PRIVACY POLICY
Momento Condominiums provides its internet users with a secure online environment. Momento Condominiums operates in accordance with the Private Sector Personal InformationProtection Act (R.S.Q., c. P-39.1) (herein after referred to as the"Act"). In this context, Momento Condominiums is committed to maintaining high standards of confidentiality regarding personal information provided by its clients, suppliers, and other businesses in the course of its real estatebrokerage activities, including via its website (https://www.momentocondos.ca)its social media, its advertisements, as well as for the needs of its CustomerRelationship Management (CRM) systems and Electronic Document Management (EDM)systems, in accordance with the obligations arising from the Act.
What is meant by "personalinformation"?
Personal information" refers to information related to an individualthat allows their identification, directly or indirectly. This information canbe in written form, images, videos, or sound recordings. In the course of itsprofessional activities, Momento Condominiums may collect personal information suchas name, address, date of birth, identity data, social insurance number,financial information, marital status, etc. The following principles ofprotection apply to the collection, use, and transmission of personalinformation that internet users may provide when using the Website.
1. Responsibility
Momento Condominiums takesresponsibility for safeguarding the personal information it holds in the courseof its real estate brokerage activities. To this end, Momento Condominiums has established a privacy policy, as well as policies and practices governing themanagement of personal information. These guidelines are designed to regulatethe collection, use, disclosure, retention, and disposal of this information.
2. Collection of Personal Information
Momento Condominiums collectsonly the personal information necessary for the conduct of its real estatebrokerage activities. For example, this may include information required tocomplete a real estate transaction, maintain records, monitor professionalpractice in accordance with the standards of the Organisme d'autoréglementationdu courtage immobilier du Québec (OACIQ), or for other specific purposesdisclosed and made known to the person giving their consent.Momento Condominiums staff are encouraged to clearly and simply explain the reasons for collectingpersonal information to the individuals concerned. Momento Condominiums also encourages its staff to use standardized forms developed by the OACIQ for thecollection of personal information. Personal information may also be collectedverbally during correspondence or through documents submitted in the course ofa real estate transaction (identity documents, financial documents, powers ofattorney, etc.).
3. Use and Disclosure of Personal Information
Personal information isused and disclosed for the purposes for which it was collected, with theconsent of the individual concerned. In certain cases provided for by law, itmay be used for other purposes, such as fraud prevention or the provision ofservices to the individual. Momento Condominiums may be required to disclosepersonal information to third parties, such as suppliers, co-contractors,subcontractors, agents, insurers (such as the Fonds d'assurance responsabilitéprofessionnelle du courtage immobilier du Québec [FARCIQ], the Fondsd'indemnisation du courtage immobilier du Québec [FICI]), the Autorité desMarchés Financiers (AMF), professionals, financial institutions, or creditverification agencies, as well as electronic document management system (EDM) providers and other regulatory bodies, both within and outside the province ofQuebec. Momento Condominiums may, without the consent of the individual concerned,share personal information with a third party when it is necessary for theexecution of a mandate or a service or business contract. In such cases, Momento Condominiums establishes a specific written mandate or contract outlining themeasures the third party must take to protect the personal information entrusted to them, committing to use it only within the scope of the mandate orcontract and to destroy it after use. The co-contractor must also cooperatewith Momento Condominiums in the event of a breach of the confidentiality ofpersonal information. Before transmitting personal information outside ofQuebec, Momento Condominiums assesses its sensitivity, the purpose of its use, andthe protection measures provided outside the province. Personal information isonly disclosed outside of Quebec if this analysis demonstrates that it willreceive adequate protection in the location of its transmission.
4. Retention and Disposal of PersonalInformation
Once the purposes forwhich personal information has been collected or used have been achieved, Momento Condominiums destroys them, unless the law specifies a specific retention period. Inaccordance with its professional obligations, Momento Condominiums must retain itsrecords for at least six (6) years after their final closure.
5. Data Security
During the collection,use, retention, and deletion of personal information, Momento Condominiums implements adequate security measures to preserve the confidentiality of thisdata. The personal data collected will be stored on servers and in electronicdata management systems that adhere to recognized protection mechanisms andstandards. This is to ensure the security of personal information provided byits clients, suppliers, and other businesses in the course of its real estatebrokerage activities. These activities include, among others, the use of theWebsite, social media, advertisements, as well as the use of CustomerRelationship Management (CRM) systems and Electronic Document Management(EDM)systems. All of this is in compliance with the legal obligations imposedby the Private Sector Personal Information Protection Act.
Privacy Incident
A privacy incident refers to unauthorized access, use, or disclosure ofpersonal information in violation of the Act, loss of personal information, orany other breach of data protection. SIX Agency has established a protocol formanaging privacy incidents. This protocol identifies individuals assisting thePrivacy Officer and outlines specific measures to be taken in the event of anincident. It also defines responsibilities at each stage of incidentmanagement, including measures to ensure data security.
6. Roles and Responsibilities
A. SIX Agency, its Staff, Team Members, orAdministrative Assistants, as applicable:
Ensure the confidentialityof personal information by adopting best practices in information management.This includes providing guidelines, training, and instructions to staff membersregarding the appropriate collection, use, storage, modification, consultation,communication, and proper destruction of personal information. Implementnecessary protective measures to mitigate the risks of privacy incidents. Thismay include computer security practices, updating policies related to personalinformation, staff training, and other actions. Use standardized classificationmethods for documents containing personal information. Apply standardizedmethods for the retention of documents containing personal information,including scanning procedures. Manage physical and digital access to personalinformation based on its sensitivity. Supervise the secure destruction ofpersonal information, providing staff members with guidelines or instructionson the appropriate method of destruction, destruction timelines, etc.
B. Personal Information Protection Officer:
In accordance with thelaw, Momento Condominiums has appointed a Personal Information Protection Officer.The Personal Information Protection Officer ensures compliance with existingpolicies and applicable regulations. They are responsible for managing privacyincidents and take actions as prescribed by the law in this context. Theyhandle requests for access and correction of personal information, as well ascomplaints related to the processing of personal information by Momento Condominiums. They are consulted during the assessment of privacy factors for any projectinvolving the acquisition, development, or redesign of information systems orelectronic service delivery involving the collection, use, disclosure,retention, or disposal of personal information. They may suggest measures toprotect personal information within the scope of such projects.
C. Staff Members, Team, or AdministrativeAssistants:
Staff members, teammembers, or administrative assistants of Momento Condominiums have access topersonal information only to the extent necessary to perform their duties ormandate. They ensure the integrity and confidentiality of personal informationheld by Momento Condominiums. They comply with all policies and directives of Momento Condominiums regarding access, collection, use, disclosure, and destruction ofpersonal information, as well as information security, and follow the providedinstructions. They adhere to the security measures in place in their workplaces and on any equipment containing personal information. They exclusively useequipment and software authorized by Momento Condominiums. They ensure the timelyand secure destruction of personal information, following received guidelines,and promptly report to their supervisor any act that could constitute an actualor suspected breach of security rules related to personal information.
7. Access, Withdrawal, and Correction
Rights Any individual (ortheir authorized representative) has the right to request access to theirpersonal information held by Momento Condominiums. An individual can also withdrawtheir consent at any time regarding the collection, use, and disclosure oftheir personal information. This withdrawal must be recorded inwriting.Furthermore, an individual has the right to request the correction of personalinformation they believe to be inaccurate, incomplete, or ambiguous in theirrecord. Upon request, it is also possible to electronically transfer thepersonal data that Momento Condominiums holds about an individual to a third party. Momento Condominiums reserves the right to refuse a request for access or correction incases provided for by the Law (htps://www.legisquebec.gouv.qc.ca/en/document/cs/P-39.1).
8. Complaints
Any individual whobelieves they have suffered harm related to the processing of their personalinformation by Momento Condominiums can file a complaint. This complaint will beprocessed promptly, and a written response will be provided within a maximum of30 days by the Personal Information Protection Officer. To submit a request foraccess, correction of your personal information, or any other request to whichyou are entitled, or to file a complaint regarding the processing of your personal information, please contact:
Laurent Cardinal
Responsable de la protection des renseignements personnel
L’Agence immobilière SIX
200 Av. Laurier O suite 400, Montréal, QC H2T 2N8
(514) 548-3448
laurent@sixcommunications.ca
