Privacy policy
Last update : July 10, 2024
In accordance with the Act respecting Access to documents held by public bodies and the Protection of personal information (CQLR, c. A-2.1), the Université de Sherbrooke for the Quebec Pain Research Network (collectively “QPRN,” “we” or “our”) implements means to protect data, personal information and non-personal information regarding the Users of the Quebec Pain Registry Website (https://quebecpainregistry.com/) (hereinafter individually and collectively referred to as “Information”). This privacy policy governs the privacy practices of the QPRN with respect to our use of your Information (the “Privacy Policy”) and namely aims to inform you about:
• What types of security procedures are in place to protect your Information;
• What Information we collect from you;
• How we use your Information and with whom we may share it;
• What are your choices regarding the collection, use and distribution of Information;
• How you can access and/or rectify inaccurate Information;
• How is your Information stored and destroyed.
For your information, this Privacy Policy applies only to Information collected by the QPRN as part of your use of the Website. This Privacy Policy does not apply to any Information collected online or offline by any other entity, whether or not that entity is affiliated with the QPRN.
If not defined in this Privacy Policy, all capitalized terms in this Privacy Policy have the definition ascribed to them in the Terms of Use of the Website.
Security
The Information obtained in relation to your use of the Website shall be kept in secure places and on controlled servers belonging to Université de Sherbrooke for and on behalf of the QPRN, and which are located on the premises of Université de Sherbrooke or at the offices of third-party service providers of QPRN.
In order to protect any Information we collect, we have put in place physical, electronic and administrative measures to prevent any unauthorized access to or disclosure of your Information, including in particular the following measures:
• DKIM, SPF, DMARC and other specific DNS settings
• TLS/SSL/DANE encryption (START)
• Website strengthening/security features/connection security
• Vulnerability detection
• Monthly website updates
• Antivirus and firewalls
• Security measures for equipment containing or processing personal data.
Although we take all reasonable measures to protect the Information you share with us, no transmission of Information via the Internet can be 100% guaranteed and Information stored electronically is never completely immune from attack and therefore we cannot guarantee the security of any Information you provide to us.
All privacy settings applicable to your use of the Website provide, by default, the highest level of privacy, without any intervention on your part.
Please note that any use of technology to identify, locate or profile you is disabled by default and such technology will only be enabled with your express consent.
Security Incidents
The QPRN keeps an up-to-date register of all known security incidents, as defined in the Act respecting Access to documents held by public bodies and the Protection of personal information (CQLR, c. A-2.1), that may affect the security or confidentiality of your personal information. If an incident presents a risk of serious harm being caused to you, the QPRN will take the necessary measures to notify you, subject to the applicable legislative provisions. The assessment of the risk of harm is based on the sensitivity of the information concerned, the apprehended consequences of its use and the likelihood that it will be used for harmful purposes.
Your Information
Information linked to the use of The Website
The QPRN may use your Information to optimize the functionality and modules of the Website and to generate anonymized Website usage statistics. Among other things, we collect the following non-personal information about your use of the Website:
• Date and place of use;
• Frequency of use;
• Average duration of use; and
• Language preference
The QPRN uses the services of Matomo to collect, compile and analyze non-personal information, specifically aggregated and anonymous statistical data, in order to better understand how The Website is used. This data is used in particular to monitor and analyse the use of The Website, to improve its functionality and to select more accurately the content and graphic design, all with a view to meeting Users’ expectations. We invite you to consult Matomo’s privacy policy.
Information linked to the online forms of The Website
In order to better understand and respond to the needs of Website Users, and also to offer you certain personalized services, the QPRN collects your Information when you explicitly share it with us through our online forms. Among the Information collected through the online forms, there may be personal information that are collected to offer you certain QPRN Services, which make it possible to identify or contact you (e.g.: First and last name, e-mail address, phone number, address).
The QPRN will never communicate or use this Information for purposes other than those for which it was collected without first obtaining your express consent in this regard.
We may also disclose your Information if we believe that we must do so under any applicable law in Canada and Quebec, to comply with a legal process or a government request, to apply the Terms of Use of the Website and/or to protect the rights, property or safety of the QPRN, its Users, partners or the public.
The QPRN may use your Information for purposes of study, research or statistics, only insofar as an assessment of the factors relating to privacy has previously been completed in accordance with the provisions of the Act respecting Access to documents held by public bodies and the Protection of personal information (CQLR, c. A-2.1), (hereinafter the “PPIA”).
Access, portability and rectification right
The PPIA sets the terms and conditions for access and portability as well as the procedures for rectification of your personal information. Only authorized members of the QPRN staff or that of its partners and authorized suppliers have access to it. Some of this personal information is communicated only in the cases provided for by the PPIA.
The QPRN undertakes to provide an access, portability and rectification right to persons wishing to review, extract, modify or eliminate Information about themselves.
The Privacy Officer is also responsible for ensuring compliance with the PPIA.
To make comments or a request regarding the application of the PPIA, please contact the Privacy Officer whose name and contact details are described at the very end of this Privacy Policy.
Your Information and the Website
You do not need to send us any Information to use the Website. We may, however, collect Information about our Users at various locations on the Website. If you choose to provide us with Information about yourself, we may provide you with information about products, services and/or events that may be of interest to you.
Cookies
A cookie is a small data file stored on a User’s device by a web server. Cookies are used to help us identify you when you return to the Website in order to adapt the information you receive when you browse the Website. Cookies make it possible to obtain non-personal information allowing the QPRN to better understand the profile of Users as well as their behaviour through the Website. We use functional cookies to ensure that our site functions properly:
• WPML uses cookies to identify the visitor’s current language, the language last consulted and the language of Users who have logged on. No data relating directly to the User will be shared.
• Complianz, to collect and record consent based on browser and device. For this functionality, your IP address is anonymised and stored in our database. This service does not process any personally identifiable information and does not share any data with the service provider.
• Elementor facilitates website design through a user-friendly drag-and-drop interface, offering a variety of customizable templates and widgets
• Wordfence is the most popular WordPress firewall and security scanner, protecting over 5 million websites worldwide from attackers targeting WordPress. Wordfence Free includes an endpoint firewall and malware scanner built from the ground up to protect WordPress.
• Gravity Forms is a WordPress plugin that allows site owners, admins, and developers to create simple and complex forms to collect information on their WordPress site and then decide what to do with that information
Storage
We only keep your Information for the time necessary to fulfill the purposes for which it was collected, all in accordance with the current schedules for records retention of Université de Sherbrooke. Subsequently, the Information shall be destroyed in a secure and confidential manner, subject to the provisions of the Archives Act (CQLR, c. A-21.1).
Your choices regarding disclosure and changes to your Information
If you do not want your Information to be used as described in this Privacy Policy, please stop using the Website. Even if you cease your use of the Website in accordance with the foregoing and subject to the provisions of the aforementioned PPIA, the Information may remain in the QPRN database and/or in the servers of its authorized suppliers, including, in particular, Université de Sherbrooke.
Note, however, that the QPRN may, from time to time, anonymize your personal information to use it for purposes of public interest and then continue to use it at its sole discretion.
Modifications to the Privacy Policy
We reserve the right to modify this Privacy Policy at any time and without notice. You can verify if this Privacy Policy has been modified and updated by referring to the “Last Update” date indicated at the top of this document. In any case, your continued use of the Website after any modification of the Privacy Policy shall constitute your acceptance of such modification.
Third Party Websites
The QPRN is not responsible for the personal information that is collected, used or disclosed by any Third Party Website and the QPRN expressly disclaims any responsibility related to such collection, use, disclosure or retention.
Contact us
You can contact the QPRN at any time for any complaint or question related to your Information. For any complaint or other question concerning your Information or the application and interpretation of this policy, you may contact the QPRN Privacy Officer at the following email address:
c/o: Erwan Leclair, Privacy Officer
QUEBEC PAIN RESEARCH NETWORK
2500 boulevard de l’Université
Sherbrooke, QC J1K 2R1
(the “Privacy Officer”)
Email: info@qprn.ca
