1-INTRODUCTION
Lambert Médico Factures (hereinafter "LMF") is concerned about respecting your privacy and protecting your personal information.
In the course of using our services, LMF may collect and you may disclose personal information.
The purpose of this policy is to explain the following to users of LMF's services:
- How their personal data is collected and processed;
- What rights they have to their data;
- Who is responsible for processing the personal data collected and processed;
- To whom these data are transmitted;
- The use of LMF cookies on its websites.
2 - APPLICABLE LAWS
This Directive takes into account the legal obligations defined, among others, by the Act respecting the protection of personal information in the private sector (chapter P-39.1) and the Quebec Health Insurance Act (chapter A-29).
At the same time, a European resident's personal information will be handled in accordance with the European Union's General Data Protection Regulation (GDPR).
3 - PERSONAL INFORMATION
Any information that relates to a natural person and allows that person to be identified is considered personal. Your personal information may include, but is not limited to, your first and last name, date of birth, home address, telephone numbers, gender, e-mail address, information about your family situation, information you enter when you create a profile to join one of our services, your lifestyle or your health.
However, personal information does not include information concerning the exercise of a function within an enterprise, such as name, title and function, as well as the address, e-mail address and telephone number of the place of work.
4 - OUR COMMITMENT
We have established and implemented internal policies and procedures to adequately protect personal information in our possession, regardless of the medium or form in which it is held. We review them on a regular basis.
We make our employees aware of the importance of protecting personal information by requiring them to undergo training on the subject and by issuing occasional directives outlining their role and obligations in this regard.
5 - INFORMATION GATHERING OBJECTIVES
In the course of our duties, we collect your personal and confidential information solely to enable us to provide you with the requested services in an appropriate and personalized manner. In all cases, the disclosure of your personal and confidential information will be subject to obligations to maintain confidentiality and comply with applicable laws.
6 - CONSENT
Subject to the exceptions and requirements of applicable laws, we will not communicate or disclose your personal information to any third parties without your consent.
By using our services, you consent to the collection, use and disclosure of your personal and confidential information in accordance with this policy. The form of consent may vary depending on the context or the service requested.
Your consent will also be requested:
- By a representative of our general management for contractual purposes
- By a representative of our human resources department
- By a representative of one of the services you wish to join
- By the main service provider in cases where LMF acts as a subcontractor
You may withdraw your consent at any time, subject to certain legal or contractual restrictions.
In certain circumstances, we may collect, use or disclose personal information without your knowledge or consent. Such circumstances may arise, for example, when, for legal, medical or security reasons, it is impossible or unlikely to obtain your consent, or when the information is required to investigate a possible breach of contract, to prevent or detect fraud, or to enforce the law.
Before disclosing personal information about another person to us, you must obtain that person's consent to the disclosure and processing of that personal information under the terms of this policy.
6.1 - PERSONAL INFORMATION ABOUT A MINOR
Personal information concerning a minor under the age of 14 will not be collected from him or her without the consent of the parent or guardian.
7 - LIMITS ON COLLECTION, USE AND DISCLOSURE
7.1 - COLLECTION
We limit the collection, use and disclosure of your personal information to the purposes we have identified to you. Personal information is accessible to any person who is entitled to receive it within LMF when this information is necessary for the performance of his or her duties.
If you submit personal information to one of our websites for the purpose of publication, we will publish it and may use the information in accordance with the permissions you grant us.
7.2 - USE
We may use the personal information we collect for the following purposes, among others:
- To provide the requested service;
- To confirm your identity and respond to your requests for information;
- To improve our service offering;
- To operate and improve the website and our solutions while understanding user usage patterns;
- To provide any other complementary service associated with the requested service;
- To meet legal and regulatory requirements;
- To control the quality of customer service and prevent errors and fraud.
7.3 - DISCLOSURE
We may disclose your personal information to any of our employees, professional advisers, suppliers, or subcontractors or affiliates to the extent reasonably necessary to provide the services requested and for the purposes set out in this policy.
As a general rule, we do not disclose your personal information. Occasionally, we may share your personal information with certain suppliers or agents in order to provide the services you have requested. In all cases, we comply with legal restrictions and requirements when disclosing your personal information and, in certain circumstances, this is subject to a written agreement and a security assessment demonstrating that your personal information is adequately protected in a manner similar to that in place at LMF.
Your personal information will not be disclosed to third parties other than in accordance with this Privacy Policy, except as required or permitted by law, or as ordered by a court of competent jurisdiction.
We do not sell your personal information to third parties.
7.4 - IMPACT ASSESSMENT
A Privacy Impact Assessment (PIA) on the use of personal information by our services and/or systems is conducted before any personal information is collected by LMF. When transfers are made outside Quebec, the impact on such a transfer will also be carried out.
7.5 - INTERNATIONAL DATA TRANSFERS
The information we collect may be stored, processed and transferred to any country in which LMF or its subcontractors, offer their services , in order to enable us to use the information in accordance with this policy.
The information we collect may be transferred to or processed in the following countries: the United States of America and certain countries of the European Union.
Personal information that you publish on our website or submit for publication may be available via the Internet worldwide. We cannot prevent the use, good or bad, of this information by third parties.
You expressly agree to the transfer of personal information as described in this section.
8 - NON-PERSONAL INFORMATION
We automatically collect certain non-personal information using third-party analytics programs such as Google Analytics to help us understand how our visitors use our web services, but none of this information identifies you personally. The following information may be collected, stored and used:
- Information about your computer, including your IP address, geographic location, browser type and version, and operating system;
- Information about your visits to and use of our web sites, including referral source, length of visit, pages viewed, and web site navigation paths;
- Information generated when you use our site, including when, how often and under what circumstances you use it;
9 - COOKIES
LMF and affiliated web services use cookies. Cookies are small data files stored on your computer or mobile device when you visit a website or application. They are used to enhance your user experience by recording certain data. By using LMF web services, you consent to this use.
9.1 - COOKIES WE USE ON OUR WEBSITES
We use cookies for the following purposes:
a) Authentication: We use cookies to identify you when you visit and browse our website and web platforms. Cookies collected for this purpose are used for login and session management.
b) Personalization: We use cookies to store information about your preferences and enable us to personalize the service to your needs. The cookies used for this purpose are used to capture the language of use of LMF websites.
9.2 - COOKIES USED BY OUR SERVICE PROVIDERS
In certain situations, it is possible that one of our services is provided by one of our external suppliers who may use cookies that will be stored on your computer or mobile device.
9.3 - COOKIE MANAGEMENT
You can set your browser or device to refuse cookies or delete them after they have been stored. Please consult the "Help" section of your browser or device for instructions. Please note that deleting or refusing cookies may affect your user experience.
To change your cookie consent options for our website, click here to bring up the banner again and change your choices.
10 - RETENTION OF INFORMATION
When your personal information is no longer required, it is destroyed in accordance with the law and our records retention policy. In certain circumstances, we may anonymize the personal information we retain.
Your personal and confidential information is kept, directly or through subcontractors, only for as long as is necessary for the purposes of the services requested and applicable legal and regulatory requirements. We require our subcontractors to subscribe to confidentiality commitments and to apply policies equivalent to this one. In all cases, access to your personal and confidential information is restricted to those persons for whom access is required in the performance of their duties.
11 - LIABILITY
We are responsible for personal information in our possession or custody, including information we entrust to third parties for the purpose of providing you with the requested service. We require these third parties to maintain this information under strict confidentiality and security standards.
We adhere to the principles set out by law. We have policies and guidelines in place to ensure that your privacy is protected. The Privacy Officer oversees this Privacy Policy as well as the company's various frameworks.
Our staff is informed and properly trained on privacy policies and practices.
12 - SAFETY MEASURES
We have implemented a number of security measures with respect to the personal information and confidential data we hold in order to protect such information against loss or theft and to prevent unauthorized access, transmission, use or modification of such personal information, including the following subsections:
Learn more about our security measures
12.1 - PRIVACY IMPACT ASSESSMENT
LMF conducts a Privacy Impact Assessment (PIA) of any project involving the acquisition, development or redesign of an information system or the electronic delivery of services that involves the collection, use, disclosure, retention or destruction of personal information. This assessment documents the serious and legitimate interest in the use of personal information.
12.2 - SECURE COMPUTING ENVIRONMENTS
Infrastructure and equipment are hosted in a secure environment in a data center located in Quebec, Canada. In cases where it is impossible to host a solution or service in Quebec, we ensure that security measures equivalent or superior to those required by this Policy are put in place.
Access to LMF web services is via a secure SSL (HTTPS) transmission channel.
Learn more about our security measures
12.3 - ACCESS MANAGEMENT
Only employees whose duties require it have access to personal or confidential information. Data access is logged and monitored .
12.4 - TRAINING AND AWARENESS-RAISING
Our employees and partners are trained and made aware of the importance of protecting your personal information.
12.5 - COMMITMENT TO CONFIDENTIALITY
Our employees sign a confidentiality agreement.
Security audits are carried out by firms specializing in information security.
12.6 - DESTRUCTION
LMF ensures the physical and technological security of the personal information it holds in order to prevent accidental destruction, loss, disclosure or inappropriate destruction.
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected. We must destroy or anonymize this information in accordance with the law and our retention schedule. When we destroy or anonymize your personal information, we take the necessary steps to ensure its confidentiality and that no unauthorized person has access to it during the destruction or anonymization process.
12.7 - MANAGING INCIDENTS INVOLVING PERSONAL INFORMATION
If LMF has reason to believe that a confidentiality incident involving personal information has occurred and that there is a risk of serious harm caused by the incident, LMF will promptly inform the Commission d'accès à l'information and any person whose personal information is affected by the incident. It may also notify any person or organization likely to reduce this risk, by communicating only the personal information necessary for this purpose without the consent of the person concerned. In all cases, a log will document the incident for reference purposes.
13 - USER RIGHTS
13.1 - REQUEST FOR ACCESS, WITHDRAWAL OR CORRECTION
Subject to any regulatory or contractual restrictions, you may consult, correct or destroy the personal information we hold about you.
We will send you such information within a maximum of 30 days from the date of receipt of the written request and in a structured, commonly used technological format. A fee may be charged for processing your request.
Under certain circumstances, we may refuse to provide you with the requested information. Exceptions to your right of access include the fact that information cannot be disclosed for legal or security reasons. These limitations are described in the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1).
You may verify the accuracy and completeness of your personal information and, if necessary, request that it be amended. Any request for amendment will be processed in accordance with the law.
However, members and candidates are obliged to keep their information up to date in accordance with the Professional Code.
13.2 - DATA PORTABILITY
The user has the right to request the portability of his personal data, held by LMF, to another site.
13.3 - LIMITING AND OBJECTING TO DATA PROCESSING
The user has the right to request that LMF limit or object to the processing of his/her data and LMF cannot refuse this request unless it can be shown that there are legitimate and compelling reasons for doing so, which may override the interests and rights and freedoms of the user.
13.4 - DECISION BASED EXCLUSIVELY ON AN AUTOMATED PROCESS
The user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him, or significantly affects him in a similar way.
14 - INQUIRIES, COMPLAINTS AND QUESTIONS
We are committed to responding to your questions and concerns regarding the protection of your personal information. If you are not satisfied with the response, you may contact the Privacy Officer at the above address.
14.1 - CONTACT
Any request or complaint concerning the protection of personal information should be sent to the Privacy Officer at the address below:
Privacy Officer
Lambert Médico factures
769 Woodward Street
Sherbrooke, QC J1G 1W5
Fax 819-823-9736
E-mail: rp@lambertmedicofactures.com
In the event that the LMF Privacy Officer decides not to respond to a user's request, and the user wishes to contest this decision, or if he believes that one of his rights has been infringed, he is entitled to contact the Commission d'accès à l'information du Québec.
15 - REVISION AND APPROVAL
This Policy comes into effect upon its adoption by LMF's Executive Committee and may be revised at any time by the Privacy Officer.
Amendments may be proposed by various LMF stakeholders and must be submitted in writing to the Access and Privacy Officer.
LMF reserves the right to modify this policy at any time. Any changes will be posted on LMF's various web platforms. Your use of the Services following the posting of changes to the Policy constitutes acceptance of those changes.
This Policy should be reviewed at least every two years to ensure that it remains relevant to LMF's mission, the activities of its users and any substantial changes in legislation or regulatory requirements.
16 - EFFECTIVE DATE
This Policy takes effect on September 1st 2022. It cancels and replaces all previous guidelines on this subject.