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This Policy has been developed within a governance framework for the protection of personal information (practices governing the retention, destruction, and anonymization of personal information) (the “Policy“).
ESPACES LOKALIA and 9349-6347 QUÉBEC INC., its affiliates, and subsidiaries (collectively “Espaces Lokalia” or “we” or “us“) implement this Policy with respect to individuals (collectively “Client(s)”, “Individual(s)”, “Employee(s)”, or “you” or “your”) from whom ESPACES LOKALIA collects personal information through direct or indirect contact with an authorized representative of ESPACES LOKALIA and the website https://www.espaceslokalia.ca/ (the “Website“), for the purposes described in the PERSONAL INFORMATION COLLECTED section in paragraph 3 below.
In this Policy, the term “personal information” refers to any information collected by ESPACES LOKALIA that, alone or in conjunction with other information, allows an Individual to be directly or indirectly identified.
By providing one or more pieces of personal information to ESPACES LOKALIA through direct or indirect contact with an authorized ESPACES LOKALIA representative or through your use of the Website, you consent to ESPACES LOKALIA collecting, using, disclosing, and retaining this personal information in accordance with the terms, conditions, and conditions set forth in this Policy.
This Policy describes Espaces Lokalia’s practices regarding the processing of your personal information, including the collection, use, processing, transfer, storage, retention, or disclosure of your personal information (i) when you voluntarily provide such personal information to an ESPACES LOKALIA employee or authorized representative in writing, by email, or verbally, (ii) information we collect from other companies and public bodies, or (iii) during your use of the Website.
ESPACES LOKALIA reserves the right to modify the terms, conditions, and conditions set forth in this Policy at any time and at its sole discretion. In such a case, ESPACES LOKALIA will provide you with a version of this Policy containing the modifications. Your use of the Services (as defined in the PERSONAL INFORMATION COLLECTED section, paragraph 4 below) following receipt of this version will be deemed to constitute express acceptance of the modifications.
This Policy and any amended version thereof are subject to the legislation applicable in the province of Quebec.
PL25 – PRIVACY POLICY
ESPACES LOKALIA is committed to respecting and protecting the personal information of everyone with whom it interacts. ESPACES LOKALIA will handle your personal information at all times in accordance with applicable laws and the following principles:
– Personal information is collected only with your consent;
– Personal information is kept strictly confidential;
– Personal information is used only for the purposes for which it was collected; and
– You may access your personal information upon request.
PERSONAL INFORMATION COLLECTED
1. How is personal information collected?
ESPACES LOKALIA collects personal information through the following means: (i) when you voluntarily submit such personal information to an ESPACES LOKALIA employee or authorized representative in writing, by email, or verbally, (ii) information we collect from other companies and public bodies, or (iii) when you use the Website.
The personal information provided when using the Website may be communicated directly (for example, via a web form or email) or automatically (see the list of personal information collected automatically in the PERSONAL INFORMATION COLLECTED section in paragraph 3).
2. What personal information does ESPACES LOKALIA collect?
The personal information that ESPACES LOKALIA may collect is as follows:
– Your first and last name and contact information (street addresses, email addresses, telephone numbers);
– Your date of birth, gender, and preferred language;
– Information such as gender, age, nationality, profession or primary occupation, level of education, Canadian citizenship or residency, postal code, religion, marital status, consumer preferences, location data, and other demographic or behavioral information;
– Personal information allowing ESPACES LOKALIA, through its authorized representatives, to verify your identity: including a photo ID document issued by a government that is authentic, valid, and up-to-date; or a document from a reliable source that includes your name, address, and date of birth; or confirmation that you hold a deposit account, a prepaid payment product account, or a credit card or other bank account with a financial institution;
– Personal information that you are required to, or invited to, provide to ESPACES LOKALIA due to the nature of your relationship with it (social insurance number, driver’s license number, personal email address, personal telephone number, financial information, photographs for publication on the Website, and identification documents, among other things, for the application of the Act primarily aimed at improving corporate transparency or information required in the context of various transactions related to ESPACES LOKALIA’s business affairs);
– Personal information that you provide to us in the course of providing the Services, such as information regarding your rental history, medical information; and financial information that is necessary to conduct credit investigations and collect payments. Deposits and payments (credit card number, check specimens, mortgage approval, tax statements, credit report, etc.);
– Personal information generated by you in the course of your use of the Services (leases, pre-authorized debits (PADs), complaints, inquiries, reviews, comments, and survey responses, etc.);
– Personal information provided in the course of a job application or engagement with ESPACES LOKALIA (curriculum vitae, information on education, professional experience and professional affiliations, criminal record, medical information, various surveys, references);
– Personal information automatically collected during your use of the Website (see PERSONAL INFORMATION COLLECTED, paragraph 3).
3. Personal Information Collected Automatically or through Cookies and Pixel Tags
To ensure the functionality of the Website and the purposes of the personal information collected below, ESPACES LOKALIA must collect the following personal information from Individuals visiting the Website:
– The domain name of their Internet service provider;
– Their IP address;
– Their browser (Explorer, Firefox, etc.) and operating system (Windows, Mac OS, etc.);
– The date and time of their visit;
– Their country of origin;
– The pages they viewed and the time spent on each visit;
– The address of the referring website; and
– Crash data.
All of this information is collected automatically when an Individual connects to the Website. Some of this personal information is collected through the placement of temporary cookies or web beacons (also sometimes called “invisible pixels”). These files or tags also allow us to improve the performance of the Website and some of its features.
A cookie is a small text file or piece of data that is downloaded and stored on your computer or device when you visit a website (the “Cookie”).
A pixel tag is a very small graphic element with a unique identifier that can be used on our Website to measure your interactions with the Website and the services offered (the “Pixel(s)”).
By accessing our Website, you consent to Espaces Lokalia’s use of Cookies and Pixels, which allow Espaces Lokalia, among other things, to recognize you when you visit the Website in order to personalize your browsing experience according to your preferences and to offer you personalized services and products on our Website or any other website.
Most browsers are initially configured to accept Cookies. You can generally change your browser settings (which will also affect Pixels) to (i) refuse Cookies or to indicate when a Cookie is being sent; or (ii) delete or block Cookies, but this may affect your ability to use the Website, which may then no longer function properly or at all.
4. Why does Espaces Lokalia collect this personal information and other information?
ESPACES LOKALIA collects your personal information for the following purposes:
– To provide property management, residential and commercial leasing services, information, advice, and tools related to residential and commercial leasing services, to conclude real estate transactions, residential leases, and other areas related to real estate leasing, and to offer maintenance, upkeep, and concierge services, etc. (collectively, the “Services”);
– As part of your use of the Services, to issue notifications and alerts to provide you with relevant or specific information;
– Generally, to communicate with you to provide you with various information related to the Services or to offer you products and/or services that may be of interest to you;
– To follow up with you to ensure your satisfaction with the Services, or to provide any other communication related to the provision of services;
– Develop, improve, and promote the Services, including by generating and publishing depersonalized statistical data based on the personal information of several Individuals;
– Evaluate the effectiveness of ESPACES LOKALIA’s efforts to attract visitors to the Website; Evaluate what information ESPACES LOKALIA offers and what its efforts generate interest among its Website visitors; Improve the Website’s performance and effectiveness;
– Identify the legislative framework to which visitors’ personal information is subject; and
– If applicable, review your application for employment or employment with ESPACES LOKALIA.
Subject to the exceptions provided for in applicable legislation, ESPACES LOKALIA will ensure that you consent to any use of your personal information for purposes other than those listed above.
COMMUNICATION AND DISCLOSURE OF INFORMATION
Generally speaking, ESPACES LOKALIA uses Individuals’ personal information for internal purposes only. However, ESPACES LOKALIA may disclose your personal information to the following persons or entities:
1. To its employees and representatives who require access to this personal information in order to pursue the purposes and services listed in the section “Why does Espaces Lokalia collect this personal and other information” on page 4;
2. To external service providers with whom ESPACES LOKALIA has entered into a contractual agreement for the purpose of providing its Services;
3. To any other person or entity, when prescribed or permitted by applicable legislation, or with the consent of the Individual concerned.
In order to fulfill the aforementioned purposes, ESPACES LOKALIA may disclose your personal information outside Quebec. However, ESPACES LOKALIA will only do so if a privacy impact assessment demonstrates that the receiving party
is able to adequately protect such personal information, particularly with regard to generally accepted privacy principles.
We do not sell or rent personal information to any third party except in accordance with these Terms and Conditions.
We may disclose personally identifiable information without your consent in an emergency or to prevent an act of violence, for the performance of a contract, following a privacy incident, for legal or investigative purposes, when required by law or a public body, in debt collection situations, or to conclude a commercial transaction.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
Appropriate physical, technological, and administrative safeguards have been implemented to protect your personal information and reduce the risks of unauthorized and/or illegal access, use, disclosure, destruction, and accidental loss. We also seek to ensure that our service providers do the same.
ESPACES LOKALIA maintains a record of privacy incidents in accordance with applicable legislation. Should a privacy incident occur that presents a risk of serious harm to you, ESPACES LOKALIA will take the necessary steps to notify you, in accordance with applicable legislation. The assessment of the risk of serious harm to you is carried out taking into account criteria such as the sensitivity of the personal information affected by the privacy incident, the anticipated consequences of its use, and the likelihood of it being used for harmful purposes.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We are committed to ensuring the security and confidentiality of your personal information and not retaining it longer than necessary for the purposes for which it was obtained and processed. In accordance with our secure retention and destruction procedures for personal information, we only retain your personal information for the period necessary to fulfill the purposes listed in the PERSONAL INFORMATION COLLECTED section, paragraph 4 of this Policy, or for the period required to comply with our statutory obligations, whichever is later.
ESPACES LOKALIA reserves the right to close an Individual’s file when required or, in the case of ESPACES LOKALIA employees, for a consecutive period of at least seven (7) years from the end of employment, subject to a statutory obligation stipulating a different minimum retention period. Closing a file implies the complete and permanent destruction of the personal information it contains, or its anonymization for use for serious and legitimate purposes. In the event that a file concerning an Individual who is not an employee or representative of ESPACES
LOKALIA is closed, the personal information it contains will be destroyed or anonymized, usually after the expiration of a period of six (6) years following the date of closure of the file, due to retention periods imposed by law.
The term “anonymization” refers to the process at the end of which personal information no longer allows, irreversibly, the direct or indirect identification of the Individual to whom it relates.
OUR RESPONSIBILITY FOR EXTERNAL LINKS
The Website may contain links to other websites or third-party products and services (collectively, “Third-Party Products”). This Policy is limited to the personal information we collect and use through the Website. We may provide links to external resources or other websites, including, but not limited to, social media sites such as Facebook, Twitter, and LinkedIn. If you follow these links, you must use these sites in accordance with the applicable usage and privacy policies.
ESPACES LOKALIA has no responsibility or liability for your personal information that may be collected, used, disclosed, or stored by any person or entity in connection with your access to or use of Third-Party Products. We cannot be held responsible for the collection, use, or processing of personal information or other information you may provide on these sites.
YOUR RIGHTS REGARDING THE PERSONAL INFORMATION YOU PROVIDE TO US
ESPACES LOKALIA recognizes the right of Individuals to access, rectify, update, and obtain a copy of their personal information by submitting a written request to ESPACES LOKALIA, using the contact information provided at the end of the Policy.
In the event that such a written request is sent to ESPACES LOKALIA, the latter must, under the law, verify your identity and ensure a written response within a reasonable time after receiving the request. Any request that is not processed is deemed to have been refused.
In principle, the exercise by an Individual of a right provided for in this section is free of charge. However, reasonable fees may be charged to the Individual concerned to compensate for the costs of transcribing, reproducing, or transmitting their personal information. In such a case, the Individual will be notified of the amount of the fees in question before their request is processed.
Subject to your contractual commitments with ESPACES LOKALIA and applicable legislation, you may withdraw or modify your consent to the use or disclosure of your personal information. To do so, you must send a written request to ESPACES LOKALIA, using the contact information provided at the end of the Policy.
Please note that withdrawing or modifying your consent may impact ESPACES LOKALIA’s ability to properly pursue the purposes for which it collected your personal information and could impact our services to you.
If you wish to no longer receive marketing messages from us, please click the “Unsubscribe” link at the bottom of the message. If you wish to opt out completely, please contact us at the address provided below. CONTACT US
If you have any questions about our approach to privacy or if you wish to exercise any of the rights mentioned in this Policy, you can contact our Privacy Officer as follows:
Espaces Lokalia
1981 Bernard-Pilon Street, Beloeil, Quebec J3G 4S5
Attention: Privacy Officer Email: rprp@espaceslokalia.ca
Stéphanie Cocozza
Telephone: (450) 446-8221
Fax: (450) 446-8223
Please note that ESPACES LOKALIA is required to verify your identity before responding to any request, question, comment, or complaint addressed to its Privacy Officer.