General Principles

Q-CROC is committed to protecting the privacy of Personal Information. In order to inform Professionals and Members of the Public of the privacy practices put in place, Q-CROC has developed this Privacy Policy, which summarizes the following: (i) the types of Personal Information collected; (ii) the reasons for which Q-CROC collects this Personal Information; (iii) the ways in which Q-CROC uses and protects it; and (iv) the circumstances under which this Personal Information is shared with Q-CROC Partners and with any other third party when required or permitted under applicable laws. This Privacy Policy also describes the decisions that may be made in respect of the collection, access, use and retention of Personal Information. Click on the links below to access the different sections of our Privacy Policy:

Definitions and Interpretation

1. In this Privacy Policy, the following terms, which are capitalized, have the following meanings:

   Application means the progressive Web application (Progressive Web App or PWA) providing a shortcut that can be downloaded on the Member of the Public’s or the Professional’s smart device and that allows direct access to the Site, including the Search Tool and Onco+.

   Cookies means small text files that are placed on the hard drive of devices, where applicable, when a person uses Services, which may either be temporary and disappear when these devices are shut down, or permanent and persist even after these devices have been shut down.

   De-identified Information means Personal Information of which the name or any other identifier has been withdrawn so it may no longer be linked to an individual.

   Member of the Public means any potential patient and other member of the general public seeking information on oncology clinical trials.

   Onco+ refers to the tool developed by Q-CROC for the benefit of Member of the public and Professional, available on the Site and on the Application, under the terms of which Q-CROC or one of its Partners (Quebec Cancer Foundation and CIUSSS de l’Est-de-l’Île-de-Montréal) conducts a search and transmits the result to the Member of the public.

   Other Forms of Technology means any persistent cookie and session cookie, and any other form of software and system that allows data to be collected and retained.

   Personal Information means any information concerning an identifiable individual, including, but not limited to, their family name, first name and email.

   Professional means any health professional duly authorized to practice his or her profession in Quebec.

   Q-CROC means the Consortium de recherche en oncologie clinique du Québec operating under this name or under its acronym (Q-CROC).

   Q-CROC Partners means the business partners directly or indirectly assisting Q-CROC in the development or provision of its Services, including, but not limited to: (i) Quebec Cancer Foundation and CIUSSS de l’Est-de-l’Île-de-Montréal assist Q-CROC with the Onco+ program; (ii) Management Fleexer inc., which has participated in the development of the Site and the Application; (iii) the Mailchimp platform used in connection with the dispatch of newsletters and alerts; (iv) the clouds providers, such as Firebase for the database and hosting, and Agolia for the search infrastructure, which provide server locations and IT and cloud computing platforms for the retention of various information (including Personal Information); and (v) others partners offering complementary services or supporting the development or improvement of the Services as described in Section 3.2, including Google Analytics, Survey Monkey, Mouse Flow and Mailchimp, which provide analytical services.

   Search Tool means the electronic search tool developed by Q-CROC, available on the Site and on the Application, and that assists Professionals and Member of the Public in achieving the permitted purposes.

   Services means the Site, Application, Search Tool and Onco+, and any function and feature that they may include from time to time, as well as any content available from time to time through the said Services.

   Site means the Q-CROC website, available at the following electronic address: www.oncoquebec.com or, thereafter, at any other URL address.

   Web Access means the Internet interface created to give access to the account created for certain groups of Professionals.

   Unless the context requires otherwise, grammatical variations of any defined term herein bear a similar meaning and the singular includes the plural and the masculine includes the feminine, and vice versa.

Collection and use of personal information

In order to provide the agreed-upon Services, Q-CROC will collect and process information about Professionals and Members of the Public. Information will also be collected in the event that they contact Q-CROC in connection with any request, suggestion or comment. Finally, Q-CROC and the Q-CROC Partners will be able to collect information in connection with the use of the Services. In any case, this Personal Information is collected and used only for the sole purposes described in this Privacy Policy.

1. Information obtained directly from Professionals and from Members of the Public
   1. Use of the Search Tool

      Some of the Search Tool’s filters require additional information (e.g.: indicate the relevant city in the case of a search by city), which could qualify as Personal Information. The collection and processing of this information will be required in order to provide relevant results.

   2. Use of Onco+

      Onco+ can be used via the Site or the Application and otherwise (i.e., by telephone). If the Member of the public or Professional chooses to request assistance by filling out an online form (on the Site or the Application), then the Member of the public or Professional will be required to select various filters and provide certain information (e.g., indicate the relevant city in the case of a search by city), which may qualify as Personal Information. The collection and processing of this information will be required in order to provide relevant results. (Note that similar information will be requested if the Member of the Public or Professional uses the telephone service).

   3. Subscription to newsletters and alerts

      When a Professional or a Member of the Public registers to receive newsletters or alerts about oncology clinical trials, he must provide his first name and family name and email address to Q-CROC. This Personal Information is required to enable Q-CROC to send newsletters and alerts to which he has subscribed. Based on the type of publication, such Professional and Member of the Public may have to provide additional Personal Information. It will be brought to their attention before this information is collected, and such Professional and Member of the Public may request at any time to be withdrawn from any mailing list, the whole as more fully set forth below.

   4. Creation of online accounts

      At the request of certain groups of Professionals, user accounts may be created to allow their members to use certain Services (i.e. those allowing access to the professional contact information of colleagues from the same field of practice in order to contact them in connection with the conduct of oncology clinical trials or other aspects within their field).

      In order to create each Professional’s account (and data sheet), the said Professional must disclose to Q-CROC the following Personal Information: first names and family name, and professional email address and cell phone number. This information is required: (i) to create a Web account specific to each Professional; (ii) to create his or her contact form, which may be consulted by other Professionals from the same field of practice; and (iii) to identify the Professional each time he logs into Web Access. A photo may be added to the Professional’s profile at his discretion.

      Each Professional will be responsible for changing his temporary password when he first logs on (for another complex password). Note that the identifier and the password will be correlated to the account and to the Professional’s activities in order to guarantee that his account is interconnected with relevant information.
      In the event that a Professional has trouble logging on or needs to reset his password, he may contact Q-CROC as provided below or reset his password on line. In both cases, it will be necessary to disclose certain information (e.g.: full name and user name, where applicable, if they are not the same) to verify the Professional’s identity and to generate a new password specifically for the account.

   5. Comments, requests for information and for references

      In the event that a Member of the Public or a Professional contacts Q-CROC to obtain information on the Services or on any other subject, such Member of the Public or Professional will be required to provide his contact information (e.g.: name and email address). This information is required to allow Q-CROC to communicate with him and to address requests, comments or inquiries. Such Member of the Public or Professional may also provide additional Personal Information, particularly making comments, requests or suggestions.

      In addition, in the event that a Member of the Public or a Professional recommends that Q-CROC communicate with any other individual in connection with the Services, Q-CROC will then require that individual’s contact information for the above-mentioned purposes; such communication will subsequently be carried out in accordance with the applicable laws.

   6. Client Service

      In the event that a Professional or a Member of the Public contacts Q-CROC’s client service, Q-CROC will then have access to the information communicated or otherwise disclosed by that Professional or Member of the Public, including contact information, as well as any question asked or any comment and remark made. Q-CROC will then collect the required information to (i) categorize the request; (ii) address requests; and (iii) investigate any breach of the Privacy Policy or of its Conditions of Use available on the OncoQuebec website.

   7. Social media

      Q-CROC shares on Facebook information about itself and its Services. Also, any person who sends a message to Q-CROC or “follows” Q-CROC will share (and Q-CROC may consult) information that that person and his “Facebook friends” have published on their page. Since any Facebook user can always choose (through the privacy settings or the Facebook audience selector) who is authorized to consult his Facebook content, he is deemed to have agreed to share his information with his “friends” or with the persons who he “follows,” including Q-CROC, as described in the conditions of use and in Facebook’s privacy policy. Other social media platforms such as Twitter and LinkedIn will also allow any person to follow Q-CROC and to add it to his contact list. In such a case, Q-CROC will have access to such person’s Web pages and profiles in accordance with the selected settings, as more fully detailed in the applicable privacy policies and conditions of use. Q-CROC will also receive a notification and access to any “tweet,” to any link and to any other publication in which Q-CROC is identified. All persons must review the privacy settings applicable to these accounts/pages in order to validate the information to which his contacts have access and limit that access, if necessary. In the event that Q-CROC collects information available on accounts or pages, such collection will be made on an aggregate and anonymized basis and solely for lawful purposes.

   8. New Services

      In the event that additional features are offered in connection with the Services or that the new Services are made available, the collection of additional Personal Information could be required. In such a case, Q-CROC will notify the Professionals and/or Members of the Public concerned of this change in accordance with Section 10 below.

2. Information obtained from the Q-CROC Partners

   The Quebec Cancer Foundation and the CIUSSS de l’Est-de-l’Île-de-Montréal will be asked to collect and process certain Personal Information of Member of the public and Professional who use Onco+. The Quebec Cancer Foundation and the CIUSSS de l’Est-de-l’Île-de-Montréal will share such information with Q-CROC, which may also be required to process such information. The foregoing will occur in order to provide the agreed upon Services to Member of the Public and Professional as described in Section 3.1.2.
   Other partners providing complementary services or supporting the development or enhancement of the Services may also process certain information that constitutes (or may qualify as) Personal Information. For example:

   • Google Analytics can be used to collect data on the interactions of all Professionals and Member of the public with the Services. This information will then be processed and updated each time a Professional or a Member of the Public interacts again with the said Services. For this purpose, Google Analytics will place codes on the Services, which will allow Google Analytics to see the information that was consulted, and the browser, device and the system used. Likewise, Mailchimp may be used to obtain information on the communications sent (including those consulted and the time spent consulting them). The information thus collected may be shared (in whole or in part) with Q-CROC so Q-CROC may update, improve or otherwise optimize the Services or develop new Services.

   • SurveyMonkey, Cognito and Mouse Flow, may be used to collect and process information to improve and/or facilitate registration and login and control access to the Services, the Site and the Application or the Services, the Application and the Site themselves by collecting mouse activity on them.

3. Information collected through Cookies and Other Forms of Technology

   When a Professional or a Member of the Public uses the Services, certain data, including Personal Information (such as the general information on his browser, the Internet Protocol address and the interactions with the Services), may be collected through automated means, such as through the following Cookies:
   Process Cookies: These Cookies allow the Services to work properly (by making it possible to follow up on requests), ensure the integrity of the Web pages and allow Professionals and Members of the Public to browse from one page to the other.
   Security Cookies: These Cookies are used each time a Professional logs in to his account. These Cookies contain an encrypted, unique identifier tied to each account and placed on the browser, to identify Professionals.
   Statistical Cookies: These Cookies collect data, such as the date, time and frequency of use, the pages consulted, the features used, the information provided and the login information (e.g.: Internet protocol address). This information is collected for statistical and analytical purposes, in particular to determine the frequency at which the Services (including certain pages or features) are consulted and used, and what types of functions seem to be the most interesting. This information helps Q-CROC to improve its Services, based on identified needs and interests. Other forms of technology may be used for similar purposes. Cookies and Other Forms of Technology may be blocked, unless they are required for the Services to work properly. As such, though it is possible to block Statistical Cookies, it is otherwise for the Process and Security Cookies, which are essential for ensuring that the Services work properly. However, even though they cannot be blocked without affecting the ability to use the Services, these Cookies are temporary, and will therefore disappear when the browser software is closed or when the electronic devices are turned off. Any person encountering problems with the Services and/or Site features must contact Q-CROC.

Sharing of personal information

Q-CROC does not sell, does not exchange and does not lease Personal Information. In addition, Personal Information is neither shared nor disclosed to third parties, nor used for purposes other than those for which it has been collected, the whole as more fully described herein, unless it is required or authorized by law or unless valid consent has been obtained, if necessary.

1. Personal Information
   1. Sharing carried out in connection with the provision of Services

      Personal Information may be disclosed to Q-CROC Partners who assist or facilitate the provision of Services or their development (for example, Quebec Cancer Foundation which assists Q-CROC with the Onco+ Service). Any disclosure will be limited to those who need to know the information and after being assured that appropriate measures have been put in place.

   2. Transaction or corporate reorganization

      Certain Personal Information may be made accessible to any entity concerned in connection with a transaction or a corporate reorganization, if such communication is necessary to proceed with the sale or any other transaction, and as far as such disclosure is carried out in such a way as to preserve the confidentiality of the Personal Information.

   3. Legal compliance

      Personal Information may be used and disclosed if Q-CROC, acting reasonably, believes that such a use or disclosure is necessary: (i) to comply with the applicable laws, with a legal proceeding or with a government request; (ii) to protect one’s rights; or (iii) to achieve any other objective set forth in the applicable laws authorizing or requiring the disclosure of Personal Information.

2. De-identified and aggregated information

   In connection with the provision of Services, various information (that may qualify as Personal Information) will be collected automatically, then robotically de-identified. This de-identified Information will subsequently be consolidated and used in aggregate form for research and statistical purposes, and to improve and develop the Services. The de-identified Information may also be used, shared or otherwise processed for training purposes and other legally permitted purposes. In all cases, the de-identified Information cannot and will not be used to identify an individual.

Access, correction and removal of personal information

1. General

   In accordance with applicable laws, any Professional and any Member of the Public may make requests to access or correct information by contacting Q-CROC.

2. Professionals with an account

   Any Professional with an account may make access and correction requests with Q-CROC. In this respect, Q-CROC will give access or will update the information in the account (and in the data sheet) as soon as possible and in accordance with the applicable laws. Similarly, Q-CROC will close any account following such a request; in such a case, all the information in connection therewith will be permanently deleted. In doing so and if they so wish, Professionals will have to make sure to obtain a copy of the Personal Information (and of any other information, if necessary) contained in their account.

Security Measures in place

1. Q-CROC uses measures reasonably required in order to maintain the security and confidentiality of the Personal Information. To this end, Q-CROC has in particular implemented the following measures:

   1. Web access:

      Each Professional with an online account will have a unique identifier, which allows for the separation of the information contained therein from that included in the accounts of the other Professionals.

   2. Securing data in transit:

      Every time a Professional accesses the Services, an HTTPS protocol is used to transfer the information from the servers to the mobile devices, and the Secure Sockets Layer (SSL) technology protects the Personal Information using server authentication and data encryption. No access will be possible until this technology is activated, which may be confirmed by observing: (i) the browser toolbar, which will display depending on the browser a padlock on the left of the website address (URL); and (ii) the URL address or the browser address bar, in which the first letters should go from “http” to “https.”.

   3. Limited access:

      Access to Personal Information is given to only employees, Q-CROC representatives (and, if necessary, Q-CROC Partners) who need to know it, and following the implementation of appropriate measures.

   4. Secured data centres:

      The Q-CROC Services are hosted by Amazon Web Services on their servers located in Montreal and in accordance with the high security standards (currently described at: https://aws.amazon.com/compliance/programs/).

2. NOTWITHSTANDING THE FOREGOING, ANY PROFESSIONAL AND ANY MEMBER OF THE PUBLIC MUST KEEP THE FOLLOWING IN MIND:

   1. GENERAL CONSIDERATIONS:

      EVEN IF Q-CROC USES TECHNOLOGIES THAT ARE OF MERCHANTABLE QUALITY AND SUITABLE FOR THE PROVISION OF THE SERVICES, NO ELECTRONIC PLATFORM AND NO ANY SERVER – AS ANY OTHER FORM OF FILE – IS INFALLIBLE NOR FULLY SHELTERED FROM UNFORESEEABLE OR FORCE MAJEURE EVENTS, CYBERATTACKS OR UNAUTHORIZED USES AND ACCESS, AND PROFESSIONALS AND MEMBERS OF THE PUBLIC MUST BE AWARE THAT THERE IS A RISK IN TRANSMITTING ANY DATA ELECTRONICALLY. THIS RISK IS INHERENT IN ALL ELECTRONIC COMMUNICATION AS WELL AS ALL OTHER FORMS OF COMMUNICATION. CONSEQUENTLY, Q-CROC CANNOT GUARANTEE THAT SUCH INFORMATION WILL NEVER BE INTERCEPTED OR VIEWED OR SUBJECT TO OTHER INCIDENTS. FURTHERMORE, EVENTS AFFECTING DEVICES AND SYSTEMS (INCLUDING THOSE LEADING TO THEIR ACCESS AND TO THEIR CONTROL) MAY OCCUR, AND UNDESIRABLE COMMUNICATIONS AND INVITATIONS MAY BE RECEIVED. IN THE EVENT THAT A MEMBER OF THE PUBLIC OR A PROFESSIONAL RECEIVES A COMMUNICATION THAT APPEARS TO COME FROM Q-CROC REQUESTING PERSONAL INFORMATION, HE MUST THEN REFRAIN FROM REPLYING TO SUCH COMMUNICATIONS. Q-CROC WILL NEVER REQUEST THAT SENSITIVE INFORMATION BE COMMUNICATED. IN THE EVENT THAT A MEMBER OF THE PUBLIC OR A PROFESSIONAL HAD COMMUNICATED PERSONAL INFORMATION IN RESPONSE TO AN EMAIL, TO A POP-UP WINDOW OR TO A SUSPICIOUS WEBSITE CLAIMING TO BE AFFILIATED WITH Q-CROC OR IF ONE OF THE PREVIOUS EVENTS MATERIALIZES, Q-CROC WILL NEED TO BE CONTACTED IMMEDIATELY.

   2. Measures to be implemented:

      Professionals with an online account recognize and agree to be responsible to implement and fully comply with all the protection measures and procedures (physical, electronic, technological, organizational, contractual and other) deemed necessary, to ensure the security and to maintain the confidentiality of the accesses and of any information contained in his account. To that effect, such Professionals must in particular: (i) choose a complex password meeting the minimum requirements of the platform; (ii) change their password regularly; and (iii) maintain the security and the confidentiality of their personal identifier and of their password.

Retention of Personal Information

Subject to applicable laws, Q-CROC will retain Personal Information for purposes compatible with this Privacy Policy, as long as necessary to achieve the purposes described herein. In this regard, Q-CROC may retain Personal Information after the specific purposes for which it has been collected has been completed, if it is reasonably necessary: (i) to comply with the applicable laws or to prevent any violation; (ii) to resolve any disputes; and (iii) to ensure that this Privacy Policy is implemented. When this information is no longer required, it will be deleted or retained on an aggregated and anonymized basis.

Third-party Sites and Applications

The Site and the Application may include hyperlinks to third-party sites or applications. In this regard, Q-CROC points out that these hyperlinks are provided only for information purposes and that it does not endorse and has no control over the content or the information to which these hyperlinks expose those who consult them. In so doing, any decision made regarding these sites and applications is at their sole discretion. Q-CROC disclaims any liability in connection with: (i) the content of such sites and applications, including with regard to their accuracy, completeness, currency or readability; (ii) any form of interruption or change in the features of these sites and applications; and (iii) and other element related to these sites and applications. Q-CROC points out the importance of carefully reviewing the conditions of use and privacy policies applicable to these sites and applications.

Contacting Q-CROC

1. Questions, comments and requests

   1. Any questions and comments concerning this Privacy Policy, as well as any request made in connection therewith must be addressed to Q-CROC: 300-917 Mgr-Grandin, Quebec City, Quebec, G1V 3X8, oncoquebec@qcroc.ca, 418-781-0500. Requests and queries made will be handled as quickly as possible.

2. Withdrawal of consent

   In connection with communications to the attention of Professionals and Members of the Public, Q-CROC will opt for the same means of communication as those selected by such Professionals and Members of the Public, who may withdraw their consent to receiving such communications at all times. To do this, they may contact Q-CROC or click on the unsubscribe mechanism provided at the bottom of each email or simply reply to this email with the word “Stop” or “Unsubscribe.”

Amendments to this privacy policy

Q-CROC reserves the right to change or amend this Privacy Policy from time to time. Any material change will be brought to the attention of Professionals and of Members of the public before it takes effect through a Web banner or by any other means. Thereafter, the updated Privacy Policy will be made available and easily accessible. An updated version of this Privacy Policy will also be published every time a minor amendment is introduced therein. Professionals and Members of the Public may know if this Privacy Policy changed by looking at the effective date displayed thereabove. Q-CROC recommends that this Privacy Policy be reviewed periodically in order to be aware of current practices, and since the continuous use of the Services will be deemed to constitute an acceptance of any amendment made thereto. If a Member of the Public or a Professional disagrees with such amendment, he must then immediately cease or abstain from accessing or using the Services.