Privacy Protection Policy

The main objective of this policy is to ensure the protection of personal information while establishing clear guidelines for the collection, use, disclosure, retention, destruction, and management of data within ELITE IMMOBILIER. This applies to all stakeholders, including management, employees, suppliers, etc. Furthermore, this policy aims to inform all concerned parties, whether they are clients, employees, or other individuals, about how ELITE IMMOBILIER handles their personal information.

Responsibility

ELITE IMMOBILIER assumes full responsibility for safeguarding personal information under its jurisdiction. The data collected, used, disclosed, retained, or destroyed is subject to the provisions of this policy with the primary aim of maintaining the confidentiality of each individual.

To ensure the most effective protection of personal information, the Data Security Officer at ELITE IMMOBILIER must:

• Oversee and review internal practices and procedures for handling personal information and ensure compliance with current laws;
• Recommend measures to ensure the continuous protection of personal information, aligned with privacy impact assessments;
• Implement the necessary measures within the company to protect personal data;
• Ensure staff compliance and training on best practices to protect personal information;
• Coordinate, investigate, and respond to requests and complaints related to personal data protection;
• Communicate with concerned individuals and the ‘Commission d’accès à l’information (CAI)’ in the event of a data breach or incident;
• Maintain a register of incidents related to personal data.

Personal data protection is everyone’s responsibility. No retaliation can be made against an individual who files a complaint related to personal data protection or participates in an investigation process with the CAI.

Collection of Personal Information

Personal information is collected to facilitate the operations of ELITE IMMOBILIER and conduct its activities in compliance with applicable laws and standards. ELITE IMMOBILIER collects personal data only when necessary and to meet specific, predefined purposes. The collection of personal information is done directly from the person concerned and with their consent, unless an exception is provided by law.

Annex A contains a non-exhaustive list of the personal data collected and the intended use of the data. Most of the personal data collected relates to employees to meet the company’s legal obligations. Personal information of other individuals may be requested to assist employees in emergencies, for example. Employees are responsible for obtaining consent before providing such information to us.

Regarding customer information, data is provided to maintain records, management software, contracts, and billing. We place great importance on the confidentiality and security of our clients’ data. All collected information, whether contact details or other personal data, is handled with the utmost care and in compliance with applicable personal data protection laws and regulations. Our team is committed to implementing robust security measures to prevent unauthorized access and to regularly train our staff on best practices for data confidentiality. We consider the protection of our clients’ personal data as a fundamental responsibility to ensure their well-being and confidence in our services.

Consent and Accuracy of Personal Information

ELITE IMMOBILIER ensures that personal information is collected for justified, clear, and specific purposes and with the free and informed consent of the person. Consent is required for any collection, use, or disclosure of personal information. Before collecting personal information, we will ensure that your informed consent is obtained in writing, providing clear details on the purpose of the collection and how the information will be used. Your consent is essential to ensure the protection of your personal data.

Limitations on the Use of Personal Information

We collect and use your personal information only when necessary and for the purposes for which consent was obtained. ELITE IMMOBILIER may need to provide certain information to satisfy legal and regulatory verification processes. The use may vary but could serve different purposes, as outlined in Annex A.

The information may be shared with third parties to the extent necessary for the activities mentioned in Annex A. ELITE IMMOBILIER cannot be held responsible for the actions or use by third parties. Personal information will not be used or disclosed for other purposes unless required by law.

Protection of Your Personal Information

ELITE IMMOBILIER takes all reasonable precautions and implements significant physical and technical measures to prevent the unauthorized or illegal use and access to personal information. These measures include:

• Using personal information only when necessary;
• Ensuring confidentiality and protection of personal information accessed during the performance of duties, unless authorized for disclosure by the person concerned;
• Protecting records with selective and limited access to authorized individuals;
• Securing office access with locked doors and access codes;
• Secure shredding of paper records;
• Two-factor authentication for all platform logins;
• Immediate removal of access after the end of a business relationship.

Everyone is responsible for contributing to the protection of personal information. If you suspect that sensitive information has been compromised, you must immediately notify the Data Protection Officer.

Retention Period for Your Personal Information

ELITE IMMOBILIER is committed to respecting the minimum retention periods required according to the category of personal information and applicable laws. However, if the collected information is no longer useful for ELITE IMMOBILIER and its retention is not necessary or required by legislative frameworks, it will be destroyed, erased, or anonymized.

Commitment to Transparency

ELITE IMMOBILIER is committed to being transparent about the processing, procedures, and purposes governing the use of personal information for clients, employees, interns, and business partners.

Access to Your Personal Information

A person can request access to the personal information concerning them and the means used to collect it. Depending on the content of the person’s file, exceptions may apply, such as personal information related to others, though the individual will be informed. If any inaccurate information is found in the file, the person concerned can request corrections.

For consultation, withdrawal, or modification of personal information, you can write to martin@eliteimmobilier.ca. At any time, you may withdraw your consent to the communication of your personal information. A written request must be submitted to the Data Protection Officer at martin@eliteimmobilier.ca. A response will be provided within 30 days of the request’s receipt. When it is not possible to share the requested information, a legal justification and support will be provided to explain the decision to the requester.

Filing a Complaint

Anyone who believes that their personal information has been collected, retained, used, disclosed, or destroyed in a manner inconsistent with this policy may file a confidential complaint with the Data Protection Officer at martin@eliteimmobilier.ca. The individual must provide their name, contact details, including a phone number, as well as the subject and reasons for the complaint. Sufficient details must be provided to properly assess the complaint. A response will be provided within 30 days of the complaint’s receipt. If the complaint is insufficiently detailed, the Data Protection Officer may request any additional information necessary to assess the complaint. The officer will conduct an investigation of the received complaints, minimize any damages, and make necessary corrections.

It is also possible to file a complaint with the ‘Commission d’accès à l’information du Québec’. However, ELITE IMMOBILIER encourages individuals to first communicate with the Data Protection Officer and await the conclusion of the internal complaint process.

Approval

This policy is approved by the Data Protection Officer within ELITE IMMOBILIER.

Data Protection Officer
Martin Bertrand – President
63 rue de l’Hôtel-de-Ville
Gatineau (Québec) J8X 2E4
martin@eliteimmobilier.ca

For any requests, questions, or comments regarding this policy, please contact the officer via email.