Privacy Policy
1.Background
With the development of digital technologies, it is essential to pay special attention to the protection of personal data and privacy. That is why the Group of Caregivers of the Southwest (GASO), headquartered at 7475 Newman Boulevard, Office 405 (H8N 1X3), in the Borough of LaSalle, in the Province of Quebec, Canada (hereinafter referred to as "GASO" or "we"), is seriously concerned about the privacy of personal information of caregivers using our services (hereinafter referred to as "User" or "you").
This policy (hereinafter referred to as the "Policy"), for the protection of personal information, describes: The information that GASO may collect and from whom;
How we use and share your information and with whom;
Situations where we need or do not need your consent;
Your rights regarding your information and how to exercise them;
Our security measures for your information;
Other terms and conditions accompanying this policy;
How we may make changes to this policy;
How to contact us if you have a question, comment, or request.
GASO is committed not to collect, use or disclose your personal information except in accordance with this Policy and the applicable laws of Canada and Quebec.
Please read this Policy and our General Terms of Use carefully to understand our policies and practices regarding your personal information. If you do not agree with our policies and practices, you must discontinue using our platform. By accessing or using this platform, you indicate that you understand, accept, and consent to the practices described in this Policy.
The Policy may be modified from time to time. If you continue to use this Platform after we have made changes to the Policy, you indicate that you accept and consent to these changes. Whenever possible, we will inform you in advance of any major changes to the Policy.
2.Scope of the Policy
This Policy applies to the information we collect, communicate, store, and otherwise process about you:
On our website (https://gaso.ca), our social media pages, accounts, networks, or any applications they contain, designed and operated by GASO (hereinafter the "Platform").
In emails, texts, forms, and other electronic communications between you and this Platform.
Through the recording of video calls, phone calls, or discussions with GASO employees.
When you interact with our forms, advertisements, and applications on third-party websites and services, if these forms, applications, or advertisements contain links to this policy.
The Platform may include links to third-party websites, plugins, services, social media, or applications. Clicking on these links or activating these connections may allow third parties to collect or share information about you. If you follow a link to a third-party website or activate a third-party plugin, please note that these third parties have their own privacy policies, and we have no responsibility for the privacy practices and policies of the third parties. We do not control these third parties and encourage you to read the privacy policy of each third party you visit carefully.
Be aware that you can obtain more information about our practices and withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice, by contacting our Privacy Protection Officer at protection@gaso.ca. However, without your consent, GASO may no longer be able to provide you with the Platform or requested services.
Finally, if you provide GASO or third parties with personal information concerning another person, you agree that you have the necessary authorization to do so and/or have obtained all necessary consents from those third parties to allow us to process them in accordance with the Policy.
LEGAL INFORMATION
PUBLISHER
Group of Caregivers of the Southwest (GASO)
7475 Newman Blvd., #405, LaSalle (H8N 1X3)
Quebec, Canada
HOST
Wix.com,
40 Namal Tel Aviv St.,
Tel Aviv 6350671, Israel
3.Collection of Personal Information
A personal information is information specifically associated with a natural person and that can be used to identify them, either directly or indirectly, that is by arranging it with other information held by GASO or its third-party providers.
GASO may obtain personal information when you save your personal information on the Platform or, if applicable, by otherwise transmitting your personal information, in particular by creating a User account and choosing a password, opening a session as a registered User on the Platform, requesting a service, providing information in your account, or by contacting us by phone, email, or otherwise.
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed of any changes to your personal information. The law gives you the right to request access to the personal data we hold about you and to correct them.
We collect the following information from you:
Names and first names;
Age;
Gender;
Telephone number;
Home address;
Email address;
Location;
Login information;
Authentication information;
Browsing information and behavior.
If you are employed, we also collect the following information:
Bank details;
Social insurance number;
Employment history.
If you are a therapist, we also collect the following information:
ID card;
Date of birth;
Fax;
Copy of diplomas;
References;
CV;
Employment history;
Immigration status in Canada;
Work permit;
Membership in a professional order;
Civil or judicial proceedings against you;
Professional proceedings against you;
Criminal charges against you;
Suspension or removal by an organization, association, or professional order against you.
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Persons from whom this personal information is collected:
User personal information may be collected:
Directly from you through forms and communications, namely:
Platform registration form;
Contact form;
Postal communications;
Email communications;
Your member area on the GASO Platform;
Phone;
Opinion survey;
Through connection cookies;
Through our payment providers.
The legal basis for GASO's processing of User data may be one or more of the following:
User consent;
When necessary to fulfill GASO's legal obligations;
When necessary to perform a contract between the User and GASO or before concluding it at the request of the User;
When necessary to safeguard the User's vital interests or those of a third party; or
When based on a legitimate interest, such as:
Ensuring the security of the Platform, its network, and data;
Preventing fraud;
For commercial prospecting operations with the User; or
For internal administrative management purposes.
For more information on the protection of your personal information and your related rights, you can contact the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec.
Office of the Privacy Commissioner of Canada (www.privcom.gc.ca)
Commission d'accès à l'information du Québec (www.cai.gouv.qc.ca)
4.Use and Sharing of Your Personal Information
Purposes of using personal information
We collect User personal information for the following reasons:
Creation, use, and management of User accounts on our Platform;
Providing uninterrupted service;
Understanding Platform usage;
Securing the Platform;
Analyzing and improving the User experience;
Communicating with the User;
Developing, improving, marketing, or providing the Platform and our services;
Sending offers and promotions tailored to Users;
Maintaining backups of our databases and retaining records;
Preventing fraud;
Protecting the public and other Users;
Establishing, exercising, or defending legal actions, whether in the context of legal proceedings or in the context of administrative or extrajudicial proceedings for the protection and assertion of our legal rights, your legal rights, and the legal rights of others;
Complying with applicable laws and regulations.
Sharing personal information
GASO places particular importance on the sharing of personal information. Here are the situations where the personal information may be shared with our partners, websites, or third-party integrations on or using our Platform and for law enforcement or legal requests.
The categories of persons to whom User information may be transferred are as follows:
Payment providers, to process User payments;
Verification service providers, to verify User identities;
IT service providers, to ensure Platform operation and security;
Analytics service providers, to improve the Platform;
Professional liability insurance service providers (paying insurers) in cases of ethical breaches or fraud;
Service providers allowing compliance with applicable laws and regulations;
Partners, government agencies, and regulatory authorities, judicial bodies, professional orders, associates, agents, lawyers, or other representatives for compliance with legal obligations to which we are subject or for the establishment, exercise, or defense of rights in legal proceedings, whether in the context of judicial proceedings or administrative or extrajudicial proceedings;
To any other person as permitted and/or required by law.
User understands that GASO may at any time share its personal information during a partial or full transfer of its business to a third party. In such a case, the information transferred as GASO's assets will be subject to the same guarantees as those of this Policy.
If the User does not want their personal information shared with third parties or partners, they may object at any time by contacting us.
5.Situations where We Need or Do Not Need Your Consent
We only use your personal data with your consent or within the limits allowed by law. We obtain your consent to collect, use, and disclose your personal information when:
You request a service;
We need to use your information for a different purpose than the one for which you have already consented;
You interact with us.
However, we do not obtain your consent for every interaction with you. For example, if we use your personal information for a purpose related to the one for which you originally gave consent. In addition, we do not obtain your consent in certain situations provided by law, to:
Comply with a court order or any other binding request;
Assert a claim;
Investigate a breach of contract or a violation of the law;
Prevent, stop, or detect fraud.
6.Your Rights Regarding Your Information and How to Exercise Them
Your main rights under personal information protection law are as follows:
The right of access;
The right to rectification;
The right to de-indexing;
The right to restrict the processing of personal information;
The right to object to the processing of personal information;
The right to data portability;
The right to lodge a complaint with a supervisory authority; and
The right to withdraw your consent.
You have the right to obtain confirmation of whether or not we process your personal information and, if so, to access that information, as well as certain additional information. This additional information includes details about the purposes of the processing of personal information, the categories of personal information concerned, and the recipients of the personal information. To the extent that the rights and freedoms of others are not affected, we will provide you with a copy of your personal information. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
In certain circumstances, you have the right to request the erasure of your personal information within a reasonable period. These circumstances are as follows: the personal information is no longer necessary for the purposes for which it was collected or otherwise processed; you withdraw your consent to personal information processing based on consent; you object to the processing of personal information under certain applicable personal information protection rules; the personal information is processed for direct marketing purposes; the personal information is processed unlawfully. However, there are exceptions to the right to erasure. General exclusions include cases where the processing of personal information is necessary for:
The exercise of the right to freedom of expression and information;
Compliance with a legal obligation; or
The establishment, exercise, or defense of legal claims.
It is important that the personal information we hold about you is accurate and up to date. Please inform us of any changes related to your personal information that we hold about you.
If you wish to review, verify, correct, or withdraw your consent to the use of your personal information, you can also email us at protection@gaso.ca to request access, correction, or deletion of the personal information you have provided us. We can only delete your personal information by also deleting your user account and/or personal file. We may not comply with a request to change information if we believe this change would violate a law or legal obligation or make the information incorrect. We may charge you fees for accessing your personal information, but we will inform you of these fees in advance.
You have access to some of your personal information and can modify it in your member area on the Platform. Additionally, we will provide access to your personal information, subject to exceptions provided by applicable privacy legislation. Here are some examples of these exceptions:
Information protected by professional secrecy;
Information that is part of a formal dispute resolution process;
Information about another person that would reveal their personal information or confidential business information;
Information where the cost of providing it is prohibitive.
If you are concerned about our processing of personal information or wish to correct the information you have provided us, you can contact our Privacy Protection Officer at the following address: protection@gaso.ca
Right to Withdraw Your Consent
Where you have given your consent to the collection, use, and transfer of your personal data, you may have the legal right to withdraw your consent in certain circumstances. To withdraw your consent, if applicable, contact us at protection@gaso.ca. Please note that if you withdraw your consent, we may not be able to provide you a particular service.
Requests Related to Your Personal Information
We may ask you for specific information to help us confirm your identity and your rights under applicable laws, and to provide you with the personal information we hold about you or make the changes you requested. Once you have asserted your rights regarding personal information, we will process your request within 30 days, or longer if required by law. If the period exceeds 30 days, you will be informed.
Applicable privacy laws may allow or require us to deny you access to all or part of the personal information we hold about you, or we may have destroyed, erased, or anonymized your personal information in accordance with our obligations and practices regarding personal information retention. If we cannot provide you with access to your personal information, we will communicate the reasons to you, subject to legal or regulatory restrictions.
7.Security and Retention of Your Personal Information
Security
The personal information collected by GASO is kept in a secure environment. GASO has implemented appropriate measures to preserve the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, disclosure, reproduction, use, or modification, taking into account, in particular, its sensitivity and the purposes for which it is used. Furthermore, GASO requires each employee, agent, or representative of GASO to adhere to this Policy.
To ensure the security of User personal information, GASO uses, among other measures, the following:
SSL Protocol (Secure Sockets Layers);
Secure access to offices, servers, and computers;
ESET Endpoint firewall and antivirus;
Use of password-protected data networks;
Confidentiality agreements with employees;
Canadian server.
GASO is committed to maintaining a high level of security by integrating the latest technological innovations to ensure the confidentiality of User transactions to protect their personal data and prevent them from being accessed, used, or disclosed without authorization.
However, as no mechanism offers maximum security, a degree of risk is always present when using the Internet to transmit personal information. If a password is used to protect your User account and personal information, it is your responsibility to keep it confidential.
GASO maintains an up-to-date privacy incident register and will contact any User whose personal information is involved in such an incident posing a risk of serious harm.
Retention
User personal information will not be retained beyond the reasons for which it was collected. GASO complies with personal information retention periods in accordance with the Personal Information Protection Act. Personal data are stored as long as they are useful for their collection purpose.
Please contact our Privacy Protection Officer at protection@gaso.ca for more details on personal information retention periods.
8.Other Terms and Conditions Accompanying This Policy
Antispam
GASO complies with the requirements of the Canadian Anti-Spam Legislation (CASL). The user understands that they may explicitly or implicitly consent to receiving messages from GASO.
To unsubscribe from our electronic communications mailing list, simply click the "Unsubscribe" button at the top of our electronic messages. Please note that whenever we send a mass mailing, we give you the option to unsubscribe from our mailing list.
Automated Decision Making
GASO does not process any personal data in an automated manner, and we do not use your personal data for automated decision-making purposes.
Minors Under the Age of 18
Our Platform and services are not intended for individuals under the age of 18. No one under the age of 18 may provide data to or on the Platform without parental consent. If you are under 18, do not use or provide data on this Platform or through any of its features. Do not register on the Platform, use the interactive or public comment features of this Platform, and do not provide us with any information about yourself, including your name, address, phone number, email address, or username you may use.
Furthermore, if we learn that we have collected or received personal information from minors under the age of 14 without parental consent, we will delete that information. If you believe we have data about someone under the age of 14, please contact us at protection@gaso.ca.
Applicable Law
This Policy is governed by the applicable laws of Quebec and Canada. These laws apply without giving effect to any conflict of laws principles.
Severability
Each provision of this Policy forms a separate whole so that any court decision to the effect that any provision of this Policy is null or unenforceable does not in any way affect the validity of the other provisions of this Policy or their enforceable nature.
9.Changes to This Policy
We occasionally update this Policy. The continued use of the Platform constitutes the User's agreement to this Privacy Policy and its updates. If we make significant changes to how we treat our users' personal data, we will notify you by email at the address provided in your account or through a notice on the Platform's home page.
However, when the Consumer Protection Act applies, GASO will notify thirty (30) days before the modifications come into effect to the Platform's Users. If the User refuses these changes and wishes to terminate the contract, they will have no later than thirty (30) days following the entry into force of the changes to transmit a notice to GASO and resolve, without charge or penalty, their obligations to GASO.
10.How to Contact Us
You can exercise the rights provided in this Policy or address any other questions or complaints regarding GASO's practices in relation to personal information protection by contacting us at:
By mail at:
The Group of Caregivers of the Southwest (GASO)
Privacy Protection Officer
7475 Newman Boulevard, Office 405, LaSalle H8N 1X3
Quebec, Canada
By email: protection@gaso.ca
We have put procedures in place to receive and address complaints or inquiries about our personal information processing, our compliance with this policy, and applicable privacy laws. To discuss our compliance with this Policy, please contact our Privacy Protection Officer using the contact information provided above.
11.Effective Date
This Policy comes into effect upon its adoption by the board of directors.
Upon adoption, this policy repeals previous decisions on confidentiality and personal information protection.
Adopted by the Board of Directors at a regular meeting held on October 16, 2023.