PERSONAL INFORMATION PROTECTION POLICY
Last updated: September 2023
FOREWORD
GRT MANAGEMENT ROCHEFORT AND TESSIER INC. and its clients (hereinafter referred to as "GRTinc" or "we") wish to explain their practices regarding the management of Personal Information collected on their website or web platform, on their social media account (notably Facebook), or on any mobile application, as applicable (the "Site(s)").
Thus, this Policy aims at protecting Personal Information (hereinafter referred to as the "Policy") and sets out the principles that guide how we collect, use, and disclose such Information.
1. DEFINITIONS
"User" or "you" means an individual who (i) uses our Site; (ii) corresponds in any way with GRTinc; (iii) participates in a survey, draw, contest, or promotion of GRTinc; (iv) is a member of a program, including an email subscription; or (v) accesses, uses, or purchases any other service offered by GRTinc.
"Collection" means the action of gathering, acquiring, or obtaining Information, in any way and by any means, including from third parties.
"Disclosure" means the action of revealing Information to a third party.
"Information(s)" means any personal information concerning an individual that allows their identification, directly or indirectly.
"Privacy Officer" means the person mentioned in section 10 of this Policy.
2. COLLECTION OF INFORMATION
Types of Personal Information Collected:
To provide our services, we need to collect certain Information about a User that allows for their identification. Unless permitted by law or with your consent, we only collect those necessary for our activities: names, phone numbers, email addresses, postal codes, and language preferences for communications.
To use certain features of our Site, we may ask you to provide Personal Information. We only collect Personal Information that is necessary to provide you with our various services. Where possible, we indicate mandatory and optional fields.
If you use contact features such as "Contact Us," "Schedule a Visit," or "Service Call" on our Site, we may collect your name, email address, phone number, and other relevant Information about your request. We use this Information to respond to your request or comments. If you send us emails or letters, we may collect this Information in a file about you.
If you apply for a job via our Site, we may collect the following information related to your application:
- First and last name;
- Email address;
- Phone number;
- Information related to previous employment;
- Any other information contained in the resume;
With your consent, this information may be used to communicate other job offers similar to the one you are applying for.
As part of the conclusion of a residential lease, the information necessary for completing the lease form provided by the Administrative Housing Tribunal will be required. The collected personal information includes full name, phone number, email address, previous residential address, postal code, and depending on the chosen payment method, bank account number.
Methods Used for Collection:
The methods used by GRTinc to Collect Information can be traditional or technological. At all times, we respect your privacy and only use lawful means of Information Collection. Unless permitted or required by applicable laws or regulations or unless you consent, we will only retain your Personal Information for as long as necessary to achieve the purposes for which it was collected, including to meet legal, accounting, or audit requirements. GRTinc does not sell your Information to third parties.
3. DISCLOSURE OF INFORMATION:
GRTinc will only disclose your Personal Information with your consent or as permitted by law, notably in the following contexts:
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Transfer of Personal Information to third-party service providers who provide services on our behalf, notably to perform maintenance, repair/maintenance, or residential leasing services. In this case, our providers can only use your Information for the purposes for which they have access to it and must maintain the confidentiality of the Information transmitted to them.
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Disclosure of Personal Information if necessary to comply with legal, regulatory, or other requirements for insurance, verification, rental references, and security purposes, and otherwise with your consent, or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to us or our service providers). Therefore, in response to a verified request from law enforcement or a government representative regarding a criminal investigation or suspected illegal activity, we may (and you authorize us to) disclose your name, city, province, phone number, email address, and your file history. However, in a balance between your right to privacy and the ability to preserve the community from bad actors, we will not disclose additional Information to law enforcement or other government representatives without a subpoena, court order, or similar legal process, unless additional disclosure of Information is necessary to prevent imminent physical harm or financial loss.
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In the context of a business transaction, in connection with financing, securitization, insurance, sale, assignment, or any other proposed or actual disposition in whole or in part of GRTinc, or its operations or assets, for the purpose of evaluating and/or executing the proposed transaction. Assignees or successors of GRTinc, or its operations or assets, may use and disclose your personal information for purposes similar to those described in this Policy.
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In the event that your Information is disclosed outside of Quebec, this disclosure will be made in accordance with applicable laws. By using the Site, you consent to your Information being disclosed outside of Quebec, when necessary for processing, whether this disclosure is made by GRTinc or a service provider.
4. CONSENT:
Prior Consent to Collection:
By continuing to browse our Site and by transmitting Information to us through the means listed above, you consent to the Collection, use, and Disclosure of your personal information in accordance with this Policy.
Refusal to Consent:
When a User refuses to consent to the Collection of Information, we endeavor to offer them the same services as if they had consented.
However, some features and services of the Site require the collection of Information to function properly. Thus, a User's refusal to consent to the Collection of Information may result in a lower quality service or a less efficient and/or adapted service. Sometimes, services cannot be provided. If you refuse to consent to the collection of your Information or withdraw it later, it may have consequences on the services provided.
5. USE OF COLLECTED INFORMATION
The Information collected by GRTinc allows us to achieve the following objectives: improve the User experience as well as promote and/or sell products and services and ensure efficient service in the context of our real estate management functions.
Here is the list of various uses of Information at GRTinc:
- Customize our establishments, Sites, and applications to User preferences;
- Improve the performance of our Sites and applications offered to Users;
- Distribute newsletters;
- Send invitations;
- Respond to inquiries;
- Conduct surveys;
- Compile statistics to define our User profile and preferences;
- Conduct market research;
- Offer services and partnerships tailored to the preferences and needs of our Users;
- Promote promotions and programs;
- Conduct targeted advertising;
- Prevent fraud attempts;
- Any other use underlying the achievement of the objectives mentioned in the first paragraph;
- Any other use to which the User expressly consents.
The Information is kept until the purpose of the collection is achieved. Once the purpose of the collection is achieved, the Information is destroyed or anonymized for further use in accordance with the law.
6. HOSTING OF INFORMATION AND SECURITY
We protect your Information using technical, material, and administrative security measures to reduce the risk of loss, fraudulent use, or unauthorized access, Disclosure, or modification of this Information.
Access:
Access to the Information held by GRTinc is reserved for only employees whose tasks require the use of this Information, as well as only subcontractors whose mandate or contract execution necessitates the use of the Information.
Hosting:
We may engage third-party providers who securely process or store your Information. Security measures used by these specialized companies include secure servers and firewalls. All third-party providers to whom your Information is communicated, especially if they are responsible for processing or storing it, have committed to ensuring the protection of such Information.
Inherent Risks:
Sharing Information via the Internet is not without flaws. Thus, although we take reasonable measures, considering the sensitivity of the Information involved, to protect your Information, we cannot guarantee its protection. Under no circumstances will GRTinc be responsible for a breach of the confidentiality of your Information that we could not reasonably prevent.
7. USE BY MINORS
The Site is not intended for use by individuals under 14 years of age. If you are a parent or guardian and believe that we have collected Information about a child under 14, please contact the Privacy Officer, using the contact information provided in section 10 titled "Contact Us" below.
8. POLICY MODIFICATION
This Policy comes into effect on the date at the top of the Policy. Our Policy may be updated from time to time. We advise you to check it frequently. At our discretion, we may also contact you, notably by email, to inform you of changes to this Policy.
9. RIGHT TO ACCESS, MODIFY, OR DELETE YOUR INFORMATION
In accordance with applicable laws, you have, under certain circumstances, the right to access, rectify, or modify Information about you. Any request for access, modification, rectification, or deletion of your Information must be made in writing and sent to us at the email or postal address indicated in section 10 titled "Contact Us" below. To properly process your request, we may ask you to provide certain information about yourself to confirm your identity.
Any request for access may be subject to fees to cover the costs incurred by the Disclosure of the Information we hold about you.
10. CONTACT US
If you have any questions, requests regarding this Policy, or complaints, please contact Caroline Girard, by email or by mail, at the following address:
Attn: Caroline Girard
Gestion Rochefort & Tessier Inc.
2860, chemin des Quatre-Bourgeois
Bureau 101
Québec (Québec) G1V 1Y3
Fax: 418 653-1496
caroline.girard@grtinc.ca
If you wish to access your Information, please make your request in writing to the Privacy Officer, at the address provided above, providing satisfactory identification documents and proof of your right to access, as well as details about the type of Information you are seeking. We will respond to such requests within the time prescribed by law or, if no prescribed time limit, within a reasonable time, starting from the receipt of all relevant documents related to this request.