed by the applicable laws of Quebec and Canada, without giving effect to any principle relating to the conflict of laws.
You accept that all questions and disputes relating to the Platform and your use of it will first be brought in front of a mediator and, in the absence of a compromise, decided by the courts of Montreal.
Notwithstanding any jurisdiction or law that may apply, if the User is considered a consumer under the Consumer Protection Act, any litigation relating to the Policy hereof shall be subject to the laws of the Province of Quebec, and shall necessarily be submitted to the relevant jurisdiction in accordance with the rules provided by Quebec’s Code of civil procedure.
INTERPRETATION
The Policy hereof is governed by applicable Quebec and Canadian laws, including Canada’s Privacy Act. These laws apply without giving effect to any conflict of law principles.
Whenever the context so requires, any word written in the singular also includes the plural and vice versa; any word written in the masculine gender also includes the feminine gender and vice versa.
SEVERABILITY
Each provision of the Policy hereof is a separate and distinct whole so that any court decision declaring the nullity or unenforceability of one of the clauses of the Agreement shall not affect the validity or enforceability of the other provisions of the Policy hereof.
PRIVACY OFFICER
You can exercise the rights under this Policy or direct any other questions or complaints about Doctr’s privacy practices to us by contacting us via the following address:
By mail at:
Doctr – Responsible Person of Privacy Protection
4388 Rue Saint-Denis Suite 200 #622, Montreal,
Québec, Canada
By email at: legal@doctr.ca
We have put in place processes to receive and respond to complaints or information requests regarding our personal data processing, our compliance with this Policy and with applicable privacy protection laws. To discuss about our compliance with this Policy, please contact our Responsible Person for Privacy Protection by using the contact information mentioned above.
AMENDMENT TO THIS POLICY
We occasionally update this Policy. The continued use of the Platform is the User’s agreement with regard to this privacy Policy and its updates. If we make major changes to the way we process our users’ personal data, we shall inform you by email with the address you indicated in your account or by notice on our Platform’s homepage.
However, when the Consumer Protection Act applies, Doctr shall notice the Plateform’s Users thirty (30) days before the entry into effect of the Policy’s amendment. If the User refuses these amendments and wishes to terminate the contract, he shall have at most thirty (30) days following the entry into effect of the amendments to communicate a notice to Doctr and rescind, without fees or penalties, their obligations towards Doctr.
Last updated on February 4th 2023.