Privacy and Personal Information Protection Policy

Last updated: August 22, 2023

This policy describes how Clinique Juste (“Juste”, “we”) collects, processes, uses, stores and discloses personal information and personal data. in the course of its activities (the “Policy”).

This Policy applies in particular to information collected about users or visitors (“you”) through the website operated by Juste (the “Website “), but also applies to information that is by other means, as more fully detailed below.

Acceptance of the Policy

Your use of our Website signifies your acknowledgment, acceptance and consent to our Policy and you adhere to the terms and conditions displayed on the Website. If you do not accept this Policy, please do not continue to use our Website. Your use of our Website signifies your acceptance of these terms and any changes in effect at the time of use. By submitting your information, you agree that it is governed by our Policy.

The data we collect

Information that comes from you

We collect information provided by you (for example by filling out a form) through the Website interface or otherwise. In this Policy, the term “Personal Information” means any information that concerns an individual and that allows that individual to be identified. For example, Personal Information may include:

  • Your first and last name;
  • Your email address;
  • Your address, telephone number;
  • Your photography;
  • The content you upload to the Website;
  • Comments left on the Website;
  • All information transmitted to Juste by email or telephone;
  • Information collected during a conversation or other exchange with a member of our team.

Data collected by technological means

Data collected automatically

We collect certain information automatically when you log in to the Website. Data collected automatically includes certain information about your computer or mobile device as well as data about your interaction with the Website, including operating system, browser type, mobile device make and model, IP address, data relating to the path traveled on the website.

The data collected automatically is not associated with your identity by Juste.

Data from analysis tools

When you access the Website, we collect certain data from analysis tools such as Google Analytics. This data may include, for example, gender, age, and interests. This data is not associated with you personally and is transmitted to us in aggregate form.

Data from social networks

We collect information transmitted by social networking sites or applications (Facebook, LinkedIn, Twitter, YouTube, Google+, etc.) when you interact with profiles we have on these social networking sites or applications. These sites or applications are also governed by their own policies relating to your personal information which may be different from ours and could be applicable.

Your data collection options

Many of the data collected automatically by Juste are collected through processes that can be modified from your browser. You can modify your browser settings to disable the recording of digital markers such as browsing cookies or cookies from third-party sites. You can also use the “Do Not Track” header on your browser to indicate your desire not to share data.

Purposes and means by which Personal Information is collected

How is your Personal Information used?

The processing of Personal Information by Juste serves the following purposes:

  • We need to process certain Personal Information in order to be able to provide services to our customers and potential customers.
  • We process certain Personal Information when necessary to meet our legitimate interests and those of our partners, when the processing does not adversely affect the fundamental rights of the individuals concerned.
  • We process Personal Information for any purposes agreed to by you.

Your Personal Information will be used only for the purposes for which it was collected in accordance with any applicable law, including in relation to the required form of consent.

Communication with you

We use the Personal Information you provide to us to communicate with you about our products and services, but only if you have provided us with your contact information and if you have consented, expressly or tacitly, to receive communications from us.

Perform analyzes on Website traffic

We use data collected automatically, in an aggregated form that does not allow data to be associated with a particular person or mobile device, to perform analyzes of Website traffic.

Collaboration with our partners

We process certain data that is collected through the Website to meet our legitimate interests and those of our partners, in particular with a view to entering into partnerships and contracts with our partners based on the use of certain data collected by the through the Website.

We take the privacy of our visitors seriously, and therefore processing Personal Information based on our legitimate interests never involves specific, targeted surveillance of an identifiable individual.

There may be links from our Websites to other websites; Please note that this Policy applies only to our Website and not to the websites of other companies or organizations to which our Website may be linked. You should check and ensure that you read the privacy policies of the operators of the linked websites. These links to third party websites are provided for your convenience and information purposes only. Juste does not endorse and is not responsible for these linked websites or their policies regarding the retention, use and destruction of your Personal Information.

To whom is your Personal Information communicated?

We only share your Personal Information as described in this Policy or when we have obtained your consent. Your Personal Information may be communicated to the categories of people described below for the purposes mentioned.

Employees

The Personal Information collected is only accessible to our managers and employees who must access it to make the use provided for in this Policy, for example when you report an adverse event, complaint or request for access to Personal Information or in the context of of a service request.

Service Providers

Certain Personal Information may be accessible to service providers that allow us to serve our customers more effectively. We do not sell your Personal Information and we do not allow our service providers to use your Personal Information on an individual basis. Our suppliers are held to the same level of protection of Personal Information as us and they undertake in writing to us to preserve the confidentiality of the data and not to use it other than to provide us with services.

Legal obligations

We may disclose Personal Information collected to third parties if expressly authorized or required by law, or if we are required to do so by any competent authority, law, regulation, warrant, subpoena or court order. . We may disclose Personal Information in the context of legal proceedings if this is necessary to protect our rights or those of our users.

How is your Personal Information stored?

We retain the Personal Information collected until you ask us to destroy it or when our activities or purposes no longer require us to retain it. By consenting to this Policy, you consent to the retention of your Personal Information. We ensure that we keep your Personal Information in accordance with the legislative provisions in force.

The Personal Information collected is stored electronically, on servers operated by our service providers who are held to the same level of protection of Personal Information as we are and undertake to us to use security measures in order to preserve the integrity and data confidentiality. Furthermore, under agreements entered into between Juste and its external service providers, your Personal Information may also be hosted and/or transferred to and stored on other servers located outside your jurisdiction, where protection laws Personal Information may not provide similar or adequate protection to that in your jurisdiction. By consenting to this Policy, you consent to such transfer, hosting and retention of your Personal Information.

Transfer of information outside Quebec

Personal Information collected about individuals located outside of Canada is transferred to Canada.

Data security

Security measures have been put in place with respect to our services and programs to protect the loss, misuse and alteration of the information under our control. Please note, however, that no data security measures can be guaranteed to be completely effective. Therefore, we cannot certify or guarantee the security of your Personal Information or other data we hold. You transmit Personal Information and other data to us at your own risk. In accordance with applicable laws, we have implemented a privacy incident log.

Rights of access, rectification and withdrawal of consent, right to be forgotten and right to portability

Access and rectify your data

In accordance with applicable laws regarding the protection of Personal Information:

  • You have the right to ask us if we hold Personal Information about you and to obtain a copy if necessary; and
  • You have the right to rectify inaccurate, incomplete or equivocal Personal Information or if its collection, communication or retention is not compliant or authorized under the Act respecting the protection of personal information in the private sector, RLRQ , vs. P-39.1, you can demand that they be rectified.

To have access to the Personal Information that we hold about you or to modify certain Personal Information that we hold about you that is incorrect, you can make a request to us in writing to the address of the data controller indicated at the end of this policy.

We will respond to your request quickly (maximum within 30 days of receipt).

Withdrawal of consent

If you wish to withdraw your consent at any time to the processing and storage of your Personal Information, please notify us by writing to us at info@juste.org.

Upon receipt of notice of revocation of your consent, we will stop retaining your Personal Information within a reasonable period of time, which will vary depending on the Personal Information we collected and the purpose for which we collected it.

Please note that if you continue to use the Website, it will not be possible to prevent the processing of your Personal Information. The only way to stop any processing of your Personal Information is not to visit the Website and not to communicate with Juste.

Please note that, in certain circumstances, we may refuse a request to delete your Personal Information, for example when the Personal Information is necessary to comply with the law, a contractual agreement between the parties or in the context of a claim .

Opposition

In certain circumstances, you have the right to object to our processing of your Personal Information to meet legitimate interests. Your rights in this regard depend, among other things, on your place of residence. To object to the processing of your Personal Information, you can write to us at info@juste.org.

Deletion

In certain circumstances, you may request deletion of the Personal Information we hold about you. To make such a request, please write to us at info@juste.org. We will respond to your request as soon as possible (maximum 30 days after receipt) and we will destroy your Personal Information in accordance with any applicable law.

If you continue to visit the Website or if you contact Juste again, we will collect certain Personal Information about you.

Right to be forgotten

If the release of your Personal Information (i) contravenes the law or a court order, or (ii) seriously harms your reputation or privacy, you may request in writing from our Privacy Officer personal information that we restrict the distribution of your Personal Information or that the hyperlinks associated with your name and which provide access to your Personal Information are deindexed (i.e. removed from search results). Our Privacy Officer will respond to the request in writing within 30 days of receipt, unless applicable government authorities extend the time frame within which we must provide our response.

Right to portability

Upon written request from you, we will communicate to you, in a structured and commonly used technological format, any Computerized Personal Information that we have collected from you. This communication may also, at your request, be made to a person or organization authorized to collect your Personal Information.

Complaint

If you reside in the territory of the European Union, you have the right to lodge a complaint regarding the processing of your Personal Information with a privacy law enforcement authority. This authority varies depending on your country of residence.

If you reside outside the territory of the European Union, this Policy is governed by the laws and regulations applicable in Canada and the Canadian authorities have exclusive jurisdiction to receive any complaint or claim based on this Policy or on the processing of your Personal Information by Juste.

Checks

We reserve the right to verify the identity of people wishing to access Personal Information concerning them. Any information collected to carry out this verification will not be used for any other purpose.

Responsible for the protection of personal information and contact in the event of a complaint

If you have questions or concerns regarding this Policy, the processing of Personal Information concerning you, if you wish to exercise your rights or if you wish to file a complaint, please contact Sophie Tremblay, responsible for the protection of personal information directly. , by email at info@juste.org.

The Privacy Officer is also responsible for, among other things, approving the privacy governance policies and practices that we are required to establish and implement and participating in conducting assessments of the factors relating to privacy (“PIA”) when required by law.

Please note that we will endeavor to respond to your questions, concerns or complaints as quickly as possible.

If we discover that our security measures have been breached and that there is a real risk of harm to you, we will contact you, unless prohibited by law.

We expressly acknowledge that we will not use your Personal Information for any other purpose without your consent. Additionally, we will only collect Personal Information to the extent necessary for the above purposes.

Policy Change

We may modify this Policy from time to time to reflect changes in our Personal Information management practices and to comply with applicable legislative provisions. In the event that a modification is made, the new Policy will be available at the following address: www.juste.org.

We will notify individuals who have provided their Personal Information to us by email of a material change to this Policy.