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Privacy and Personal Data Privacy Policy

1. General Information

(a) Introduction

Privacy is important to the Réseau des massothérapeutes professionnels du Québec (hereinafter the “Entity,” “We,” “Us,” “Our”). For this reason, We have implemented protective measures and sound management practices for your Personal Information in accordance with the laws applicable in Quebec and across Canada.

This Privacy Policy (the “Policy”), which should be read in conjunction with Our terms and conditions, describes Our practices with respect to the collection, use, processing, disclosure, and retention of Personal Information of Our clients, visitors, and users.

By using Our https://rmpq.ca/ website (the “Website”) or any of Our services, you agree that We may collect, use, process, disclose, and retain your Personal Information in accordance with the terms described herein. If you do not agree to abide by and be bound by this Policy, you are not permitted to visit, access, or use Our Website or Services, or share your Personal Information with Us.

This Policy does not apply to the Personal Information of the Entity’s employees, representatives, and consultants, or to any other person affiliated with the Entity, or to any information that does not constitute Personal Information as defined by the laws applicable in Quebec and Canada.

b) Privacy Officer

Questions, comments, and complaints regarding the Entity’s Privacy Policy and practices may be directed to Our Privacy Officer at:

Phone: 1-800-461-1312 ext. 1425
Email: edurand@rmpq.ca
Address: 2285 Saint-Pierre, Drummondville, QC J2C 5A7

2. Definitions

The following words and phrases, when they appear with the first letter in capital letters in the Policy, shall have the meanings ascribed to them below, unless otherwise implied or explicitly stated in the text:

Service Provider” means any natural or legal person who processes Personal Information on behalf of the Entity. These are third-party companies or individuals employed by the Entity to facilitate the Services, provide the Services on behalf of the Entity, perform services related to the Services, or assist the Entity in analyzing the use of the Services.

Personal Information” means any information that relates to a natural person and allows that person to be identified, i.e., that directly or indirectly reveals something about the identity, characteristics (e.g., skills, preferences, psychological tendencies, predispositions, mental capacities, character, and behaviour of the person concerned) or the person’s activities, regardless of the nature of the medium and the form in which the information is accessible (written, graphic, audio, visual, computerized, or other).

Privacy Officer” means the person who is responsible for the application of this Policy and whose contact information is identified in Section 1 of this Policy.

Services” refers to the Website, Our social media pages, and the Services and Products.

3. Handling of Personal Information

3.1 Collection of Personal Information

In the course of Our business, We may process different types of Personal Information including the information listed below:

  • Contact information, such as your first and last name, address, email address, phone number, website, business social media pages, fax number, image, date of birth, age, gender, credit card number, username, and password;
  • Information related to your professional education and practice, such as your educational credentials and transcripts, previous association, years of practice, records and offences, employment status, membership number, name of your employer, name of your company;
  • Information relating to products or services, such as information about the Services We have provided to you;
  • Transaction and payment information, such as the payment method used, date and time, payment amount, billing postal code, your address, and other related information;
  • Information that you choose to provide or transmit to Us, for example, over the phone or on Our Website, by filling out a form, making a purchase on Our Website, responding to surveys, applying for one of Our job openings, or contacting one of Our employees or representatives;
  • 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 viewed, the time and date of your visits, the number of connections, the type of browser you use, the operating system of your device, and other hardware and software information;
    • Demographic and geolocation data, such as your IP address, a precise or approximate location determined from your IP address, or your mobile device’s GPS (depending on your device settings);
    • Financial information about your activities while using the Website and Our Services, such as a credit card number when you conduct business transactions in connection with the Entity.

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

3.2 Use of Personal Information

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

  • To operate, maintain, supervise, develop, improve, and offer all features of Our Website;
  • To present and/or provide Services to you;
  • To allow you to apply for job openings;
  • To allow you to acquire Our Services and complete transactions in connection with Our Services;
  • To carry out Our contractual obligations to you;
  • To develop, improve, and offer new Services;
  • To send you messages, updates, and security alerts;
  • 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 as needed;
  • To collect reviews and feedback in connection with Our Services;
  • To perform research, analysis, and statistics in connection with Our business and Services;
  • To detect and prevent fraud, error, spam, abuse, security incidents, and other harmful activities;
  • To allow you to join the association and renew your membership status;
  • To allow you to register for Entity activities;
  • To allow you to place orders for products;
  • To enable you to use the Entity’s online insurance receipt and client file management services;
  • To allow you to make a disclosure against a member;
  • To post a job offer, at the request of the recruiter;
  • To enable the union, the discipline committee, and the professional inspection committee to carry out their mandate;
  • For any other purpose permitted or required by law.

3.3 Disclosure of Personal Information

We may share your Personal Information with Our employees, entrepreneurs, consultants, agents, contractors, service providers, and other trusted third parties (collectively, “Service Providers”), who need the information to assist Us in operating Our Website, conducting Our business activities, or servicing you, provided that such Service Providers have previously agreed in writing to maintain 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.

3.3.1 Service Providers and Other Third Parties

Although We try to avoid sharing your Personal Information with third parties, We may use Service Providers to perform various services on Our behalf, such as IT management and security, marketing, and data analytics, hosting, and storage. We have defined below the cases in which such sharing may take place:

  • We use Cloudways’ services to host and store Our data. All of these data are hosted on Canadian servers. Consult their privacy policy.
  • We use Google Analytics to analyse the Website’s audience, compile statistics, and communicate with clients and prospects. Consult their privacy policy.
  • We use the services of Google Analytics to set cookies to store information about how visitors use a website while also creating an analytical report on the website’s performance. Some of the data collected includes the number of visitors, sources, and the pages they visit anonymously. Consult their privacy policy.
  • We use the services of Google Analytics to track user behavior. Consult their privacy policy.
  • We use the services of Google Tag Manager to set cookies to test the advertising effectiveness of websites using their services. Consult their privacy policy.
  • We use Google Analytics services to set cookies to store and count page views. Consult their privacy policy.
  • We use the services of atedra.com with an advertising cookie that connects advertisers, marketers, and agencies to the website. Consult their privacy policy.
  • We use the services of Acuitads.com with a cookie that stores a unique identifier for the user’s browser when visiting websites. This cookie collects statistical data from the visitor to deliver targeted advertisements. Consult their privacy policy.
  • We use Mailchimp’s services to send emails. Consult their privacy policy.
  • We use the WordPress multilingual plugin with a cookie to store the current language/language settings. Consult their privacy policy.
  • We use the services of Amazon Web Services. Consult their privacy policy.
  • We use the services of YouTube.com, a service of Google LLC YouTube, to set cookies to track the views of embedded videos on YouTube pages. Consult their privacy policy.
  • We use the WordPress theme with cookies that allow the website owner to implement or modify the content of the website in real time. Consult their privacy policy.
  • We use Google Ads to analyze the audience for Our Services, compile statistics, and converse with clients and prospects. Consult their privacy policy.
  • We use the services of Facebook Pixel to help understand and serve ads, compile statistics, and communicate with customers and prospects. Consult their privacy policy.
  • We use Bing Ads technology to collect and store data to create usage profiles using pseudonyms. Consult their privacy policy.
  • We use the Meta Group’s Facebook and Instagram social media services to communicate about Our Services and products. Consult their privacy policy.
  • We use Facebook’s services with a cookie that stores a unique identifier that identifies the user’s browser when visiting websites. This cookie collects statistical data from the visitor to deliver targeted advertisements. Consult their privacy policy.
  • We use Facebook’s services to communicate about Our activities and to present Our products and Services. Consult Meta’s privacy policy.
  • We use Hootsuite’s services to converse live with website visitors. Consult their privacy policy.
  • We use Moneris’ services to manage transactions. Consult their privacy policy.
  • We use the services of PayPal to manage transactions. Consult their privacy policy.
  • We use Stripe’s services to manage transactions. Consult their privacy policy.
  • We use the services of Global Payments to manage transactions. Consult their privacy policy.
  • We use the services of Lepointdevente to manage registrations and transactions. Consult their privacy policy.
  • We use Metatracer to ensure Our compliance with the privacy laws that apply to Us. Consult their privacy policy.
  • We use Vistaprint’s services to print business cards ordered by Our members on the Network’s website. Consult their privacy policy.
  • We work with certain corporate partners who are authorized to communicate with Our members to provide them with exclusive offers.
  • We work with insurers to provide them with the information needed to validate the status of Our members.

We have not exhaustively listed all the Service Providers that perform various services on Our behalf given the public nature of this Policy.

Before disclosing your Personal Information to Service Providers outside the province of Quebec or depending on the nature of the Personal Information disclosed, We conduct a Privacy Impact Assessment. When We disclose your Personal Information to Service Providers, We enter into written contracts with them before your Personal Information is disclosed and provide them with only the Personal Information necessary to carry out their mandate. As part of these contracts with Our Service Providers, We are committed to adhering to the principles set out in this Policy, and these Service Providers are required to use Personal Information confidentially, as directed by Us, and only for the purposes for which it was provided. We provide sufficient assurances that adequate protective measures are in place, that are commensurate with the sensitivity of the Personal Information processed or disclosed. When Our Service Providers no longer need your Personal Information, We require them to destroy that data appropriately.

3.3.2 Complying with Legislation, Responding to Legal Requests, Preventing Harm, and Protecting Our Rights

We may disclose your Personal Information where We believe such disclosure is authorized, necessary or appropriate, including:

  • To respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • To protect Our business;
  • To comply with legal process;
  • To protect Our rights, privacy, safety, property, yours, or that of others;
  • To allow Us to pursue available remedies or limit the damages We may sustain; and
  • In accordance with applicable laws that are applicable, including laws outside your country of residence.

3.3.3 Business Transaction

We may share, transfer, or communicate, in strict accordance with this Policy and the provisions of the Act Respecting the Protection of Personal Information in the Private Sector, CQLR P-39.1 (the “Private Sector Act”) and the Act to modernize legislative provisions as regards the protection of personal information, SQ 2021, c 25 (“Law 25”, assented to September 22, 2021), your Personal Information in the event of a sale, transfer, or assignment, in whole or in part, of the Entity or Our assets (e.g., as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation, or other business transaction, including in connection with the negotiation of such transactions). In this case, We will notify you before your Personal Information is transferred and is governed by a different privacy policy.

3.4 Consent to Personal Information

To the extent possible, the Entity obtains consent directly from the individual for the collection, use, and disclosure of the Personal Information concerned. However, if you provide Personal Information about other individuals to Us, you must ensure that you have given them due notice that you are providing their information to Us in addition to obtaining their consent to such disclosure.

We will seek your express, manifest, free, informed, and specific purpose consent before using or disclosing your Personal Information for purposes other than those set out herein. We will also seek your explicit consent whenever sensitive Personal Information is involved in any of the Entity’s processing activities. We will ask for your consent for each of the specific purposes in plain and clear terms, distinct from any other information that will be disclosed to you.

BY USING OUR WEBSITES, FILLING OUT OUR FORMS, AND SUBMITTING YOUR PERSONAL INFORMATION BY EMAIL, YOU CONSENT TO THIS PRIVACY POLICY AND TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

If you do not agree, please stop using the Websites. Except where otherwise required by law, you may withdraw your consent at any time upon reasonable notice. Please note that if you choose to withdraw your consent to the collection, use, or disclosure of your Personal Information, certain features of Our Website may no longer be available to you, or We may no longer be able to offer you some of Our services.

3.5 Retention of Personal Information

Subject to applicable law, We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, unless you consent to your Personal Information being used or processed for another purpose. As an indication, the duration of certain information may extend up to 7 years following the end of the Services rendered by the Entity to you. In addition, Our retention periods may be changed from time to time due to legitimate interests (e.g., to ensure the security of Personal Information, to prevent abuse and breaches, or to prosecute criminals).

For more information on the periods for which your Personal Information is retained, please contact Our Privacy Officer using the contact information provided in section 1b) of this Policy.

4. Your Rights

As a data subject, you may exercise the rights set out below by contacting Our Privacy Officer in writing using the contact information provided in section 1b) of the Policy. Please note that We may ask you to verify your identity before responding to any of these requests.

  • You have the right to be informed of the Personal Information We hold about you, its use, disclosure, retention, and destruction, subject to the exceptions provided by applicable law.
  • You have the right to access your Personal Information, to request a copy, including hard copy, of the documents containing your Personal Information, subject to the exceptions provided by applicable law, and to obtain, where applicable, additional details about how We use, disclose, retain, and destroy it.
  • You have the right to have the Personal Information We hold about you corrected, amended, and updated if it is incomplete, ambiguous, out of date, or inaccurate.
  • You have the right to withdraw or modify your consent to the Entity’s collection, use, disclosure, or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions.
  • You have the right to ask Us to stop disseminating your Personal Information and to de-index any link to your name that provides access to that information if such disclosure would contravene the law or a court order.
  • You have the right to request that your Personal Information be disclosed to you or transferred to another organization in a structured and commonly used technological format.
  • You have the right to be notified of a privacy incident involving your Personal Information that may cause you serious harm. To this end, We maintain a register of all confidentiality incidents and assess the harm they may cause.
  • You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions set out in applicable law.

In order to comply with your request, you may be asked to provide appropriate identification or otherwise identify yourself.

5. Cookies and Other Tracking Technologies

We use cookies and other similar technologies (collectively, “Cookies”) to help Us operate, protect, and optimize the Website and Services We offer. Cookies are small text files that are stored on your device or browser. They collect certain information when you visit the Website, including your language preference, browser type and version, the type of device you are using, and your device’s unique identifier. While some of the Cookies We use are deleted after the end of your browser session, other Cookies are stored on your device or browser to enable Us to recognize your browser the next time you visit the Website. The Personal Information collected through these Cookies is not intended to identify you. In particular, it makes it possible to ensure the functioning of the Website, to improve the browsing experience of users, and to provide certain data that allows Us to better understand the traffic and interactions that take place on Our Website as well as to detect certain types of fraud. Cookies do not cause any damage to your device and cannot be used to extract your Personal Information. We collect your IP address, information about your device and operating system or browser, your browsing history and your browsing history on Our Website as well as your queries, browsing preferences (languages used), etc.

You can set up your browser so that you are informed about the setting of Cookies when you visit the Website, so that you can decide, in each case, whether to accept or reject the use of some or all of the Cookies. Please note that disabling Cookies on your browser may adversely affect your browsing experience on the Website and prevent you from using some of its features.

6. Security Measures

The Entity has implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft, or unauthorized access, disclosure, copying, communication, use, or modification. These measures include, but are not limited to:

  • From an administrative standpoint, adopting a series of policies and procedures as part of the implementation of Our Information Governance Program, including:
  • Regulating the access, communication, retention, depersonalization, including anonymization and/or, where applicable, destruction of Personal Information;
  • Determining the roles and responsibilities of Our employees throughout the life cycle of Personal Information and documents;
  • Establishing procedures for intervening in and responding to confidentiality incidents;
  • Governing the processing of requests and complaints relating to the protection and handling of Personal Information.

At a technical level, the use of several means such as:

  • A secure server. All sensitive or credit information provided is transmitted via Secure Socket Layer (SSL) technology and then encrypted in Our Payment Gateway Provider Database only for access by authorized persons with special access rights to such systems, who are required to keep the information confidential;
  • Backup systems, network monitoring software, etc.;
  • Encryption and segregation of duties, access controls, and internal audits.

We have not exhaustively listed the set of measures We are putting in place given the public nature of this Policy.

Despite the measures described above, We cannot guarantee the absolute security of your Personal Information. If you have reason to believe that your Personal Information is no longer protected, please contact Our Privacy Officer immediately using the contact information provided in Section 1b) above.

7. Changes to this Privacy Policy

We reserve the right to change this Policy at any time in accordance with applicable law. If We make any changes, We will post the revised Privacy Policy and update the date in the footer of the Privacy Policy. We will also notify you by email at least thirty (30) days prior to the effective date of the new version of Our Policy. If you do not agree to the new terms of the Privacy Policy, please do not use Our Website and Services. If you continue to use Our Website or Services after the new version of Our Policy comes into effect, then your use of Our Website and Services will be governed by that new version of the Policy.

8. Links to Third-Party Websites

From time to time, We may include references or links to Our Facebook page, websites, products, or services provided by third parties (“Third-Party Services”) on Our Website. These Third-Party Services, which are not operated or controlled by the Entity, are governed by privacy policies that are entirely separate and independent from Ours. We therefore assume no responsibility for the content and activities of these sites. This Policy applies only to the Website and Services offered by Us. The Policy does not extend to Third-Party Services such as Our Facebook, Instagram, and LinkedIn pages.

9. Invisible ReCAPTCHA

Invisible reCAPTCHA analyzes web page function activity (e.g., mouse movements and typing patterns) to determine whether a user is a robot.

The invisible reCAPTCHA service may collect information from your device. The information collected by reCAPTCHA is retained in accordance with its privacy policy.

10. Information about Your Right to the Protection of Personal Information under the General Data Protection Regulation (GDPR)

For the purposes of this Privacy Policy, We act as the controller of your Personal Information. If you are from the European Economic Area (EEA), Our legal basis for collecting and using your Personal Information, as described in this Privacy Policy, depends on the information We collect and the specific context in which We collect it. We may process your Personal Information because:

  • We need to perform a contract with you, such as when you use Our Services;
  • You have given Us permission to do so;
  • The processing is in Our legitimate interests and does not override your rights;
  • To comply with the law.

If you are a resident of the European Economic Area (EEA), you have certain rights to protect your Personal Information. Under certain circumstances, you have the following protection rights:

  • The right to access, update, or delete the Personal Data We have about you;
  • The right to rectification;
  • The right to object;
  • The right to restrict;
  • The right to portability;
  • The right to withdraw your consent from the data.

Please note that We may ask you to verify your identity before responding to such requests.

You have the right to complain to a Privacy Authority about Our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

11. Reseller Services

We use reseller services. What is a reseller? In digital marketing, reselling (or retargeting) is the practice of showing ads across the internet to people who have already visited your website. It allows your business to leave the impression that visitors to your website are following you across the internet by showing ads from Our Service on the websites and platforms they use most.

12. Payment Details

With respect to credit card details or other payment information that you have provided to Us, We are committed to ensuring that such confidential information is stored as securely as possible.

13. Individuals Under the Age of 14

We do not knowingly collect or use Personal Information from anyone under the age of 14. If you are under the age of 14, you should not provide Us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and you become aware that your child has provided Personal Information to Us without consent, please contact Us using the contact information provided in Section 1b) above to request that We delete that child’s Personal Information from Our systems.

14. Applicable Laws

The laws of Canada and Quebec, excluding its conflict of law rules, will govern this Agreement and your use of the Website. Your use of the Website may also be subject to other local, provincial, national, or international laws.

Version 1.00 22/11/23