01
Purpose of this policy
Respecting privacy and protecting personal information matter to us. Through this policy we intend to protect them in accordance with the laws in force, first among them the Act respecting the protection of personal information in the private sector, as amended by Loi 25.
Harry Toulch Optometrists undertakes to collect, process and disclose information that identifies a person only where that person has consented, unless the law permits or requires otherwise, in which case your consent is not required.
For the purposes of this policy, “personal information” means any information concerning a natural person that allows that person to be identified, directly or indirectly.
This policy concerns the WEBSITE, and nothing else. Information gathered at the clinic, your eye exam and your ocular health record are governed by professional secrecy, the Professional Code and an optometrist's duties to their order. That is a separate and stricter regime, and this policy does not replace it.
02
Effective date
This policy applies as of September 14, 2026. It replaces the policy dated March 14, 2024, which accompanied the previous website.
We may amend it. The last updated date appears at the top of this page, and any reduction of your rights will be brought to your attention before it takes effect.
03
How consent is obtained
We undertake to obtain your consent before collecting your personal information. That consent may be express or implied, and may be given by you or by your authorized representative.
On this site it is implied, and it rests on a simple act: you fill in a form and you send it. Giving a name and a phone number so that we can call you back about an appointment amounts to consenting to that name and number being used to call you back. Nothing further is inferred from it.
If we wished to use your information for a new purpose, we would describe that purpose and ask for your consent again. You may withdraw it at any time: see clause 8.
04
Why we collect
We collect information for the following reasons, and for no other:
To answer you
A written request calls for a reply. That takes a name and a way to reach you.
To prepare an appointment
The reason for the visit, the preferred time and whether this is a first visit let us book the right length of exam, with the right optometrist.
To call you back
An appointment request is confirmed by phone. That is why the number is required there, while it stays optional on the contact form.
To meet our legal obligations
Where a law, a regulation or a professional order requires us to keep or disclose information.
To understand how the site is used
To know which pages are read, how people reach them and where visitors give up. These are aggregate statistics, and they serve to fix what works badly.
We collect nothing in order to feed an automated system that would make a decision about you.
05
Personal information collected
This site has no account, no password, no cart and no online payment. We therefore never ask for a credit card number, a health insurance number or identity documents through this site.
The only information collected is what you enter yourself in one of the two forms or in the chat window:
Contact form
First name, last name, email address, subject and message. The phone number is optional there.
Appointment form
First name, last name, phone number, email address, reason for the visit, preferred time, whether this is a first visit, whether it is urgent, and a free-text message.
Chat
The messages you write in the chat bubble at the bottom of every page, and the name or email address you choose to give there. They go straight to the clinic's staff.
The message field and the chat are free-text: write only what is needed. A web form or a chat window is not the right place for detailed health information, and we ask you for none. If your situation is urgent, call us instead.
Our host also keeps technical logs (IP address, browser type, page requested, date and time), as any web server does. They serve security and fault diagnosis, not identification or tracking.
The measurement tools finally collect browsing data automatically: pages read, time spent, the site or search you arrived from, device type, browser, language, an approximate region inferred from the IP address, and actions taken on the page (a link followed, a form started). We ask them for neither your name nor your email, and we do not tie this data to requests received through the forms. Clause 10 says which tools these are and how to refuse them.
06
How the information is used
We use the information collected solely for the purposes for which it was given:
To reply
To handle your request, by email, by phone or by chat.
To book and confirm
To agree on an appointment, confirm it, and warn you if it has to move.
To follow up
To get back in touch about the same request, until it is settled.
To keep the site safe
To detect automated submissions and abuse of the forms.
To improve the site
To read aggregate statistics that show which pages are missing, which read badly, and where visitors give up.
To measure our marketing efforts
With your consent, to learn whether our posts and campaigns bring visits and appointment requests, using the same aggregate statistics.
We do not add you to any newsletter unless you asked for it, and we do not reuse the contact details from an appointment request to send you offers.
07
How the information is handled
We take the security of your information seriously and handle it to industry standards, solely for the purposes described here.
The site is served entirely over HTTPS: what you type into a form travels encrypted between your device and the server. Information received is then emailed to the clinic and kept in HubSpot, the tool the clinic uses to follow up on requests. Access to both is limited to the staff who handle requests.
No transmission over the Internet is absolutely secure, and we will not pretend otherwise. For sensitive or pressing health information, the phone remains the channel to prefer.
08
Access, correction and withdrawal
In respect of the information we hold about you, you have:
The right of access
To know what information we hold and to obtain a copy of it.
The right of rectification
To have inaccurate, incomplete or ambiguous information corrected.
The right of withdrawal
To withdraw your consent, and to ask that information we no longer have grounds to keep be deleted.
The right to complain
To bring the matter before the Commission d'accès à l'information du Québec if our answer does not satisfy you.
To exercise any of these rights, write to the officer named at the foot of this page. We answer within the thirty days set by law. As a safeguard, we may need to verify your identity before acting.
There are cases where we cannot grant a request, for instance where the information also concerns someone else, or where a legal obligation requires us to keep it. We will then give you our reason in writing.
09
Sharing with third parties
Harry Toulch Optometrists does not sell, rent or trade your personal information to anyone. We do not pass it to advertisers or to data brokers.
It leaves the practice only in the following cases:
With your consent
Where you ask us to or authorize us to.
Our technical providers
The site's host; Brevo, which delivers the requests sent through the forms to the clinic by email; HubSpot, which receives and keeps them; and the clinic's phone system (3CX, managed by Connextek), which receives chat conversations and keeps them in a data centre in Montreal. They have access only to what they need, act on our instructions, and have no right to use that information for their own purposes.
Our analytics and marketing tools
Google and PostHog receive the browsing data described in clause 10. They receive none of the information you type into a form.
For legal reasons
Where a law, a regulation, a court order or a lawful request from an authority requires it.
Some of these providers run servers outside Quebec, including in the United States. Your information may therefore be processed there and be subject to the laws of those territories. We use only established providers with protection commitments of their own. Chat conversations, however, stay in Quebec: the 3CX system and everything in it are hosted in Montreal.
Optik Avenue Optométristes is a separate business, with its own management and its own records. We disclose nothing you entrust to us to them.
10
Cookies and similar technologies
A cookie is a small file a site places in your browser to recognize you from one page to the next, or from one visit to the next. This site uses some, and here is which.
Analytics and marketing
Google Analytics, loaded through Google Tag Manager. It counts visits, pages read and actions taken on the page, so that we know what works, what is missing, and whether our marketing efforts bring visits. Google Ads, loaded the same way, tells us whether a visit from one of our Google ads leads to a request or a call. It is also used to show our Google ads, elsewhere on the web, to people who have visited the site. PostHog, loaded directly by the site, also counts visits and pages read, and records how visits unfold (scrolling, clicks, pages viewed) so that we can see where the site trips people up. These recordings contain nothing you type: form fields and form text are masked. PostHog keeps this data in the United States. These tools set cookies of their own and receive your IP address.
The map
The map on the home page and the one on the contact page come from Google Maps. As soon as one of those maps appears, your browser talks directly to Google, which sees your IP address and may set cookies of its own depending on your settings.
The chat
The chat bubble is loaded from 3CX's servers on every page. Your browser therefore talks to 3CX, which sees your IP address. It sets no cookie, but keeps in your browser what it needs to follow a conversation from one page to the next. It is not used for analytics or marketing.
No reCAPTCHA
The anti-bot filter on both forms is a hidden field, which loads no script.
These tools belong to third parties, and what they do with the data they receive falls under THEIR privacy policy, not ours. We pass them nothing of what you type into a form.
Analytics and marketing cookies are only turned on with your consent. On your first visit, a banner asks you to accept or decline them; until you choose, they stay off. Your choice is kept for 12 months in your browser, and you can change it at any time with the “Manage cookies” link at the bottom of every page. You may also refuse cookies through your browser settings. The site remains fully usable either way: only the map may stop appearing. Recent browsers also offer a private browsing mode, which clears cookies when you close it.
This site also links to outside pages, including Facebook and Instagram. This policy stops applying the moment you leave our site, and we do not answer for what those third parties do with your information.
11
How long information is kept
We keep information received through the forms and the chat for as long as it takes to handle your request and follow up on it, then for as long as a legal or professional obligation requires, where one applies.
A chat conversation can be read only by the clinic staff who receive it. It is not archived: it is erased from the system as soon as staff close and delete it. While it stays open, it remains in the system, accessible to those staff only.
A request that leads nowhere is destroyed once it has no further purpose. A request that leads to an appointment joins the clinic's file, where it then falls under the retention rules proper to a clinical record, which are longer, and not under this policy.
The host's technical logs are kept for a short period, for security, then deleted automatically.
Once the retention period has run, information is securely destroyed or irreversibly anonymized.
