Privacy Policy

Last updated: March 17, 2026

1. Privacy Officer

In accordance with Bill 25, we have designated a person responsible for the protection of personal information:

The privacy officer ensures the application of this policy, processes access or rectification requests, handles complaints related to the protection of personal information, and manages privacy incidents.

2. Personal Information Collected

In the course of our clinical activities and online presence, we may collect the following information:

2.1 Identification and Contact Information

• Name, first name and date of birth
• Postal address, email and phone number
• Quebec Health Insurance Board (RAMQ) number
• Dental insurance information

2.2 Medical and Dental Information

• Medical and dental history, allergies and medications
• Radiographs, imaging (CBCT, intraoral scanner) and clinical photographs
• Treatment plans, clinical notes and complete orthodontic records

2.3 Financial Information

• Dental insurance information
• Banking or credit card details (for payment)
• Billing history

2.4 Information About Minors

• Information about parents or legal guardians
• Parental consent

2.5 Technological Information (Website)

• IP address, browser type and operating system
• Pages visited on our website and visit duration
• Data from online contact forms

3. Purposes of Collection

Your personal information is collected and used for the following purposes:

3.1 Provision of Care

• Establish your patient file and perform the diagnosis
• Provide orthodontic care and ensure your treatment follow-up
• Communicate with you about your appointments

3.2 Administration

• Manage appointment scheduling
• Process payments, billing and insurance claims
• Comply with our legal and professional obligations

3.3 Service Improvement

• Evaluate and improve the quality of care
• Improve the user experience on our website
• Perform statistical analyses (with anonymized data)

4. Legal Basis for Processing

5. Consent

In accordance with Bill 25, we obtain your consent before collecting, using or disclosing your personal information. This consent is:

• Manifest: expressed clearly and freely
• Informed: you are informed of the purposes of the collection
• Specific: given for each distinct purpose
• Temporary: valid for the duration necessary for the identified purposes

5.1 Consent of Minors

For patients under 14 years of age, consent is given by the parent or legal guardian. For patients 14 years and older, consent may be given by the patient themselves, in accordance with the Civil Code of Quebec.

5.2 Withdrawal of Consent

You may withdraw your consent at any time for non-essential treatment purposes (marketing communications, email/SMS reminders, use of photos for promotional purposes).

Withdrawal of consent for information essential to treatment may, however, limit the services we are able to offer you.

6. Disclosure to Third Parties

Your personal information is never sold, rented or exchanged. It may only be disclosed in the following situations:

Any service provider with whom we share information is bound by a confidentiality agreement and may only use the information for the intended purposes.

7. Transfers Outside Quebec

In accordance with Bill 25, before any transfer of personal information outside Quebec, we conduct a privacy impact assessment (PIA).

You have the right to be informed of any transfer outside Quebec and to request details about the protection measures in place.

8. Retention and Destruction

Upon expiration of the retention period, information is securely destroyed (shredding for paper documents, permanent deletion for digital data, destruction according to environmental standards for radiographs).

9. Data Security

We implement security measures appropriate to the sensitivity of the information we hold:

9.1 Technical Measures

• SSL/TLS encryption for all Web transmissions
• Encryption of data at rest (AES-256)
• Firewall and intrusion prevention
• Regular secure backups
• Strong authentication for system access

9.2 Organizational Measures

• Access limited on a need-to-know basis
• Confidentiality agreements signed by all staff
• Staff training on information protection
• Documented internal policies and procedures

9.3 Physical Measures

• Controlled access to premises
• Locked filing cabinets for paper records
• Secure document destruction

10. Your Rights (Bill 25)

Bill 25 and PIPEDA grant you several rights:

• Right of access: view the information we hold about you and learn how it is used
• Right of rectification: have any inaccurate, incomplete or equivocal information corrected
• Right to erasure: request the deletion of your information when it is no longer necessary (subject to our legal retention obligations)
• Right to portability: obtain a copy of your information in a structured and commonly used technological format
• Right to de-indexation: request that hyperlinks providing access to your information be deactivated
• Right to withdraw consent: at any time, for information whose collection is based on your consent

To exercise your rights, contact our privacy officer at the coordinates provided in section 1. Response time: 30 days (extendable by 30 days if necessary, with a reasoned notice).

11. Use of Artificial Intelligence

For the sake of transparency, we inform you that our clinic uses artificial intelligence (AI) tools in certain aspects of its activities. This section describes the uses, limitations and safeguards in place.

11.1 AI Tools Used and Context

We use AI tools exclusively in the following areas:

11.2 No Clinical Decision Made by AI

11.3 Patient Data Protection

AI does not have access to your patient records. The AI tools used for content creation, social media and the chatbot operate entirely independently of our clinical systems. Specifically:

• No personal health information is transmitted to generative AI tools
• AI systems have no access to our orthodontic records, radiographs or clinical notes
• The chatbot only collects information that the visitor voluntarily provides (name, email, general question)
• Orthodontic planning software (Invisalign, SPARK) is subject to strict confidentiality agreements (see section 6)

11.4 Transparency on AI-Generated Content

Some content published by our clinic is created or assisted by artificial intelligence tools:

• Blog: Educational articles may be written with AI assistance. All medical content is reviewed and approved by Dr Benguira before publication.
• Social media: Posts may be written or scheduled using AI tools. Content is approved by the team before distribution.
• Images: Some illustrative (non-clinical) images may be AI-generated. Clinical photos (before/after, radiographs) are always authentic.

11.5 Regulatory Compliance

Our use of artificial intelligence complies with the following regulatory frameworks:

• Bill 25 (Quebec): Transparency on the use of automated technologies, protection of personal information, right to information on automated processes
• Bill C-27 / AIDA (Canada): We are monitoring the development of the Artificial Intelligence and Data Act (AIDA) and commit to complying with its requirements upon enactment, particularly regarding risk assessment and transparency
• Code of Ethics for Dentists: Clinical judgment remains exclusively human, in accordance with the professional obligations of the Ordre des dentistes du Québec

We regularly reassess our AI practices to ensure they remain compliant with applicable laws and industry best practices.

12. Automated Decisions

In addition to the AI tools described in section 11, we do not use automated decision-making processes (including profiling) that have legal or significant effects on you. Should we use such systems in the future, you would have the right to be informed, to know the parameters used, and to request human review.

13. Cookies

Our website uses cookies and similar technologies:

You can manage your cookie preferences through your browser settings. We do not use third-party advertising tracking cookies.

In accordance with Bill 25, we inform you of the use of these technologies and obtain your consent when required. Some third-party services may transfer data outside Quebec; we ensure that adequate protection measures are in place.

14. Minors

We pay particular attention to the protection of information about minor patients:

• Parental consent required for children under 14
• Limited access to sensitive information
• No online collection of information from minors without parental consent

Parents or legal guardians have the right to access their minor child's file, to request rectification of information, and to consent to or refuse non-essential data processing.

15. Privacy Incidents

In accordance with Bill 25, in the event of a privacy incident presenting a risk of serious harm, we commit to:

• Assessing the severity of the incident and taking necessary measures to limit harm
• Notifying the Commission d'accès in l'information du Québec (CAI) within the prescribed deadlines
• Notifying the affected individuals as soon as possible
• Maintaining a registry of privacy incidents
• Identifying the cause and preventing recurrence

16. Amendments to the Policy

This policy may be amended to reflect legislative changes, the evolution of our practices, or new technologies used. Any significant amendment will be published on this page with the update date and will be the subject of a notice on our website.

17. Complaints and Recourse

If you believe your personal information protection rights have not been respected, you may:

• Contact our privacy officer (section 1). We commit to responding within 30 days.
• File a complaint with the Commission d'accès in l'information du Québec (CAI)
• File a complaint with the Office of the Privacy Commissioner of Canada (for matters under PIPEDA)

18. Contact Information

For any questions regarding this policy or the protection of your personal information:

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