ᐅᕙᑦᑎᓄᑦ ᐃᓚᐅᓚᐅᕆᑦ
ᐅᕙᑦᑎᓂ ᐱᓇᓱᑦᑎᐅᖃᑕᐅᓚᐅᕆ
ᐅᖓᕙᒥ ᑐᓚᑦᑕᕕᒃ ᖃᓄᐃᖏᓯᐊᕐᓂᒧᑦ

ᓇᐅᓕᒫᓄᑦ ᖃᐅᔨᔭᐅᒋᐊᖃᖏᑐᓄᑦ ᒪᓕᒐᖅ

1. General Information

1.1 Introduction


Privacy is important to the Ungava Tulattavik Health Center (hereinafter « CSTU », « we », « our »). In terms of application, we have implemented safeguards and practices for the sound management of your personal information in accordance with applicable laws.

This Privacy Policy (the « Policy »), which should be read in conjunction with the Terms and Conditions of Website Use and Services Agreements with CSTU, describes our practices regarding the collection, use, processing, communication and retention of the Personal Information of our customers, visitors and users.

By using our website http://www.tulattavik.com (the « Website ») or one of our Services, you agree that we may collect, use, process, disclose and retain your Personal Information in accordance with the conditions described herein. If you do not agree to abide by and be bound by this Policy, you are not authorized to visit, access or use our c or our Services, or share your Personal Information with us.


This Policy does not apply to Personal Information of CSTU employees, representatives and consultants, or any other person affiliated with CSTU, or any information that does not constitute Personal Information as defined by applicable law.


1.2 Responsible For The Protection Of Personal Information


    Questions, comments and complaints regarding CSTU's Privacy Policy and practices may be directed to our Privacy Officer at the following coordinates:


    Email : jfarteau@kesserwan.com

    Address : P.O. Box 149, Rue Kigiak, Kuujjuaq (Québec) J0M 1C0


      2. Definitions

        The following words and expressions, when they appear with a first capital letter in the Policy, have the meaning attributed to them below, unless there is an implicit or explicit derogation in the text:


        « Service provider » : any natural or legal person who processes data on behalf of CSTU. These are third party companies or individuals employed by CSTU to facilitate the Services, to provide the Services on behalf of CSTU, to perform Services-related services, or to assist CSTU in analyzing the use of the Services.


        « Personal information » : any information which relates to a natural person and allows him to be identified, i.e. which directly or indirectly reveals something about the identity, characteristics (e.g. skills, preferences , psychological tendencies, predispositions, mental capacities, character and behavior of the person concerned) or the activities of this person, and this whatever the nature of the medium and whatever the form in which this information is accessible (written, graphic , sound, visual, computerized or other).


        « Personal Information Protection Officer » : the person in charge of the application of this Policy and whose contact details are identified in section 1 of this Policy.


        « Services » : Services means the website and all related services offered by CSTU, which includes professional services and, where applicable, associated media, printed materials and “online” or electronic documentation.

        3. Processing Of Personal Information

        3.1 Collection Of Personal Information


          As part 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, your address, your e-mail address and your telephone number;
          • professional or employment-related information, such as your resume, criminal history information, and other information you provide to us when applying for employment at CSTU;
          • information relating to products or services, such as information concerning the services we have provided to you;
          • information relating to products or services, such as information concerning the services we have provided to you;
          • transaction and payment information, such as 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, when you fill out a form, respond to surveys or communicate with one of our employees or representatives;
            • log information and other information about your activities on the Website, such as your IP address, the pages you visited, the time and date of your visits, the type of browser you use, the system of operating your device and other hardware and software information;
            • geolocation data, such as your IP address, a precise or approximate location determined from your IP address or the GPS of your mobile device (depending on your device settings).


          In each case, such personal information is processed in accordance with the legitimate and necessary purposes listed in Article 3.2 below.


          3.2 Disclosure Of Personal Information


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

            • operate, maintain, supervise, develop, improve and provide all the functionality of our Website;
            • provide Services to you;
            • develop new Services and improve our Website and our Services;
            • send you messages, updates, security alerts;
            • for marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;
            • answer your questions and provide you with assistance as needed;
            • administer a contest, promotion, survey or other feature of the Website or our Services;
            • collect opinions and comments relating to our Services;
            • conduct research and analysis in connection with our business and our Services;
            • detect and prevent fraud, error, spam, abuse, security incidents and other harmful activities;
            • send you communications as required by law;
            • for any other purpose permitted or required by law.

            Please note that we do not use the information we collect to draw any inferences or interpretations.


            3.3 Service Providers and Other Third Parties


              We may share your Personal Information with our employees, contractors, consultants, agents, Service Providers and other trusted third parties who need the information to help us operate our Website, perform and protect our business activities or serve you, provided that these 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, except as permitted by law.


              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 analytics. , hosting and data storage. We have defined below the cases in which such sharing can take place:

                • We use Google Analytics to analyze the audience of the Platform and Google Drive to store our documents. See their privacy policy;
                • We use the services and platforms of the Beauvoir agency for hosting the Site; and
                • We use the services and platform of the firm iCims for the collection and storage of references, criminal records and other documents related to the hiring of employees.


                When we communicate your Personal Information to Service Providers, we enter into written contracts with them before your Personal Information is communicated to them and we only provide them with the Personal Information necessary to carry out their mandate. As part of these contracts with our Service Providers, we agree that the principles set out in this Policy will be respected, and these Service Providers are required to use Personal Information as we direct and only for the purposes for which they were provided. In addition, these Service Providers offer us sufficient guarantees as to the implementation of adequate protection measures that are proportional to the sensitivity of the Personal Information processed or communicated. When our Service Providers no longer need your Personal Information, we ask them to destroy this data in an appropriate manner.


                3.3.2 Compliance with Laws, Responding to Legal Requests, Preventing Harm and Protecting Our Rights


                  We may disclose your Personal Information when we believe such disclosure is permitted, 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 those of third parties;
                  • to allow us to pursue available remedies or limit the damages that we may sustain; and
                  • in compliance with the laws in force which are applicable, including laws outside your country of residence.


                  3.3.3 Commercial transaction


                  We may share, transfer or communicate, in strict accordance with this Policy, your Personal Information in the event of a legislative change or during certain commercial transactions involving CSTU. In this case, we will notify you before your Personal Information is transferred and becomes governed by another privacy policy.


                  3.3.4 Consent of Personal Information


                  Where possible, CSTU obtains consent directly from the individual concerned for our collection, use and disclosure of their Personal Information. However, if you provide us with Personal Information about other people, you must ensure that you have duly notified them that you are providing us with their information in addition to having obtained their consent to such communication.


                  We will seek your express consent before using or disclosing your Personal Information for purposes other than those set out herein.


                  3.3.5 Retention of Personal Information


                  Subject to applicable laws, we keep your Personal Information only for the time necessary to achieve the purposes for which this information was collected, i.e. for the duration of the employment relationship of the employees who provided the Information and during the period necessary for their preservation at the time of the termination of an employee's employment, 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 5 years following the end of the employment relationship of a CSTU employee. In addition, our retention periods may be changed from time to time due to legitimate interests (for example, to ensure the security of Personal Information, to prevent abuse and breaches or to prosecute criminals).


                  To obtain more information on the periods during which your Personal Information is kept, please contact our Personal Information Protection Officer using the contact information provided in section 1.2 of this Policy.


                  4. Your Rights

                    As a data subject, you can exercise the rights set out below by completing the form available here and sending it by email or by post to the attention of our Personal Information Protection Officer at the coordinates provided in Section 1.2 of the Policy:

                    • You have the right to be informed of the Personal Information that we hold about you and to request a paper copy of the documents containing your Personal Information, subject to the exceptions provided by applicable law;
                    • You have the right to have the Personal Information we hold about you rectified, modified and updated if it is incomplete, ambiguous, outdated or inaccurate;
                    • You have the right to withdraw or modify your consent to CSTU collecting, using, disclosing or retaining 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 attached to your name that gives access to this information if this dissemination violates the law or a court order;
                    • You have the right to request that your Personal Information be communicated to you or transferred to another organization in a structured and commonly used technological format;
                    • You have the right to lodge a complaint with the Commission d'accès à l'information, subject to the conditions provided for by 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 the services we offer. Cookies are small text files that are stored on your device or in your browser. They collect certain information when you visit the Website, including your preferred language, browser type and version, type of device you use, and unique device identifier. If some of the Cookies we use are deleted after the end of your browser session, other Cookies are stored on your device or on your browser in order to allow us to recognize your browser when you next visit the Website. The data collected through these Cookies is not intended to identify you. In particular, they make it possible to guarantee the functioning of the Website, to improve the browsing experience of users and provide certain data that allow us to better understand the traffic and interactions that take place on our Website as well as to detect certain types of frauds. Cookies do not cause any damage to your device and cannot be used to extract your personal information.


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


                      6. Security Measures

                        CSTU has implemented physical, technological and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft or any unauthorized access, disclosure, reproduction, communication, use, modification. These measures include, but are not limited to, encryption, access control, segregation of duties, internal audit, etc.


                        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 details provided in Section 1.2 above.


                        7. Changes To This Privacy Policy

                          We reserve the right to modify this Policy at any time in accordance with applicable law. If there are any changes, we will post the revised Privacy Policy and update the updated date in the footer of the Privacy Policy. We will also notify you by email at least thirty (30) days before the effective date of the new version of our Policy. If you do not agree with the new terms of the Privacy Policy, we invite you to no longer use our Website and our Services. If you continue to use our Website or our Services after the new version of our Policy takes effect, then your use of our Website and our Services will be governed by this new version of the Policy.


                          8. Links To Third-Party Websites

                            From time to time, we may include on our Website references or links to websites, products or services provided by third parties (the « Third Party Services »). These Third Party Services, which are not operated or controlled by CSTU, 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 the services we offer. The Policy does not extend to Third Party Services.

                            9. 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 must not provide your Personal Information to us without your parent's or guardian's consent. If you are a parent or guardian and become aware that your child has provided Personal Information to us without consent, please contact us using the contact details set out in Section 1.2 above to request that we delete that child's Personal Information.

                            10. Contact Us

                              Any questions, comments, requests or concerns regarding this Privacy Policy should be directed to our Privacy Officer at the contact information provided in Section 1.2 of this Policy.