How We Collect Information

We may collect Personal Information from the following sources :

• Directly from you

• Automatically, from devices used to access the Website

Information We Collect

Personal Information collected may include:

• Contact information

• Internet Protocol address

• Other information you, as applicable, choose to provide

How We Use Information

We use Personal Information we collect to:

• Contact you to confirm your Study eligibility

• Analyze the use of and improve the Website

• Comply with applicable laws and our policies

How We Share Information

We may share Personal Information:

• To comply with applicable law; or

• As otherwise required or permitted under applicable law

1. Introduction

We are committed to protecting the privacy of Personal Information, and take the protection of data privacy very seriously. In this regard and in order to bring to your attention the privacy practices implemented, we have prepared this Privacy Policy, which summarizes: (i) the types of Personal Information collected, (ii) why we do it, (iii) how we use and protect it, and (iv) under what circumstances it could be shared when required or permitted under applicable law. This Privacy Policy further describes the decisions that can be made with respect to the processing of your Personal Information. Click on the links below to jump to the different sections of our Privacy Policy:

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• Definitions and Interpretation

• Collection and Use of Personal Information

• Sharing of Information Collected

• Security

• Storage of Personal Information

• Accessing, Correcting and Deleting Personal Information

• Third-Party Websites

• Contacting us

• Changes to Privacy Policy

2. Definitions and interpretations

2.1    Definitions. In this Privacy Policy, the terms set forth below have the following meanings:

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• Cookies designates the small text files that are placed on devices when using/accessing the Website.
   

• Personal Information means any information about an identifiable individual, such as your name and contact information (e-mail and phone number) and Internet Protocol address.
   

• Study refers to the Study entitled “COLCHICINE CORONAVIRUS SARS-CoV2 TRIAL (COLCORONA)” commonly referred to as the ColCorona Study.
   

• We (or similar words) designates the Montreal Heart Institute, a corporation duly constituted under Part III of the Companies Act, CQLR c C-38 and located at 5000 Belanger Street, Montreal (Quebec) H1T 1C8 CANADA.
   

• Website means the website available at https://www.colcorona.net/ or any other URL, as may be applicable from time to time.
   

• You means any individual located in a country, province or territory where the Study is conducted, who has reached the age of majority in such jurisdiction and who either wish to be part of the Study /or to navigate on the Website to learn more about the Study.

2.2    Interpretation. Unless the context requires otherwise: (i) grammatical variations of any term defined herein have a similar meaning; and (ii) words importing the singular number shall include the plural and words importing the masculine gender shall include the feminine and neutral genders and vice versa.

3. Collection and use of personal information

This Website has been developed to assist in identifying a maximum number of potential Study participants. Should you use the Website to establish a first contact with our Study staff, then you will need to disclose a limited amount of Personal Information. Other information may also be collected directly from you or by automated means when you use the Website, as further described below.   In all cases, such Personal Information is only collected and used and processed for the purposes detailed in this Privacy Policy, and will not be used/processed for a different or incompatible purpose without your knowledge and, where required by law, consent.

3.1    Information obtained directly from you

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3.1.1    Voluntary communication by you to participate in the Study

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The Website provides initial information about the Study that we are sponsoring and for which we are looking for participants. In this regard, the main feature of the Website is its e-mail feature allowing you to send us an e-mail request to be re-contacted by one of our Study staff to confirm your eligibility, should you be interested in taking part of the Study. In such a case, you will be required to disclose only that information (namely, your name, phone number and e-mail) required for such staff to re-contact you. You may provide additional information (such as any message), which facultative information will be reviewed as well by our staff if provided. Your coordinates (and other information, if any) will only be used for that purpose.

Such staff will then re-contact you by phone or by e-mail (to schedule a call). During that conversation, such staff will provide you with additional and comprehensive information about the Study, and will confirm your Study eligibility. In order to determine whether you can be part of the Study, some additional Personal Information will be collected about you during that call with your consent. The Personal Information verbally disclosed during that call will only be processed by us for that purpose.

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3.1.2    Comments and requests for information

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Should you contact us to obtain information about the Study or about any other matter, then you will be required to provide your contact information (e.g. names and e-mail). This information is required by us in order: (i) to categorize the communication; (ii) communicate with you; and (iii) either determine whether the Study is performed in your geographic area and respond to you enquiries about the Study, or otherwise process the request (e.g. investigate any breach of the Privacy Policy or other applicable terms and conditions)or response to your questions/comments.

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3.1.3    Social media

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We share information about ourselves and our Study on Facebook. Similarly, if you send or accept our “friend request” or otherwise “follow” us, then you will share the information that you and your “Facebook friends” posted on their Facebook pages and we may consult it. Since Facebook users can always choose the audience that can see what they share via their Facebook privacy settings or the Facebook audience selector, you will be considered as having agreed to share such information with your “friends” or persons you “follow” as described in Facebook privacy policy and terms of use. Should we collect information available on social media accounts or pages, we will do so on an aggregate and de-identified basis and for lawful purposes only. Note that our intended use of social media is not to learn, be added by or to follow patients, but rather to learn more about potential participants’ pools, to identify prospective jurisdictions, and to assess the interests of the population.

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3.2    Information collected using Cookies and similar technologies

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When you use the Website, certain information, including Personal Information (such as general browser information, Internet Protocol addresses, the interactions with the Website and any other information described below) may be collected by automated means, such as through the following types of Cookies:

• Process Cookies: allow the Website to work properly ensuring the integrity of web pages and allowing you to browse from one page to the other;

• Preference Cookies: allow our Website to remember information that changes the way it behaves or looks;

• Statistical Cookies: collect data, such as the date and time when the Website were last used and the frequency of such uses, the pages or content consulted and the manner the Website was used, the information provided and the features of their operating systems and connection information (e.g. Internet Protocol address). This information is collected for analytical and statistical purposes, such as to determine for the purposes set forth in point 3.3 below.
   

Other forms of technologies can also be used for similar purposes.
 

Cookies and other forms of technologies can be blocked. Anyone experiencing problems with the functionalities of the Website should contact us. You can take the following steps to block Cookies and other forms of technologies: (i) for Google Analytics, click here; (ii) for Hotjar cookies, click here; likewise, some web browsers may be configured to send 'Do Not Track' signals to the websites that you visit. While there is no consensus among industry participants as to what 'Do Not Track' means in this context, the Website – like many websites – does not alter practices when a 'Do Not Track' signal is received from a visitor's browser. To find out more about 'Do Not Track', please click visit here. Because we link to social media sites (as mentioned below), and which from time to time may include third-party advertisements, other parties may collect your personally identifiable information about your online activities (e.g. your IP address) over time and across different web sites when you visit the Website.  Please note that not all tracking will stop even if you delete Cookies.

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3.3   Information obtained from Google Analytics and Hotjar Ltd

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Google Analytics can collect data about the interactions with the Website. Such information will then be processed and be updated every time you (or any person) interact with the Website, which will allow Google Analytics to see which information was consulted, the browser used, device and operating device. The statistical and other aggregated information so collected may be shared (in whole or in part) with us in order for us: (i) to update, upgrade or otherwise improve the Website, or to develop new features; and (ii) to help us to know how many users we have, which parts of our Website are most popular, what browsers are used, the country or region where our users are located, and the demographics and interests of our users (so we can maximize compatibility). This enables us to better understand who is using our Website and to improve it. Google Analytics cookies may retain information for up to two years. For more information about Google Analytics services, please click here.

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Likewise, we use Hotjar cookies from Hotjar Ltd to help us better understand how you (and other persons) use the Website and how we can improve the Website through a range of tools such as heat maps, feedback polls and surveys. For more information, click here.

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4. Sharing of information collected

We do not sell, trade or otherwise share Personal Information. Furthermore, Personal Information is not shared, used or disclosed to third parties for purposes other than those for which it was collected as described herein, unless required or authorized by law or unless proper consent was obtained, as applicable.

4.1    Personal Information

Personal Information may be used and disclosed if we, acting reasonably, believe that such use, disclosure or other process is necessary to comply with applicable laws, legal process or governmental request, or is otherwise required to protect our rights or to fulfill any other purpose set forth in the applicable law allowing or requiring the disclosure of Personal Information, including disclosures:  (i) to enforce the Privacy Policy; (ii) to respond to claims that any information you provide violates the rights of third parties; (iii) to protect the rights, property, or personal safety of us, our users and/or the public; or (iv) in relation to the merger or other form of reorganization of the health and social services in the Province of Quebec. 

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4.2    Anonymized Information used on an aggregated basis

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Personal Information and/or other information may be anonymized and added to a consolidated dataset, that we may process on an aggregated basis: (i) for research purposes; (ii) for Website improvement; and (iii) for training, promotion and statistical purposes and as applicable any other lawful purposes. In any event, note that anonymized information cannot and will not be used to re-identify or re-contact any person. 

5. Security

5.1    Measures implemented. We use measures as may be reasonably required to preserve the security and privacy of Personal Information, such as the following measures:

• Securing data: Hyper Text Transfer Protocol (HTTPS) and Transport Layer Security (TLS) technologies are used, which can be confirmed by looking (i) at the address bar which will, depending on the browser, have a lock to the left of the website address (URL), and (ii) at the URL or the address bar of the browser, where the first characters of the address in that line should change from “http” to “https”.

• Limited access: Access to any Personal Information is granted only to our Study staff on a “need-to-know” basis.

• Secured datacenters: The Website is hosted by Wix, which states that its web hosting services are secure, reliable and compliant with the highest international standards, as further detailed and confirmed here.

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5.2    LIMITATION. DESPITE THE FOREGOING, ANY ELECTRONIC PLATFORMS AND SERVERS – AS WITH ANY OTHER FORM OF FILE – IS NOT INFALLIBLE AND FULLY SHELTERED FROM UNFORESEEABLE OR FORCE MAJEURE EVENTS, CYBERATTACKS OR UNAUTHORIZED USES AND ACCESS. ANYONE SHALL BE AWARE THAT THERE IS A RISK IN TRANSMITTING ANY DATA ELECTRONICALLY, WHICH IS INHERENT IN ALL ELECTRONIC DEALINGS, AS WELL AS TO ALL OTHER FORMS OF COMMUNICATIONS. CONSEQUENTLY, WE CANNOT GUARANTEE THAT INFORMATION WILL NEVER BE INTERCEPTED OR VIEWED OR SUBJECT TO OTHER INCIDENTS. SUCH EVENTS MAY OCCUR, PURSUANT TO WHICH DEVICES OR SYSTEMS CAN BE ACCESSED OR CONTROLLED BY UNAUTHORIZED PERSONS, AND UNDESIRABLE COMMUNICATIONS AND INVITATIONS MAY BE RECEIVED. SHOULD YOU OR ANY PERSON RECEIVE A COMMUNICATION THAT LOOKS LIKE IT IS FROM US ASKING FOR PERSONAL INFORMATION, YOU (OR SUCH PERSON) SHALL AVOID RESPONDING TO SUCH COMMUNICATIONS. WE WILL NEVER REQUEST FINANCIAL AND OTHER SENSITIVE INFORMATION THAT WAY. IF ANYONE HAS CONCERNS ABOUT THE SAFETY AND SECURITY OF PERSONAL INFORMATION, OR HAVE COMMUNICATED PERSONAL INFORMATION IN RESPONSE TO A SUSPICIOUS E-MAIL, POP-UP OR PHONY WEBSITE CLAIMING TO BE AFFILIATED WITH US OR IF ANY OF THE FOREGOING EVENTS TAKES PLACE, PLEASE CONTACT US IMMEDIATELY.  YOU HAVE TO KEEP IN MIND THAT THERE IS NO SUCH THING AS PERFECT SECURITY.

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5.3    EXCLUSION/LIMITATION OF LIABILITY. UNLESS PROHIBITED UNDER APPLICABLE LAWS, UNDER NO CIRCUMSTANCES SHALL WE BE LIABLE FOR ANY DIRECT OR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR OTHER DAMAGES THAT MAY ARISE FROM A CLAIM OF BREACH OF THIS PRIVACY POLICY.  Some jurisdictions do not allow the exclusion or limitation of liability for consequential, incidental or other damages. In such jurisdiction, our liability is limited to the greatest extent permitted by law, or to $1,000, whichever is less, unless the foregoing is prohibited in which case said limitation will be inapplicable in that case (but applicable and enforceable to the fullest extent legally permitted against any person and/or in any other circumstances).

6. Storage of personal information

Subject to applicable laws, we will retain and store Personal Information for use and disclosure consistent with this Privacy Policy, as long as necessary for the purposes detailed herein (and for the period required under applicable laws if you are enrolled in the Study as confirmed during your call with our Study staff), following which it will be deleted. Should you decide not to be part of the Study (or not be eligible) then all Personal Information collected will be deleted. Despite the foregoing, we may retain Personal Information after the specific purpose for which it was collected has been fulfilled if reasonably necessary: (i) to comply with applicable laws or prevent any contravention; (ii) to resolve disputes; and (iii) to enforce this Privacy Policy. Once no longer required, the information will either be erased or stored on an aggregated and anonymized basis.

7. Accessing, correcting and deleting personal information

In accordance with applicable laws, you may make requests for access or rectification with respect to the Personal Information collected and stored by (or via) the Website as set forth above by contacting us. We will not discriminate against you for making any request of access or otherwise exercising any of your rights under applicable laws. Please note that we may be required or permitted by law to not delete (or allow deletion) of Personal Information, for instance should you be eligible and decide to be part of the Study. We will respond to all legitimate requests within the period of time set forth under applicable laws.

8. Third-party websites

Should any link to third-party websites be provided on the Website for convenience or information purposes, then you shall be aware that these sites operate independently and are subject to distinct terms of use and privacy policies, and shall not be seen as affiliated to us. In both cases, it is strongly recommended that you review the distinct terms of use and policies of such third-party websites, as we have no control over and are not responsible for the content or practices of any such websites.

9. Contacting us

9.1    Questions, comments and requests

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All questions and comments regarding this Privacy Policy or requests made in furtherance of said policy should be directed to us by one of the following means:
 

5000 Belanger Street, Montreal (Quebec) H1T 1C8 CANADA

Attn. David Rhainds

E-mail: david.rhainds@icm-mhi.org

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Requests and demands made will be dealt with as soon as possible.

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9.2    Withdrawal of consent

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We may communicate with you for the purposes set forth herein. We will generally use the same means of communication you used to contact us or the preferred means specified by you. You can withdraw applicable consent at any time by clicking on the ready-to-use “unsubscribe” mechanism provided at the bottom of each e-mail or simply reply to that communication with the word “STOP” or “Unsubscribe” or similar wording.

10. Changes to this privacy policy

We reserve the right to change or modify this Privacy Policy from time to time. Any material change will be notified prior to the change taking effect via a web banner or by any other means reasonably bringing them to your attention, while those requiring an express consent, if any, will be made in a format allowing you to provide such consent. Thereafter, the Privacy Policy as updated will be made available and easily accessible. Furthermore, an updated version of this Privacy Policy will be published each time a minor change is made. Finally, we reserve the right to update and amend this Privacy Policy without prior notice to reflect legal and regulatory changes or additional requirements. Anyone may determine whether this Privacy Policy has changed by looking at the effective date appearing at the top of said Privacy Policy. We recommend that this Privacy Policy be reviewed periodically in order to assess the current practices applicable, as the continued use of the Website shall constitute acknowledgement and acceptance of any amendment thereto. Should you disagree with the amendments made to this Privacy Policy or other applicable terms and conditions, then you shall immediately stop accessing or using the Website.  Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.