Cliniques Michel Pop Inc. (“Cliniques Michel Pop,” “we,” “us” or “our”) is committed to protecting the privacy, security and confidentiality of the personal information collected through cmpop.com.
This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you visit our website, submit an appointment request, contact us online, interact with our digital content or advertising, or manage your cookie preferences.
This Policy applies to personal information collected through cmpop.com, including information submitted through online forms, website communications, cookies and digital measurement technologies.
Once information is transferred into Cliniques Michel Pop’s clinical, administrative or patient-management systems, it may be governed by separate privacy, medical-record and information-governance policies applicable to the clinic and its healthcare professionals.
1. Who is responsible for your personal information?
Cliniques Michel Pop Inc. is responsible for the personal information collected through its website.
Our Privacy Officer oversees our website privacy practices, including access and correction requests, consent withdrawals, privacy questions and complaints, confidentiality incidents and compliance with applicable privacy requirements.
The Privacy Officer’s contact information is provided at the end of this Policy.
2. What personal information do we collect?
The personal information we collect depends on how you interact with our website.
Appointment requests
When you submit an appointment request, we may collect:
- – Your gender, first and last name, date of birth and city
- – Your email address and telephone number
- – Information about how you heard about us
- – Additional information about the source of your referral
- – Information about your vision or eye condition
- – Whether you are interested in correcting your vision to reduce or eliminate your dependence on glasses
- – The date, time, source and status of your request
- – Records of our communications and follow-up with you
Information concerning your eyesight, symptoms, medical condition or interest in a particular treatment may constitute sensitive health information.
Our online appointment form must be completed by a person who is 18 years of age or older. If an appointment request concerns a minor, it must be submitted by the minor’s parent or legal guardian. Existing patients and individuals who have received eye surgery outside Cliniques Michel Pop should contact the clinic by telephone.
Website and device information
Depending on your consent choices, we may collect technical and usage information when you visit our website. This may include your Internet Protocol address, approximate location derived from that address, device type, browser, operating system, cookie identifiers, consent preferences, pages visited, time spent on the website, links or features used, referral sources, advertising campaign information, call-attribution information, video interactions and website performance or security data.
We may also record neutral website events, such as whether an appointment form was started or submitted.
Our analytics and advertising systems are configured so that information entered into appointment-form fields, including names, contact information, dates of birth and selected vision conditions, is not transmitted to analytics or advertising platforms.
Website communications
When you contact us through the website, we may collect your name, contact information, the contents of your communication, the date and time of the request, any information you voluntarily provide and records of our response.
Please do not submit medical information that is not reasonably necessary for your request through a general website form or unsecured email.
3. How do we collect personal information?
We collect personal information directly from you when you complete an appointment form, submit another website form or communicate with us online.
We may also collect information automatically through cookies, pixels, tags, local storage, server logs and similar technologies. Depending on your consent choices, information may also be collected through analytics, advertising, referral and call-attribution platforms.
In some cases, information may be received from a service provider acting on our behalf or from another source where you have consented to the collection or where the collection is otherwise permitted by law.
We limit the collection of personal information to information that is reasonably necessary for the purposes identified in this Policy or communicated to you at the time of collection.
4. Why do we use personal information?
Responding to appointment requests
We use information submitted through our appointment form to identify and contact you, respond to your inquiry, understand the general nature of your request and direct it to the appropriate clinic, team or service.
We may also use the information to schedule an appointment or consultation, prepare for administrative or clinical follow-up, determine whether additional information is required and maintain a record of our communications with you.
Submitting an appointment request does not provide medical advice, establish a diagnosis, guarantee eligibility for a treatment or replace an examination by a qualified healthcare professional.
Communicating with you
We may use your personal information to respond to an inquiry, confirm or manage an appointment request, provide administrative instructions, notify you of relevant changes and follow up regarding a consultation or requested service.
Operating and protecting our website
We use information to process online forms, maintain website functionality, diagnose technical problems, improve website performance, prevent fraud or misuse, detect security incidents and protect our visitors, personnel, systems and operations.
We may also maintain logs, backups and system records for operational, security and troubleshooting purposes.
Measuring website and marketing performance
With your consent, we may use analytics and advertising technologies to understand how visitors use our website, measure website traffic, determine how visitors discover Cliniques Michel Pop and evaluate the effectiveness of our advertising.
We may also use this information to attribute appointment requests to marketing channels, improve our website content and user experience, and optimize our marketing investments.
Neutral events, such as the completion of an appointment request, may be used to measure performance. We do not transmit appointment-form values, selected vision conditions, dates of birth, contact information or other identifiable health information to analytics or advertising platforms.
Promotional communications
Submitting an appointment request does not automatically subscribe you to promotional emails or text messages.
We use your contact information to send promotional communications only where we have obtained the consent required by applicable law. You may withdraw this consent at any time by using the unsubscribe mechanism included in the communication or by contacting us.
Consent to receive promotional communications is separate from the consent required to process an appointment request.
Legal and security purposes
We may use personal information to comply with applicable laws and regulations, respond to lawful requests or legal proceedings, establish or defend legal rights, investigate complaints or confidentiality incidents and prevent fraud, misuse or unauthorized activity.
5. Consent
Where consent is required, we request it in clear and understandable language for identified and specific purposes.
Because information concerning your eyesight, symptoms or medical condition may be sensitive, we obtain express consent where required for its collection, use or disclosure.
Consent requested in writing is presented separately from other information where required by law.
You may withdraw your consent at any time, subject to applicable legal or contractual restrictions. Withdrawing consent does not affect processing that occurred before the withdrawal and may prevent us from responding to or completing a request where the information is necessary for that purpose.
Cookie and tracking preferences may be changed or withdrawn through the consent-management platform available on our website.
6. Cookies and similar technologies
Our website uses cookies and similar technologies.
A cookie is a small file stored on your computer, mobile device or browser when you visit a website. Similar technologies may include pixels, tags, scripts, local storage, server logs and browser or device identifiers.
We use the following categories of technologies:
Necessary technologies
These technologies are required for the secure and proper operation of our website. They may support consent management, website security, form operation, navigation, language preferences and other essential functions.
Necessary technologies cannot be disabled through our consent-management platform where they are required to provide the website or a service requested by you.
Performance technologies
With your consent, these technologies collect statistical information about how visitors use our website. This helps us measure website traffic, understand navigation patterns, identify technical issues and improve website performance and content.
Functional technologies
With your consent, these technologies support optional website functionality, such as remembering language preferences, displaying embedded videos and operating interactive content.
Some functional technologies may be set by third-party services integrated into our website. Refusing them may prevent certain features or content from working properly.
Advertising technologies
With your consent, these technologies may be used to measure advertising campaigns, attribute website visits and appointment requests to marketing sources, store advertising click identifiers, measure neutral conversion events and improve campaign effectiveness.
These technologies may involve providers such as Google LLC and Meta Platforms, Inc.
We do not use appointment-form values, selected eye conditions or other identifiable health information to create advertising audiences or personalize advertising.
Our separate Cookie Policy provides the current list of cookies and similar technologies detected on our website, including their providers, purposes, categories, domains and retention periods.
You can choose to opt out of all but the necessary cookies. In the settings of the browser, you can change the settings to ensure that cookies will be blocked. Most browsers provide you with an explanation on how to do this in the so-called ‘help-function’. However, if you block the cookies, it is possible that you will not be able to enjoy all the technical features our website has to offer and it may negatively affect your user experience.
7. Consent management and tracking technologies
CookieFirst is used to collect and manage website consent preferences.
Depending on your consent choices, our website may use services such as Google Analytics 4, Google Tag Manager, Google Ads, Meta Pixel, Meta Conversions API, Stape.io, YouTube, Rendia and call-attribution technologies.
The complete and current inventory is available through our Cookie Policy.
Our website uses both browser-based and server-side measurement technologies. Server-side tracking is configured to respect the consent choices recorded through CookieFirst.
Refusing or withdrawing consent prevents the corresponding non-essential analytics and advertising events from being processed through both browser-side and server-side systems. Server-side tracking does not override your consent preferences.
Non-essential performance, functional and advertising technologies are not activated until the required consent has been provided through our consent-management platform.
8. Advertising and sensitive health information
We recognize that visiting a page concerning a vision condition, treatment or procedure may reveal information about a person’s possible health interests.
Our tracking and advertising systems are configured to prevent appointment-form values and identifiable health information from being transmitted to advertising platforms.
Appointment-form values, contact information, dates of birth, selected eye conditions and other identifiable health information are not transmitted to Google Analytics, Google Ads, Meta or other advertising platforms.
We do not use selected vision conditions to create advertising audiences, use identifiable medical information to personalize advertising, sell identifiable appointment information or use an appointment request to infer or confirm a diagnosis.
Submitting an appointment request also does not automatically add you to a promotional list.
Neutral conversion events, such as the completion of an appointment request, may be used to measure marketing performance, subject to your consent choices.
9. Who has access to personal information?
Access to personal information collected through our website is limited to authorized personnel, representatives and service providers who require it to perform their duties or provide services on our behalf.
These parties may include appointment and patient-service teams, administrative and information-technology personnel, website and hosting providers, form-processing and appointment-management providers, communication providers, information-security providers, analytics and advertising-measurement providers, consent-management providers and server-side tracking providers.
Professional advisers, regulatory authorities or public authorities may also receive information where permitted or required by law.
Personnel and service providers are required to protect the confidentiality of the information to which they have access.
10. When may personal information be disclosed?
We may disclose personal information with your consent, to respond to a request you submitted, to manage an appointment or communication, or to service providers acting on our behalf.
Information may also be disclosed where necessary to comply with a legal or regulatory obligation, respond to a lawful request, detect or investigate fraud or a security incident, protect the rights or safety of Cliniques Michel Pop or others, or establish or defend legal rights.
Personal information may also be disclosed in connection with a proposed or completed business transaction, subject to applicable legal safeguards.
Service providers may use personal information only for the services they provide to us and must protect it through appropriate contractual, administrative, organizational and technical measures.
We do not sell personal information.
11. Processing and storage outside Quebec
Before communicating personal information outside Quebec, we conduct a privacy impact assessment in accordance with applicable legal requirements.
This assessment considers, among other things, the sensitivity of the information, the purpose of the processing, the security measures that will apply, the legal framework applicable in the relevant jurisdiction and the contractual safeguards available.
We implement safeguards appropriate to the sensitivity of the information and the circumstances.
Information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies, regulatory authorities or government institutions in accordance with those laws.
Our service providers remain subject to their contractual obligations to protect the information they process on our behalf.
12. How long do we retain personal information?
We retain personal information collected through our website only for as long as reasonably necessary to process and follow up on your request, manage website communications, maintain appropriate administrative records, comply with legal obligations, resolve complaints or disputes, protect our legal rights and maintain security or confidentiality-incident records.
Appointment requests transferred into the clinic’s administrative or patient-management systems may then be retained according to the clinic’s separate retention policies and applicable requirements.
Appointment requests that are not transferred into those systems are retained only for the period required to process and follow up on the request, in accordance with our retention schedule.
Cookie, analytics and advertising information is retained according to the applicable provider settings, consent choices and retention periods identified in our Cookie Policy.
When personal information is no longer required, we securely destroy or anonymize it in accordance with our retention schedule and applicable requirements.
You may contact our Privacy Officer for additional information about the retention period applicable to a particular category of website information.
13. How do we protect personal information?
We use administrative, physical and technical safeguards appropriate to the sensitivity, purpose, amount, format and location of the personal information we hold.
These safeguards may include access restrictions, role-based permissions, authentication controls, secure transmission methods, encryption where appropriate, system monitoring, backup processes, confidentiality obligations, personnel training, service-provider assessments and incident-response procedures.
No website, electronic transmission method or information system can be guaranteed to be completely secure. We therefore cannot guarantee absolute security.
14. Confidentiality incidents
We maintain procedures to identify, assess, document, contain and respond to confidentiality incidents involving personal information.
Where a confidentiality incident presents a risk of serious harm, we will notify the competent privacy authority and affected individuals as required by law.
We also take reasonable measures to reduce the risk of injury and prevent similar incidents from occurring.
15. What are your rights?
Subject to applicable law and verification of your identity, you may have the right to:
- – Request confirmation that we hold personal information about you
- – Request access to or correction of your personal information
- – Request information about how your personal information has been used or disclosed
- – Withdraw consent where processing depends on consent
- – Change or withdraw your cookie and tracking preferences
- – Unsubscribe from promotional communications
- – Request computerized personal information in a structured and commonly used technological format, where applicable
- – Request deletion, cessation of use or cessation of dissemination where permitted by law
- – Request that certain links be de-indexed or re-indexed where the applicable legal conditions are met
- – Submit a question, concern or complaint regarding our privacy practices
Certain rights may be subject to legal or regulatory restrictions.
We may ask you to provide information reasonably necessary to verify your identity before processing a request. We will respond within the period required by applicable law.
16. Information concerning minors
Our online appointment form must be completed by a person who is 18 years of age or older.
If an appointment request concerns a minor, it must be submitted by the minor’s parent or legal guardian. The parent or legal guardian must ensure that they are authorized to provide personal or health information concerning the minor.
We do not knowingly use personal information concerning minors for personalized advertising.
If we learn that personal information concerning a minor was collected in a manner that does not comply with applicable requirements, we will take reasonable steps to delete it or obtain the required authorization.
17. Third-party websites and services
Our website may contain links to websites, applications, social networks or services operated by third parties.
The privacy practices of these third parties are governed by their own privacy policies and terms. Cliniques Michel Pop is not responsible for the content, security or privacy practices of websites or services it does not operate.
We encourage you to review the privacy information provided by a third party before submitting personal information through its services.
18. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our website practices, technologies, service providers, legal obligations or privacy program.
The date displayed at the beginning of this Policy indicates the date of its most recent revision.
Any change to this Privacy Policy will be the subject of a notice published on our website and communicated by an appropriate means designed to reach the individuals concerned, in accordance with applicable requirements.
The version published on our website is the current version of this Policy.
19. How can you contact us?
Questions, privacy requests, consent withdrawals and complaints may be directed to:
Cliniques Michel Pop Inc.
Attention: Privacy Officer
9001 Boulevard de l’Acadie, Suite 900
Montreal, Quebec H4N 3H5
Canada
Telephone: 1-800-661-6345
Email: [email protected]
Please do not include unnecessary medical information in an initial privacy-related email.
We may contact you to verify your identity or request additional information before responding to a privacy request.
If you are dissatisfied with our response, you may also contact the Commission d’accès à l’information du Québec or another competent regulatory authority.