PRIVACY POLICY

Last updated: September 2023

PREFACE

GESTION ROCHEFORT ET 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 accounts (including Facebook), or on any mobile application, if applicable (the "Site(s)").

Thus, this Policy aims to protect personal information (hereinafter referred to as the "Policy") and outlines the principles that guide how we collect, use, and disclose this information.

1. DEFINITIONS

"User" or "you" refers to a natural person 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 email communication; or (v) accesses, uses, or purchases any other service offered by GRTinc.

"Collection" refers to the action of gathering, acquiring, or obtaining Information, in any way and by any means, including from third parties.

"Disclosure" refers to the action of revealing Information to a third party.

"Information" refers to any personal information that concerns a natural person and allows them to be identified, directly or indirectly.

"Privacy Officer" refers to the person mentioned in section 10 of this Policy.

2. COLLECTION OF INFORMATION

Personal Information Covered

To provide our services, we need to collect certain Information about a User that allows them to be identified. Unless permitted by law or with your consent, we only collect the necessary information 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 the personal Information necessary to provide 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 regarding 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 concerning you.

If you apply for a job through our Site, we may collect the following information related to your application:

  • Name and surname;
  • Email address;
  • Phone number;
  • Information related to previous jobs;
  • 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 applied for.

In the context of concluding a residential lease, the necessary information to complete the lease form provided by the Administrative Housing Tribunal will be required. The personal information collected includes the full name, phone number, email address, previous residential address, and postal code, and depending on the chosen payment method, bank account number.

Means of Collection

The means used by GRTinc to collect Information can be traditional or technological. At all times, we respect your privacy and only use lawful means of collecting Information.

Unless applicable laws or regulations allow or require it, or we have your 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 if legally authorized to do so, including in the following contexts:

  • Transferring personal Information to third-party service providers who provide services on our behalf, such as maintenance, repair, or residential rental services. In this case, our providers can only use your Information for the purposes for which they have access and must maintain the confidentiality of the Information transmitted to them.
  • Disclosing personal Information if necessary to meet legal, regulatory, or other insurance, audit, rental reference, and security requirements, and otherwise with your consent, or as permitted or required by law (including as required by Canadian and foreign laws applicable to us or our service providers). Consequently, in response to a verified request from law enforcement or a government representative concerning 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's history. However, in balancing your right to privacy and the ability to protect 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 further disclosure of Information is necessary to prevent physical harm or imminent financial loss.
  • In the context of a business transaction, related to the financing, securitization, insurance, sale, transfer, or any other proposed or actual disposition of all or part of GRTinc or its business or assets, for the purpose of evaluating and/or executing the proposed transaction. GRTinc's assignees or successors, or its business or assets, may use and disclose your personal Information for purposes similar to those described in this Policy.
  • In the event that your Information is disclosed outside Quebec, this disclosure will be made in accordance with applicable laws. By using the Site, you consent to your Information being disclosed outside Quebec when necessary for processing, whether this disclosure is made by GRTinc or a service provider.

4. CONSENT

Prior Consent for Collection

By continuing to browse our Site and providing us with Information 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 strive to offer the same services as if they had consented. However, some features and services of the Site require Information to function correctly. Therefore, a User's refusal to consent to the Collection of Information may result in a lower quality or less efficient and/or tailored service. Sometimes, services cannot be provided. If you refuse to consent to the collection of your Information or withdraw it later, it may impact the services provided.

5. USE OF COLLECTED INFORMATION

The Information collected by GRTinc allows us to achieve the following objectives: improving the User experience, promoting and/or selling products and services, and ensuring efficient service in our property management functions.

Here is the list of various uses of Information at GRTinc:

  • Adapt our establishments, Sites, and applications to User preferences;
  • Improve the performance of our Sites and applications offered to Users;
  • Distribute newsletters;
  • Distribute invitations;
  • Respond to Information requests;
  • Conduct surveys;
  • Accumulate statistics to define our typical User and their 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 subsequent use in accordance with the law.

6. INFORMATION HOSTING AND SECURITY

We protect your Information using technical, material, and administrative security measures to reduce the risk of loss, fraudulent use, unauthorized access, Disclosure, or modification of this Information.

Access

Access to Information held by GRTinc is restricted to employees whose tasks require the use of this Information and to subcontractors whose mandate or contract execution requires the use of the Information.

Hosting

We may use third-party providers who securely process or store your Information. Security measures are used by these specialized companies, such as secure servers and firewalls. All third-party providers to whom your Information is communicated, particularly if they are responsible for processing or storing it, have committed to ensuring its protection.

Inherent Risks

Sharing Information over the Internet is not without flaws. Thus, even if we take reasonable measures, considering the sensitivity of the information concerned, to protect your Information, we cannot guarantee its protection. In no case 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 persons 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 at the contact details indicated in section 10 titled "Contact Us" below.

8. POLICY MODIFICATION

This Policy is effective as of the date indicated 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, including by email, to notify you of changes to this Policy.

9. RIGHT TO ACCESS, MODIFY, OR DELETE YOUR INFORMATION

In accordance with applicable laws, you have, in certain circumstances, a right to access, rectify, or modify the Information concerning 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. We may request certain information about you to confirm your identity to adequately process your request.

Any access request 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, a request regarding this Policy, or a complaint, please contact Caroline Girard by email or by mail at the following address:

Attn: Caroline Girard
Gestion Rochefort & Tessier Inc.