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Latest version March 19, 2024

Table of Contents


Latest version March 19, 2024

Quatuor M.D. Inc. (“Quatuor”) is committed to protecting the privacy of your Personal Information, defined as any information that pertains to a natural person and allows them to be identified directly or indirectly (“Personal Information”). This might include, for example, a name, a mailing address, a phone number, a bank account number, or information about your personal health. Please read this privacy policy carefully as it explains how we collect, use, process, and disclose your Personal Information (“the Policy”).

This Policy applies to any Personal Information we may collect from you when you: (i) use the Quatuor MD online client portal app (“the Portal”), (ii) visit and receive care at a Quatuor MD health facility or through our virtual care services, (iii) apply for a job at Quatuor MD, (iv) visit our website where this Policy is posted (“the Websites”), or (v) interact with us in any other way.

1 COLLECTION AND USE OF PERSONAL INFORMATION Quatuor MD collects only the Personal Information necessary for the purposes of its activities. We use and disclose your Personal Information for the purposes to which you have consented or as permitted by law. The purposes for which Quatuor MD collects your Personal Information are specified at the time of collection, for example, when you open a client account with us. You will also be informed of these purposes upon request. We may collect your Personal Information for the purposes described below.

Healthcare and wellness services: We collect your Personal Information to enable Quatuor MD healthcare providers to deliver health services when you visit our clinic, receive virtual care services, use our Portal, or engage with us in other ways. This information is stored in your electronic medical record and is accessible only to Quatuor MD staff members who need access in the course of their duties, as well as to care providers, agents, and subcontractors in our clinics and through virtual care technologies as part of performing their services in line with the purposes described in this Policy. We also collect Personal Information to provide you with wellness services. Information we collect to provide you with wellness services is not stored in your electronic medical record.

While the nature of the health Personal Information you provide is specific to you and your healthcare needs, we generally collect information such as your name, gender, date of birth, general health concerns, your personal and family medical history (including information about any treatment, diagnosis, or prescription), information about appointments with doctors and medical referents, healthcare documents (including reports and imaging results), your health insurance card number, and other relevant health information to determine if you are eligible to receive healthcare services, to plan them, and to provide them to you.

Virtual care services: Healthcare providers at Quatuor MD offer virtual care services to provide non-urgent healthcare remotely via real-time audio or video technology. If you choose to use our virtual care services, Quatuor MD may ask you to verify your identity, for example by showing your government-issued photo ID to the care provider at the beginning of your virtual care session. Virtual care sessions are not recorded.

Quatuor MD app: As a Quatuor MD client, you will create an online account to access and use the Portal to communicate with us, access test results, and use our virtual care services. To create and administer your account and authenticate you, we will collect your full name, email address, date of birth, and a password that you create. We also collect your health insurance card number to provide you with provincially funded health resources and to accurately identify and link your personal health information records. You may also choose to add information to your account profile, such as your gender, address, preferred phone number, emergency contact details, marital status, employment status, the name of your workplace, your role, which help us understand your needs and tailor our products, services, and pricing to your needs. The information in your account profile on the Portal can be automatically updated to reflect the information you provide to Quatuor MD when you book a service or visit our clinic. You are required to keep your username and password secure and not share them with anyone else. We will never ask for your password in an unsolicited communication (letters, phone calls, or emails).

Appointment scheduling: We collect Personal Information when you schedule an appointment with a healthcare provider. This information may include the type of visit you desire (i.e., in-person, virtual, or by phone), your name, the reason for scheduling the appointment, your medical history, and your emergency contact details. We use this information to schedule your appointment and provide the healthcare provider with the information they need to deliver healthcare services to you. For certain products and services, we will ask for a credit card number at the time of booking, as described below.

Payment: If you purchase a product, service, or membership from Quatuor MD, we will collect your full name, payment information (including billing address, credit card number, expiration data, and CVV code) to process the transaction and enable Quatuor MD healthcare providers to provide you with the healthcare services you have purchased.

Marketing communications: Providing health information and educational material is a key feature of Quatuor MD’s service offering. When you become a member of Quatuor MD (or if we have your consent), we collect and use your full name, email address, and/or mobile phone number to send you information about resources, services, offers, events, and promotions from Quatuor MD that may be tailored to your interests and interactions with Quatuor MD.

You can unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of each email or by adjusting your preferences via the account profile on the Portal. You can also choose to no longer receive marketing communications by email by contacting us using the contact details provided in the “Contact Us” section below. Please note that you may continue to receive transactional, informational, or account-related communications even if you unsubscribe from marketing communications.

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. We may use the information obtained from our surveys, which may include Personal Information about health, to review and identify opportunities for improving our delivery of healthcare and wellness services to our clients and as explained to you at the time of the survey. Participation in our surveys is optional, and consent is requested at the time of your participation.

Research and analysis: Quatuor MD may participate in medical research projects using Personal Information about health collected previously or prospectively with the aim of improving the healthcare and wellness services offered by Quatuor MD and advancing medical knowledge, subject to the following conditions.

Quatuor MD will not use or disclose your Personal Information about health in the context of these research projects in a manner that allows you to be identified directly or indirectly without first obtaining your consent or in a manner consistent with applicable law, such as with the approval of a research ethics committee.

Quatuor MD may generate depersonalized information and disclose it to third parties who are part of the research project and are required to use the data for the purposes of the study, in compliance with applicable legal requirements.

Depersonalized information is information from which identifiers and other information have been removed so that it is not reasonably foreseeable that the information could be used, alone or in combination with other information, to directly identify an individual. Depersonalized information will only be disclosed to the third party in compliance with legal requirements, including implementing appropriate measures to protect the privacy of the individuals concerned.

Quatuor MD may also generate and analyze depersonalized data to create comparative statistical reports between customer groups or sectors to better understand health trends and improve operations, products, and services of Quatuor MD. These benchmarking reports may be shared with third parties (such as Quatuor MD’s business customers) to provide insight into customer and business populations on an aggregate basis.

Careers: If you use our Website to apply for a job at Quatuor MD, you may provide us with certain Personal Information about you, such as the information contained in a resume, cover letter, or other job-related documents. We use this information for the purpose of processing and responding to your application or for future reference purposes (to inform you about the opening of other positions at Quatuor MD).

Clinic visits: We may conduct video recordings for security purposes using cameras located in public areas of our clinic, such as the reception and clinic entrance and exit areas. In areas of our clinic where we conduct video recordings, we will post signs to inform you of this.

Telephone calls: Quatuor MD may record telephone calls for quality control purposes. You will be informed in advance and will have the option to refuse this recording. Quatuor MD retains recordings only for the duration required to achieve quality control purposes.

Contacting us: You can contact Quatuor MD, including by phone, email, or through the Portal. When you contact us to share a comment, question, or concern, you may provide information that identifies you, such as your name, email address, and phone number, as well as additional information we need to help us respond promptly to your question or comment. We may retain this information to assist you in the future.

2 CIRCUMSTANCES OF PERSONAL INFORMATION COLLECTION Directly from you: Most of the Personal Information we collect is provided by you directly, including when you:

From third parties: Quatuor may also collect your Personal Information from third parties with your consent or if the law allows it to collect them in this way. For example, we may collect relevant Personal Information about your health from your other healthcare providers to enable healthcare providers at Quatuor MD to provide you with healthcare services.

Through our Websites and online services: Visits to our Websites and online services: Quatuor MD may also collect Personal Information when you visit our Websites or connect to our online services (when you access and use the Portal, for example).

Subject to applicable requirements regarding consent to collection through a service or technological solution, the IP address used by your device to connect is automatically collected when you access the Websites of Quatuor MD. Other related information such as the requested pages, the type of browser, the operating system, and the average time spent on our Websites is also collected. We use this information to help us understand our Website activity and to monitor and improve our Websites.

Cookies: Quatuor and some of its advertising network partners may also collect other information regarding the use of its Website, and this is done through the use of commonly called “cookies.” These files allow, among other things, to recognize the user of our site when they access it and as they move from one page to another. Quatuor MD and, where applicable, its advertising network partners, use these cookies to identify individuals who show particular interest in certain pages of its Websites and this, for the purpose of targeted advertising. This allows it to display specific advertisements, including in the form of banners, on other Websites visited by you.

Except for cookies that are essential to the proper functioning of our site, you can, at any time, accept or refuse (this could deprive you of certain features offered on our site) the use of these connection cookies through completion.

Tracking tags and invisible pixels: The Websites may also use technology called “trackers” or “web beacons.” This technology allows us to understand which pages you visit on the Websites. These trackers are used to help us optimize and tailor the Websites for you and future visitors to the Websites.

3 SHARING OF PERSONAL INFORMATION We do not disclose your Personal Information to third parties without your consent, except to partners or service providers in the context of performing service contracts in the cases described below or to public authorities when applicable law requires or allows it.

Other healthcare providers: We may share your Personal Information with other healthcare providers and facilities (for example, another doctor or healthcare practitioner, a paramedical professional or a member of your clinical care team, a public hospital, a pharmacy, a laboratory, or an ambulance service) for the purpose of ensuring the continuity of your care. We may also share your Personal Information if it proves necessary to contact your family or a potential special proxy.

Employers and other third parties: When Quatuor MD services are made available to you by your employer as part of your benefits plan, we may share anonymized information about the use of Quatuor MD services with your employer. We may also share limited Personal Information with your employer for billing and invoice reconciliation purposes. Quatuor MD may create and share reports containing anonymized information with other third parties, such as benchmarking reports or other comparative reports.

Benefit providers: We may disclose certain Personal Information to your benefit provider to coordinate payment, including your name, the date of service, and the service provided. We may also share certain Personal Information with Quebec’s health insurance plan for billing state-funded services.

Referrals to affiliated clinics: When Quatuor MD services are offered to you as part of a social benefit by your employer, but there is no Quatuor MD clinic in your area, we may direct you to an affiliated clinic that has entered into a partnership with us and disclose certain Personal Information about you, such as your employer, your full name, your gender, your address, your phone number, and your email address, to this affiliated clinic. We may also disclose this information to ensure the continuity of your care and to enable you to access and use healthcare services offered by clinics other than Quatuor MD in locations outside Quebec.

Service providers: Your Personal Information may be transferred (or otherwise made available) to third parties who provide services to us or on our behalf. We use third parties to provide services such as laboratory tests, virtual care technology, printing, mail distribution, cloud storage services, payment card processing, and recruitment. Our service providers only receive the information they need to fulfill the functions assigned to them. They are not allowed to use or disclose Personal Information for commercial purposes or for any other purposes that are not part of the performance of the service contract that binds us to them.

Research partners: As described above, Quatuor MD may participate in medical research projects from time to time, including with third-party partners. Quatuor MD may generate depersonalized information and disclose it to third parties who are part of the research project and who are required to use the data for the purposes of the study, in compliance with applicable legal requirements.

Compliance with the law and compliance: We and our Canadian, American, and foreign service providers may disclose your Personal Information in response to a search warrant or other legally valid request or order, or to another organization for the purpose of investigating a breach of an agreement or an offense against the law or to detect, suppress or prevent fraud, or otherwise as required or authorized by Canadian, American, or other law or by a judicial process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed if it proves necessary for the establishment, exercise, or defense of legal claims and to investigate actual or suspected losses or damage to persons or property, or to prevent them.

Sale of the business: We may transfer the information we hold about our customers as an asset in the context of a merger, acquisition, or proposed or completed sale (including transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of Quatuor MD.

4 CONSENT Quatuor MD collects, uses, and discloses your Personal Information provided that your consent has been obtained in accordance with applicable requirements, or without your consent, in certain cases provided by law, such as in the context of a criminal prosecution or investigation.

Subject to the applicable exceptions by law, the consent of the holder of parental authority or guardian is requested for a minor under 14 years old.

5 RETENTION OF PERSONAL INFORMATION We retain Personal Information only as long as necessary to meet the purposes mentioned in the Policy or to meet our legal or business requirements. Personal Information about health that is part of your medical record will be retained in accordance with applicable laws and regulations on retention.

Your Personal Information is generally retained in Quebec. However, the disclosure of Personal Information to certain technology solution providers may result in the transfer of such information outside Quebec. In such cases, Quatuor MD validates in advance the laws and personal information protection practices applicable in the target jurisdiction and provides contractual commitments regarding personal information protection and information security to ensure adequate protection of your Personal Information.

Quatuor MD may depersonalize Personal Information so that it is no longer possible to directly identify an individual and use this information for internal research and analysis purposes. Quatuor MD may also use anonymized information for serious and legitimate purposes and retain it indefinitely, as provided by law. Destruction and anonymization are carried out securely.

6 SECURITY AND PROTECTIVE MEASURES We have implemented reasonable administrative, technical, and physical measures to protect the Personal Information we hold and control against theft, loss, and unauthorized access, use, alteration, and disclosure. These security measures are proportionate to the degree of sensitivity of your Personal Information. Only employees and service providers of Quatuor MD who have access to the Personal Information of our clients are those who have a “need to know” this information to carry out their professional duties.

In addition, employees of Quatuor MD are bound by confidentiality agreements. Information security and personal information protection training and awareness are offered on a regular basis to employees of Quatuor MD.

Even though Quatuor MD deploys a multitude of security measures to adequately protect your Personal Information and reduce the risks of breach to a minimum level, a risk always remains and does not allow us to guarantee 100% that your Personal Information will not be the subject of a breach of confidentiality or integrity in the event of a breach of our physical, technical, or administrative security measures.

You can contribute to reducing these risks by responsibly using the resources and services made available by Quatuor MD. For example, you should be in a private location and not use an employer’s or another person’s computer or device to use the virtual care services offered by Quatuor MD. For more information, please consult the client information sheet on virtual care included in the confirmation email of your reservation.

If you have reason to believe that Personal Information has been compromised, please contact our Personal Information Protection Officer (“PIPO”) whose contact details are found below.

7 YOUR CHOICES Marketing communications: If you receive our marketing communications by email, you can unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of the email or by modifying your preferences in the account profile on the Portal. You can also choose to no longer receive our marketing communications by clicking on the unsubscribe link at the bottom of our communications or by contacting our PIPO at the contact details indicated below.

Closing your account: You can also close your account on the Portal at any time. To close your account or request the deletion of the Personal Information contained in your account profile, please contact us at the contact details below. If you choose to close your account or delete the Personal Information contained in your account profile, we may retain certain information (including your medical record) to meet our legal or regulatory obligations. For more information, please refer to the “Retention of Personal Information” section above.

8 YOUR RIGHTS AND HOW TO EXERCISE THEM Access and rectification: Subject to the limited exceptions provided by applicable legislation, you have the right to access, review, update, and request the rectification of inaccuracies in your Personal Information. You can make these requests by contacting our PIPO whose contact details are indicated below. You can also update your Personal Information in your account profile or by calling Quatuor MD. We may ask you for certain Personal Information when you make such a request in order to verify your identity. Requests for access and rectification are free of charge. However, reasonable fees may be charged for the transcription, reproduction, or transmission of your Personal Information. Your request will be processed no later than thirty (30) days following the date of receipt of your written request to the PIPO.

Withdrawal of consent: You may withdraw your consent, in cases where this is permitted, for your Personal Information to be used by Quatuor MD. Any request for withdrawal of consent must be communicated to the Personal Information Protection Officer (“PIPO”) whose contact details are found below at the end of this Policy.

Automated decision-making: If Quatuor MD implements a decision-making process that is based exclusively on automated processing (without human intervention) of Personal Information, you will be informed of the fact that you are subject to such a process, the decision that has been made, and your right to present your observations with respect to this decision. You may also be informed on request of the following:

Portability [Effective as of September 2024]: You may obtain, on request, a copy of the Personal Information that has been collected about you. If your Personal Information has been computerized and in the absence of serious practical difficulties, you may request that it be provided to you in a structured, commonly used technological format.

Complaint: Any questions regarding your Personal Information or complaints following the non-compliance with the principles set out in the Policy must be submitted in writing to the PIPO whose contact details are found below.

9 LINK TO THIRD-PARTY SITES Our Websites may contain links to other websites that Quatuor MD does not own or operate. We provide links to third-party websites for the convenience of the user. These links are not intended to endorse the linked websites or to refer to them. This Policy does not apply to information collected by linked websites. These have separate and independent privacy policies, notices, and terms of use. We have no control over these websites and, therefore, we are not responsible for how the organizations that operate these linked websites may collect, use, disclose, secure, and otherwise process Personal Information. We encourage you to read the privacy policy of each website you visit.

10 UPDATES TO THE PRIVACY POLICY We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to regularly review this page to ensure you are aware of these changes. We will indicate at the top of this privacy policy the date of its last update.

11 OUR PERSONAL INFORMATION PROTECTION OFFICER Quatuor MD has appointed a PIPO who ensures that Quatuor MD complies with applicable laws and regulations regarding the protection of Personal Information.

Responsible of The Protection of Personal Information:

Andrée April, General Manager and Vice President of Operations

Mailing address: 800 rue du Square-Victoria, Office 2700, Montreal (Quebec) H3C 0B4

Email address: [email protected]