Last update : September 29,  2022

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 My Pain Management Portal (the “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 Portal. 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 Portal, accessible through the following hyperlink:

The Information obtained in relation to your use of the Portal shall be kept in secure places and on controlled servers belonging to Université Laval for and on behalf of the QPRN, and which are located on the premises of Université Laval or at the offices of third-party service providers of the 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:
• SSL (Secure Sockets Layer) protocol;
• Access management—authorized person;
• Computer backup;
• Username and password;
• Firewalls.
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 Portal 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.

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.

In order to better understand and meet the needs of the Users of the Portal, the QPRN collects your Information when you use the Portal. Among the Information we collect, there may be personal information that makes it possible to identify or contact you. Such Information is only collected when consent has been previously obtained from Users. Some of your Information may be “sensitive” in nature, including medical or otherwise intimate information, and may give rise to a high degree of reasonable expectation of privacy. The QPRN undertakes to process this “sensitive” Information with increased diligence, in particular by ensuring that it never communicates or uses this “sensitive” Information for purposes other than those for which it was collected without first obtaining your express consent in this regard. Among the Information we collect, we also collect the following non-personal information about your use of the Portal:

• The date and place of use;
• The frequency of use; and
• The average duration of use.

The QPRN may also collect any other Information about you from its third-party service providers and partners, in particular those that have entered into a service agreement with the QPRN for the provision of the Portal. For example, the QPRN also uses the services of Google and Google Analytics to collect, compile and analyze non-personal information, more specifically aggregated and anonymous statistical data in order to better understand how the Portal is used. This data is used mainly to monitor and analyze the use of the Portal, improve its functionalities and choose more precisely the content and graphic design, all in order to meet the expectations of Users.

The QPRN may use your Information in several ways, including in particular:
• For marketing purposes, improving the Portal, optimizing the functionalities and modules of the Portal; and
• To generate anonymized statistics on the use of the Portal.
In addition, we use your Information to allow us to operate the Portal and provide you with the QPRN Content, the QPRN Services and, more generally, appropriate information resources related to pain management.
The QPRN may hire external companies to provide services on its behalf (e.g.: to host the Portal or analyze anonymized data). We may provide your Information to those service providers so that they can perform such services, and you agree that the QPRN may share such Information for such purposes.
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 Portal accessible through the following hyperlink: 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”).

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 personal information about themselves.
The Privacy Officer is also responsible for ensuring compliance of 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.

You do not need to send us any Information to use the Portal. We may, however, collect Information about our Users at various locations on the Portal. 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.

The Portal may from time to time use cookies and other similar technologies in order to better recognize you when you return to the Portal. 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 Portal in order to adapt the information you receive when you browse the Portal. 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 Portal. You are always free to block cookies if your device allows it, for example by installing an add-on to your web browser, but this could prevent you from accessing certain parts of the Portal.
Our web pages or email messages may contain small graphic images called “web beacons” (also sometimes called a “pixel tag”) which allow us to track and collect certain limited information about Portal Users, such as the type of device requesting the web beacon, the IP address of the device to which the web beacon is transmitted, and when the web beacon was viewed. Web beacons may be invisible to the User, but in general any electronic image seen as part of a web page or email, including HTML content, may act as a web beacon. We may use web beacons to count the number of visitors to the Portal or to track the browsing habits of Portal Users, and we may include web beacons in emails in order to count how many messages have actually been opened or have elicited a response.
We use cookies and web beacons to compile a set of statistics about our Portal; we do not link the Information collected by our web beacons to the personally identifiable information you provide to us while using the Portal.

When you visit the Portal, we may collect and store log files, more specifically certain non-personally identifiable information such as: the domain name, the host from which you access the Internet, the IP address of the device you are using, the browser software you are using, your operating system, the date and time you access the Portal, the Internet address of the website from which you have accessed the Portal, the website you visit when you leave the Portal and the number of “clicks” you have made on the Portal.
We collect this information to analyze trends, manage the Portal and gather broad demographic information for global purposes. We may also determine the technology available by your browser in order to provide you the most appropriate version of the Portal. We may also use the Information collected about our Users to deliver customized content, advertisements, products and services or to improve content, navigation on the Portal or for any other internal purposes.

We only keep your Information for the time necessary to fulfill the purposes for which it was collected, all in accordance with Université Laval current schedules for records retention. 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).

If you do not want your Information to be used as described in this Privacy Policy, please stop using the Portal. Even if you cease your use of the Portal 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 Laval.
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.

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 Portal after any modification of the Privacy Policy shall constitute your acceptance of such modification.

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.

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
2500 boulevard de l’Université
Sherbrooke, QC J1K 2R1
(the “Privacy Officer”)