Privacy Policy
Clinique de Santé Respiratoire des Sommets
Last Updated: May 4, 2026
This Privacy Policy describes how your personal information is collected, used, and shared when you visit www.csrsommets.ca (the “Site”), make a purchase through the Site, or use our clinical services. This Policy is governed by the Act to modernize legislative provisions respecting the protection of personal information (Law 25) and any other applicable laws in Québec.
TABLE OF CONTENTS
- Privacy Officer
- What Information Do We Collect?
- How Do We Process Your Information?
- What Legal Bases Do We Rely On to Process Your Information?
- When and With Whom Do We Share Your Personal Information?
- Do We Use Cookies and Other Tracking Technologies?
- Is Your Information Transferred Internationally?
- How Long Do We Retain Your Information?
- How Do We Protect Your Information?
- Do We Collect Information from Minors?
- What Are Your Privacy Rights?
- Do-Not-Track Features
- Do We Update This Notice?
- How Can You Contact Us About This Policy?
1. Privacy Officer
- Name: Kathleen Longpré
- Title: Privacy Officer
- Email: info@csrsommets.ca
- Phone: 1-877-744-0416
2. What Information Do We Collect?
We collect the personal information that you voluntarily provide to us when you register on our website or during your visits to our clinic, express an interest in obtaining information about us or our products and services, participate in activities on our website or at our clinic, or otherwise contact us.
Information You Voluntarily Provide
- Names
- Phone numbers
- Email addresses
- Mailing addresses
- Usernames
- Passwords
- Billing addresses
- Debit/credit card numbers
Sensitive Information
Where necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
Payment Information
We may collect information necessary to process your payments if you make purchases, such as your payment method number and the associated security code. All payment information is stored by Stripe, PayPal, Apple Pay, and Google Pay. You can review their privacy policies here: Stripe, PayPal, Apple Pay, and Google Pay.
Health Information (Sensitive Information)
As part of our clinical services (sleep apnea diagnosis and treatment), we may collect health information considered sensitive, including:
- Test results (Epworth Sleepiness Scale, sleep studies)
- Medical diagnoses and prescriptions
- Treatment-related information (CPAP devices, respiratory therapies)
- Information collected through our Juvonno patient portal
This health information is subject to enhanced security measures and is used solely for the purpose of providing healthcare services, with your explicit consent.
Information Collected Automatically
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data: IP address, device information, browser type and settings, timestamps, pages and files viewed, searches, and other actions performed within the Services.
- Device Data: IP address, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system.
- Location Data: Information about your device’s location. You may disable location collection through your device settings.
Information Collected from Other Sources
To enhance our ability to provide you with relevant advertising, offers, and services, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, social media profiles, and customized profiles for the purpose of targeted advertising and event promotion.
3. How Do We Process Your Information?
We process your personal information for various reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication, and to manage user accounts.
- To provide and facilitate the delivery of services to users.
- To respond to user inquiries and provide support.
- To send you administrative information (details about our products and services, changes to our terms and policies).
- To process and manage your orders, payments, returns, and exchanges.
- To request feedback regarding your use of our Services.
- To send you marketing and promotional communications, where consistent with your preferences. You may unsubscribe at any time.
- To deliver targeted advertising tailored to your interests and location.
- To protect our Services, including fraud monitoring and prevention.
- To identify usage trends and improve our Services.
- To protect an individual’s vital interests, such as preventing harm.
4. What Legal Bases Do We Rely On to Process Your Information?
We only process your personal information when we believe it is necessary and we have a valid legal basis to do so under applicable law, whether with your consent, to comply with legal obligations, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to pursue our legitimate business interests.
If you are located in Canada, we may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission may be inferred (implied consent). You may withdraw your consent at any time.
In certain exceptional circumstances, we may be legally permitted to process your information without your consent, including:
- If the collection is clearly in an individual’s best interest and consent cannot be obtained in a timely manner.
- For investigations and the detection and prevention of fraud.
- For business transactions, subject to certain conditions.
- If the information is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
- For the identification of injured, ill, or deceased persons and communication with next of kin.
- If we have reasonable grounds to believe that an individual has been, is, or may be a victim of financial abuse.
- If disclosure is required to comply with a subpoena, warrant, court order, or court rules relating to the production of records.
- If the information was produced by an individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was produced.
- If the collection is solely for journalistic, artistic, or literary purposes.
- If the information is publicly available and specified by applicable regulations.
5. When and With Whom Do We Share Your Personal Information?
We may share your information with vendors, third-party service providers, contractors, or agents who perform services for us or on our behalf. We have contracts in place with these third parties designed to help protect your personal information. They are not permitted to do anything with your personal information unless we have instructed them to do so, and they will not share it with any other organization.
The third parties with whom we may share personal information include:
- Advertising, direct marketing, and lead generation: ActiveCampaign, Google AdSense, and Facebook Audience Network
- Remarketing platforms: Google Ads Remarketing, Google Analytics Remarketing, and Facebook Remarketing
- Social media sharing and advertising: Facebook Ads and Facebook Social Plugins
- Web and mobile analytics: Google Analytics, Google Tag Manager, and Hotjar
- Patient portal and clinical records: Juvonno
We may also share your personal information in the following situations:
- Business transfers: in connection with a merger, sale of company assets, financing, or acquisition of all or part of our business by another company.
- When we use Google Maps Platform APIs (e.g., Google Maps API, Places API).
- If required by law, subpoena, search warrant, or to protect our rights.
We do not sell your personal information to third parties.
6. Do We Use Cookies and Other Tracking Technologies?
We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information.
During your first visit to our website, a consent banner allows you to accept, reject, or customize the use of non-essential cookies. You may modify your preferences at any time through this consent management tool.
You may also opt out of targeted advertising through the following links:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Digital Advertising Alliance: https://optout.aboutads.info/?c=3&lang=en
7. Is Your Information Transferred Internationally?
Our servers are located in the United States and Canada. If you access our Services from outside Canada, please be aware that your information may be transferred to, stored, and processed by us in our facilities, as well as by the third parties with whom we share your personal information (see Section 5), in the United States, Canada, and other countries.
For more information about Google’s privacy practices, please visit: https://policies.google.com/privacy. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
8. How Long Do We Retain Your Information?
We retain your personal information for the following periods:
- Order information: as long as necessary for accounting and legal purposes, generally 7 years.
- Health records: in accordance with Québec legal requirements (minimum 5 years for adult patient medical records).
- Browsing data and cookies: according to the settings of each tool (e.g., Google Analytics retains data for 26 months by default).
At the end of the applicable retention periods, your personal information is securely destroyed or anonymized.
9. How Do We Protect Your Information?
We implement appropriate security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction, including:
- Encryption of payment data (SSL/TLS protocol)
- Restricted access to health information, limited to authorized personnel only
- Use of secure platforms for the management of clinical records (Juvonno)
In the event of a privacy incident presenting a risk of serious harm, we will notify you and the Commission d’accès à l’information du Québec, in accordance with Law 25.
However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. Do We Collect Information from Minors?
We do not knowingly collect data from children under the age of 18 or market our services to them. By using the Services, you represent that you are at least 18 years old, or that you are the parent or legal guardian of a minor and consent to that minor dependent’s use of the Services.
If we become aware that personal information has been collected from users under the age of 18, we will deactivate the account and take reasonable measures to promptly delete such information from our records. If you become aware of any such data, please contact us at info@csrsommets.ca.
11. What Are Your Privacy Rights?
In accordance with Law 25 and applicable Québec laws, you have the following rights:
- Right of Access: to access the personal information we hold about you.
- Right to Rectification: to have inaccurate or incomplete personal information corrected or updated.
- Right to Erasure: to request the deletion of your personal information, subject to applicable legal retention requirements.
- Right to Data Portability: to receive your personal information in a structured, commonly used technological format.
- Right to Withdraw Consent: to withdraw your consent at any time where consent is required (e.g., marketing communications).
- Right to File a Complaint: with the Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca).
To exercise any of these rights, please contact our Privacy Officer at info@csrsommets.ca. We will respond to your request within 30 days of receipt.
12. Do-Not-Track Features
Most web browsers, as well as some mobile operating systems and mobile applications, include a Do-Not-Track (“DNT”) feature or setting that you can activate to indicate your privacy preference regarding online tracking. At this time, no uniform technological standard for recognizing and implementing DNT signals has been finalized.
As a result, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we are required to follow in the future, we will inform you of that practice in a revised version of this Policy.
13. Do We Update This Notice?
We may update this Privacy Policy from time to time to reflect changes in our practices or to comply with new legal requirements. The date of the latest update is indicated at the top of this document. If we make material changes, we will notify you by email or by posting a notice on our Site.
14. How Can You Contact Us About This Policy?
For any questions, requests, or complaints regarding this Policy or the protection of your personal information, please contact:
- Privacy Officer: Kathleen Longpré
- Email: info@csrsommets.ca
- Phone: 1-877-744-0416
- Website: www.csrsommets.ca
If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec: www.cai.gouv.qc.ca.