Terms of Use and Privacy Policy

Personalized Support Service Privacy Policy

Last updated on 22 April 2024

1. GENERAL PRINCIPLES

Clinical Trials Quebec is committed to protecting the privacy of Personal Information. In order to inform Users of the privacy practices put in place, Clinical Trials Quebec has developed this Privacy Policy, which summarizes: (i) the types of Personal Information collected; (ii) the purposes for which it is collected; (iii) the ways in which it is used and protected; and (iv) the situations in which it may be shared with Authorized Subcontractors or other persons if required or permitted by law. This Privacy Policy also describes the rights of Users, the security measures in place and the procedure in the case of a confidentiality incident. Click on the links below to access the different sections of our Privacy Policy :

2. DEFINITIONS AND INTERPRETATION

2.1 Definitions.

Capitalized terms used in this Privacy Policy have the following meanings :

  • Authorized Subcontractors means any person who assists Clinical Trials Quebec in the development or provision of the Services, the Content and/or the Website and who needs to have access to certain data (including Personal Information) to do so.
  • Content means information and other content made available on the Website or as part of the Services.
  • Cookies means small text files that are placed on the browser of devices when a User accesses or uses the Services, the Content or the Website, and which may be temporary (and disappear when such devices are closed) or permanent (and remain on the browser even after such devices are closed).
  • De-identified Information means any information that no longer allows a person to be directly identified.
  • Other Purposes means any processing for any purpose authorized by the law or by a User, including the use of Personal Information for purposes consistent with the purpose for which it was collected or the processing of De-identified Information for statistical, study and research purposes or for the development, evaluation and improvement of the Services, the Content and the Website.
  • Personal Information means any information about an individual that directly or indirectly identifies that individual. The term Personal Information includes health information.
  • Clinical Trials Quebec refers to CATALIS Québec, a not-for-profit organization created under the Canada Not-for-Profit Corporations Act, S.C. 2009, c. 23, also doing business under the name of “Clinical Trials Quebec” and conducting this initiative under that name.
  • Services means the support services offered by Clinical Trials Quebec to Users and available via the Website, including all functions and features of these Services.
  • Website means the section exclusively dedicated to the Service and its components available on the Clinical Trials Quebec website, available at this address or at any other address thereafter.
  • User means any health professional or potential patient (including their caregivers and/or legal representatives) wishing to obtain Services with the respect to clinical trials conducted in Quebec or elsewhere in Canada or in the world (in the absence of such trials in Quebec).
2.1 Interpretation.

Unless the context requires otherwise, grammatical variations of any defined term herein has a similar meaning and the singular includes the plural and the masculine includes the feminine, and vice versa.

3. COLLECTION AND USE OF PERSONAL INFORMATION

In order to provide the agreed-upon Services, Clinical Trials Quebec must collect and process information about Users, including Personal Information. Data (including, where applicable, Personal Information) will also be collected if Users contact Clinical Trials Quebec. Finally, Clinical Trials Quebec and its Authorized Subcontractors may process information (including Personal Information, where applicable) in connection with the Services. In all cases, such Personal Information is collected and processed only for the purposes described in the Privacy Policy.

3.1 Information Provided by Users

In order to use the Services, Users will be required to provide information. As part of this process, each User will be required to select the Services they wish to use, consent to the use of those Services and consent to the sharing of their information. If a User is making a request on behalf of another person and chooses to provide personal information about that person, then the User must confirm that they have the right to provide that information. (A User who makes a search on behalf of another person does not have to include that person's name or other identifiers, and Clinical Trials Quebec does not wish to receive such information). The consent and information provided will be kept in the User's file.

3.1.1 Use of Services : In order for Clinical Trials Quebec to provide the agreed upon Services, including the report of research results, any User shall provide their first/last name and contact information, including an email address. In addition, each User must select : (i) certain search criteria, including the type of disease and clinical trial sought; and (ii) certain categories of information, including the sex and age group of the person for which the research is undertaken. Finally, any User will be required to provide certain additional information (e.g., the relevant city, health-care facility or postal code). The collection and processing of such Personal Information are required to provide the Services. A User may, at any time, modify the search filters (e.g., according to the evolution of their medical condition or location).

3.1.2 Continuous Monitoring Service : When a User wants to receive alerts on clinical trials, they will have to provide to Clinical Trials Quebec first/last name and email address. This Personal Information is required to allow the User to receive applicable updates. An update will be sent when a new result becomes available; if there are no results for a few consecutive months, Clinical Trials Quebec will contact the User to inform them of the situation. Depending on the type of alerts, a User may be required to provide additional Personal Information; this will be brought to the User’s attention prior to the collection of such information. Any User may unsubscribe from any alert at any time, as set forth in Section 7.2.2 below.

3.1.3 Comments, Questions and Requests for Information : If a User contacts Clinical Trials Quebec to obtain information regarding its Services or any other subject, such User will provide certain Personal Information (e.g., their name and email address). Such User may provide other Personal Information (e.g., their opinion). Clinical Trials Quebec will use this Personal Information to respond to their communication. This Personal Information may also be used for any Other Purpose.

If new services are made available, then additional collection and processing of Personal Information may be required. Clinical Trials Quebec will notify affected Users of this change in accordance with Section 8.2 below.

3.2 Information Obtained from Platforms or Using Technologies

Certain platforms and technologies can provide information :

3.2.1 Google Analytics and Cyberimpact. Google Analytics may collect data about any User's interactions with the Services, the Website and the Content. This information will then be processed and updated each time a User interacts with them again. In order to do this, Google Analytics will place codes on the Services, Website and Content, which will allow Google Analytics to see which information has been accessed, as well as the browser and device used. Similarly, Cyberimpact's technologies may be used to obtain information on transmitted communications (e.g., to determine whether a result report has been consulted). The information so collected will be in a Depersonalized format and can be used for Other Purposes.

3.2.2 Platforms. Clinical Trials Quebec uses social media platforms, such as Twitter and LinkedIn, that allow any individual to follow Clinical Trials Quebec (or its initiative) and to add Clinical Trials Quebec to their contact list. In such case, Clinical Trials Quebec will have access to that person's Web pages and profiles in accordance with the settings chosen, as more fully detailed in the privacy policies and terms of use applicable to these platforms. Clinical Trials Quebec will also receive notification and access to tweets, links and/or other publications in which Clinical Trials Quebec is identified. Any person should review the privacy settings applicable to their accounts/pages to validate what information their contacts have access to and limit such access, if necessary. Clinical Trials Quebec may wish to use certain information available on accounts or pages for Other Purposes; if so, such information will first be converted into De-identified Information.

3.2.3 Information Collected through Cookies and Other Forms of Technologies. When a User accesses or uses the Services, the Content or the Website, certain data (including Personal Information) may be collected. This information includes data about the browser used, the Internet Protocol address and the clicks/interactions that have occurred. This collection will be done by the following Cookies:

Strictly Necessary Cookies: Strictly necessary cookies help services, content and the website to function properly, web pages to maintain their integrity and users to interact with functionalities. The website cannot function properly without these cookies.

  • Preference Cookies: Preference cookies allow us to personalize and enhance the user experience by presenting customized features or content. Cookies store information that modifies the way the site behaves or what it displays, such as your language preference, or the region in which you are located.
  • Analytics Cookies: These cookies collect data (such as date, time and frequency of use, pages viewed, features used, information provided and login information) to enable us to see how users interact with the services, content, and website. The statistics generated enable us to improve the content and design better features that enhance the User experience.
  • Marketing Cookies: Marketing cookies are used to track visitors’ website browsing preferences. The objective is to use this data to present advertisements that are personalized to each user while making them relevant to the users and more targeted for third-party publishers or advertisers.

Other forms of technologies may be used for the same purpose. Cookies and other technologies that are not required (e.g., Analytics Cookies) can be blocked without impacting the Services, Website and Content. Blocking those that are required (e.g., Process/Utility Cookies) may affect the use of the Services, Website and Content. These technologies and Cookies are temporary in nature and will disappear once the browser (or device) is closed. Anyone experiencing problems may contact Clinical Trials Quebec.

4. SHARING/COMMUNICATION OF PERSONAL INFORMATION

Clinical Trials Quebec does not sell or otherwise market Personal Information. Furthermore, Personal Information is not shared with third parties, and is not used for purposes other than those: (i) described in this Privacy Policy; (ii) required or permitted by law; and (iii) to which the relevant Users have given their valid consent.

4.1 Personal Information

4.1.1 Sharing as Part of the Provision of the Services : Personal Information may be disclosed to Authorized Subcontractors who assist Clinical Trials Quebec with the Services, the Website or the Content. Disclosure will be limited to Authorized Subcontractors who have a need to know and who are bound by confidentiality undertakings, and will be made in accordance with the laws.

4.1.2 Corporate Transaction/Reorganization : Certain Personal Information may be disclosed to a third party as part of a corporate transaction/reorganization if: (i) necessary to carry out the transaction/reorganization; (ii) done in a manner that preserves the confidentiality of the Personal Information and (iii) done in accordance with the law.

4.1.3 Others : Personal Information may be used and disclosed by Clinical Trials Quebec acting reasonably, if it believes that doing so is: (i) necessary to comply with applicable laws, or any legal process or governmental request; (ii) necessary to protect its rights; or (iii) otherwise permitted or required by law. Clinical Trials Quebec may also use, disclose or otherwise process any Personal Information as permitted by law, including for any Other Purpose.

4.2 De-identified Information

Users acknowledge and agree that De-identified Information (e.g., information that excludes their names or other identifiers) may be created from Personal Information and used and otherwise processed for any Other Purpose. Clinical Trials Quebec will take reasonable steps to limit the risks that anyone identifies a User from De-identified Information.

5. SECURITY AND PRIVACY INCIDENTS

5.1 Security Measures.

Clinical Trials Quebec has put in place measures to protect Personal Information that are reasonable, based notably on the sensitivity of the information concerned, the purposes for which it is to be used, the quantity and distribution of the information and the medium on which it is stored. These measures include the following:

5.1.1 Limited Access : Subject to applicable laws, access to any Personal Information is granted only to employees and representatives of Clinical Trials Quebec (and, where applicable, Authorized Subcontractors) who have a need to know such information and following the implementation of appropriate measures.

5.1.2 Privacy Impact Assessment : Clinical Trials Quebec has conducted a Privacy Impact Assessment of the Services as required by law. Clinical Trials Quebec conduct other Privacy Impact Assessments if other Services and features are added or when required by law.

5.1.3 Encryption in Transit : Whenever a User makes a request through the Services, an HTTPS protocol is used to transfer the information, and Secure Sockets Layer (SSL) technology protects Personal Information through server authentication and data encryption. Activation of this technology can be confirmed by looking at: (i) the browser bar, which will then, depending on the browser, display a padlock to the left of the website address (URL); and (ii) the URL or address bar of the browser, in which the first characters should change from "http" to "https".

5.1.4 Secure Data Centre : The Services are hosted on a secure and private platform provided by a recognized IT provider.

5.2 LIMITATIONS.

WHILE THE SERVICES AND THE WEBSITE HAVE BEEN CREATED USING TECHNOLOGIES OF MERCHANTABLE QUALITY, ANY TECHNOLOGY – JUST LIKE ANY OTHER SERVICE OR DELIVERY METHOD – IS NEVER INFALLIBLE OR FULLY PROTECTED AGAINST UNFORESEEN EVENTS, CYBER-ATTACKS (AND OTHER ILLEGAL ACTS) OR FAILURES, AND ALL USERS SHOULD BE AWARE THAT THERE IS A RISK ASSOCIATED WITH ANY TRANSMISSION (INCLUDING ANY E-TRANSMISSION) OF DATA. CLINICAL TRIALS QUEBEC CANNOT GUARANTEE THAT SUCH DATA (INCLUDING PERSONAL INFORMATION) WILL NEVER BE INTERCEPTED OR BE SUBJECT TO OTHER INCIDENTS. IN ADDITION, EVENTS AFFECTING DEVICES AND SYSTEMS (INCLUDING THOSE LEADING TO THEIR ACCESS AND CONTROL) MAY OCCUR, AND UNWANTED COMMUNICATIONS AND INVITATIONS MAY BE RECEIVED. IF A USER RECEIVES A COMMUNICATION THAT APPEARS TO BE FROM CLINICAL TRIALS QUEBEC REQUESTING FINANCIAL OR OTHER PERSONAL INFORMATION (OTHER THAN THE DATA PROVIDED ON THE FORM), THEN ANY USER SHOULD REFRAIN FROM RESPONDING TO THAT COMMUNICATION. CLINICAL TRIALS QUEBEC WILL NEVER REQUEST FINANCIAL OR OTHER INFORMATION IN THIS MANNER (SUBJECT TO PERSONAL INFORMATION SPECIFICALLY REQUIRED TO PERFORM THE SERVICES). IF A USER HAS DISCLOSED PERSONAL INFORMATION IN RESPONSE TO A COMMUNICATION, POP-UP OR SUSPICIOUS WEBSITE CLAIMING TO BE AFFILIATED WITH CLINICAL TRIALS QUEBEC OR IF ANY OF THE FOREGOING EVENTS OCCUR, THEN SUCH USER SHOULD CONTACT CLINICAL TRIALS QUEBEC IMMEDIATELY.

5.3 Privacy Incidents :

If Clinical Trials Quebec has reasons to believe that a confidentiality incident involving Personal Information has occurred, then Clinical Trials Quebec will take reasonable steps to reduce the risk of harm and to prevent further incidents. If the incident presents a risk of serious injury, then Clinical Trials Quebec will notify the Commission d'accès à l'information and any User affected by the incident. Clinical Trials Quebec may also notify any person who could reduce this risk (by communicating only the necessary Personal Information). Finally, Clinical Trials Quebec will comply with the other requirements imposed by the law.

6. RETENTION OF PERSONAL INFORMATION

Clinical Trials Quebec will retain Personal Information for as long as necessary to fulfill the purposes for which it was collected. These permitted purposes include those required: (i) to provide the Services; (ii) to comply with the law or prevent a breach; (iii) to resolve any dispute; and (iv) to ensure the implementation of this Privacy Policy. When such information is no longer required, then it will be destroyed or retained in an anonymized format (for meaningful and legitimate purposes and in accordance with applicable legal requirements).

7. USERS’ RIGHTS AND COMMUNICATION WITH CLINICAL TRIALS QUEBEC

7.1 Users’ Rights

Clinical Trials Quebec will confirm the existence of any Personal Information it holds about a User upon receipt of a request to that effect from an individual who is entitled to make such a request, and will provide access to (and a copy of) such Personal Information. Requests for correction or any other rights may be made by any person concerned by contacting Clinical Trials Quebec and complying with the requirements prescribed by law.

7.2 Communication with Clinical Trials Quebec

Anyone can contact Clinical Trials Quebec for :

7.2.1 any questions, comments and requests : The contact information of the Person in charge of the protection of personal information is available below. Requests and inquiries will be handled promptly and within applicable legal timeframes.

Privacy Officer
CATALIS Quebec
465 McGill Street, Suite 200
Montreal (Quebec) H2Y 2H1
vieprivee@catalisquebec.com

7.2.2 unsubscribing from alerts : This can be done at any time by using the contact information provided in Section 7.2.1 or by clicking on the unsubscribe mechanism at the bottom of each email or by replying to an email received with the word "Stop" or "Unsubscribe."

8. MISCELLANEOUS

8.1 Amendments :

Clinical Trials Quebec may modify this Privacy Policy from time to time. Such changes will be made available by any means acceptable to Clinical Trials Quebec (depending on the nature of the changes made). If a User does not agree with such amendments, then they must cease accessing and using the Services, the Website and the Content before such changes become effective; thereafter, all access and use shall constitute acceptance of such amendments.

8.2 Hyperlinks to Third-party Websites :

The Website, the Content and/or the Services (including any reports) may include hyperlinks to Other Sources, including third-party websites. Clinical Trials Quebec reminds you that these hyperlinks are included for informational purposes only and that it does not endorse or control the content on these hyperlinks. Clinical Trials Quebec is not responsible for these Other Sources. Users choose whether or not to access the hyperlinks, and should review the terms of use and privacy policies applicable to those websites.

8.3 Severability :

If any provision is in conflict with any law or is unenforceable, then such provision shall be severable from the remaining provisions, and shall be deemed rewritten so as to be valid and enforceable while preserving, to the greatest extent possible, its original intent and scope.

8.4 Force Majeure :

Clinical Trials Quebec is not liable for any damage caused by a situation of force majeure.

8.5 Applicable Laws :

This Privacy Policy is governed by the laws in force in the Province of Quebec excluding any principles and rules that may lead to the application of foreign laws. Any dispute that cannot be resolved through direct and good faith negotiations shall be submitted to the courts of the Province of Quebec, which shall have exclusive jurisdiction to resolve such dispute.