PRIVACY AND PROTECTION OF PERSONAL INFORMATION POLICY

Protecting your personal or business information is a priority for us. Your consent is essential for us to collect, use and disclose your information. The decision to disclose your personal information to us is yours. Personal information allows us to identify you and to serve you in a way that meets your expectations.

It is our responsibility to ensure that all information collected is handled securely. In this regard, we invite you to read our privacy policy, where you will find answers to your questions, including the nature of the information collected, the reasons why we ask you to provide personal information, what we do with your information and the security measures in place to protect it.

The term “personal information” means any information about you that allows you to be identified, directly or indirectly.


Obtaining your consent


What does my consent involve?

By voluntarily providing us with your personal information, you consent to Développement immobilier Le Croissant inc. (“DICI”) collecting, using and sharing it in accordance with this policy, in order to serve you on a day-to-day basis and to meet our legal obligations.

Your consent is valid only for the time necessary to achieve the purposes for which it was requested, which are described in more detail below.

Please note that we only collect, use and share the personal information that is necessary, unless the law authorizes us to process it otherwise.


Can I withdraw my consent to the use of my personal information or refuse to provide certain information?

You may withdraw your consent to the use of your personal information at any time by contacting our person in charge of the protection of personal information, whose contact details appear below. You may also refuse to provide certain information at any time.

Please keep in mind, however, that if you refuse to provide certain information or withdraw your consent to its use, we may not be able to provide you with all or part of our products and services, since certain information is essential to the relationships we maintain with our clients.


Limiting our collection to what is necessary


What personal information do we collect about you?

Personal information may include: your name; email and mailing addresses; telephone number; date of birth; and any other personal information you may provide to us from time to time.

Please note that if you provide us with personal information about other people (such as your children or other family members), you must ensure that you have duly informed them that you are providing their information to us and that you have obtained their consent to such disclosure, or that you hold parental authority (if information about minors is provided).


How is your personal information collected?

We do not collect your personal information unless you provide it to us voluntarily. We only collect the personal information necessary for the purposes identified before such collection, which are set out below. When you provide us with personal information, you accept the way we collect, use, disclose and manage this information, as described in this policy.

In particular, we may collect your personal information in the following situations, where applicable:

• You complete an information request or a form;
• You take part in one of our contests or promotions, or answer a survey;
• You ask to subscribe to our newsletter or to receive other communications; or
• You contact us by telephone, by email, in person or otherwise.

Whenever possible, we will obtain your personal information directly from you with your consent, when you provide it to us by contacting us in the ways described above.

However, we may collect your personal information from third parties where you have consented to it, in particular from real estate brokers, or where the law permits us to do so.


Being transparent


How do we use your personal information?

We collect personal information to properly complete your file, to respond to your requests and to administer and perform our services.

We may also use your personal information, according to the choice you have expressed, in particular when you subscribe to our mailing list to receive promotional communications, in order to keep you informed of our new products and services or to send you advertising material or additional information about our products, services and surveys, for marketing and solicitation purposes. However, you are free to choose not to receive advertising or commercial material at any time.

In addition, the information you provide to us may be used by us i) for targeting and commercial prospecting purposes, ii) for statistical analysis purposes, in particular regarding market and industry trends, and iii) for the development and continuous improvement of our products and services.

If we use your personal information in contexts other than those mentioned in this privacy policy or those permitted by applicable laws, you will be notified and given the opportunity to consent before any action is taken.


With whom do we share your personal information?

We may disclose your information to service providers retained to provide services either on our behalf or for our benefit, in particular to the following categories of providers:

• Our professional advisors, including, for example, legal, financial, business, risk management or other advisors, bankers, architects and chartered professional accountants;
• Our real estate brokers;
• Our interior designers;
• Our general contractor, its project managers and subcontractors;
• Our insurers and insurance brokers; and
• Third-party service providers for the hosting and maintenance of our site, the hosting of our data through cloud services, billing, bookkeeping, information technology (IT) services, sending emails or other communications on our behalf, or organizing promotions or analyzing the effectiveness of our advertising strategy.

These third parties may have access to or process personal information as part of the services they provide to us. We limit the information we provide to these service providers to only the information reasonably necessary to enable them to perform their duties. Please note that their use of the information we disclose to them is subject to legal restrictions and that they are only authorized to use your information for the sole purpose of performing their duties. Indeed, each of our contracts with our service providers contains commitments designed to protect the confidentiality of the personal information disclosed. Please also note that information may be disclosed outside Quebec, as some of our service providers have facilities in Canada and the United States.

In addition, we may, with your consent, share personal information with other persons or entities involved, directly or indirectly, in the performance of our services, including, for example, your financial institutions.

We may transfer the information we hold about you in the context of a commercial transaction within the company. Please note that any use of the information we disclose in this regard is subject to legal and contractual restrictions for the purposes of the contemplated transaction. Accordingly, a written agreement will be entered into with the other party to the transaction, under which that party will undertake, among other things, to use the information solely for the purpose of concluding the commercial transaction and to take the necessary measures to protect the confidentiality of the information so transferred.

Your personal information will not be used or disclosed for purposes other than those for which it was collected and in accordance with this policy, unless you consent or where the law requires or permits it. In particular, if sensitive personal information about you is used for purposes other than those for which it was collected, you will be notified and given the opportunity to expressly consent before such use is made. Apart from the uses authorized herein or by law, we undertake not to disclose, sell or otherwise transfer to third parties, or exchange with third parties, the information you provide to us.

Finally, please note that if we have to make a decision concerning you, we will ensure that the personal information used to make it is up to date and accurate.


Who has access to your personal information at DICI?

Access to your personal information is limited to DICI representatives who need access to it in the performance of their duties. Accordingly, all of our directors have access to your personal information in order to be able to offer you our products and services.

Our directors are trained in and made aware of the importance of protecting your personal information. In addition, our directors are bound by confidentiality commitments.


Protecting your information


How do we protect your information?

We strive to maintain reasonable physical, technical and administrative safeguards, in accordance with generally accepted industry standards, to protect personal information against loss, theft and unauthorized access, disclosure, copying, use or modification. For example, we manage our server and ensure the effectiveness of our firewall infrastructure so that you can browse safely. To access secure areas of our website, where applicable, a username and password will be required. We constantly review our practices and policies, check our data network, test the effectiveness of our site’s security and carry out every update required to ensure that the confidentiality of your information is never compromised.

Communications over the Internet are subject to interception, loss or alteration. Accordingly, you acknowledge that the information or material you provide electronically by accessing or using this site is neither confidential nor proprietary, except to the extent required by applicable laws, and that unprotected email communications over the Internet may be intercepted, altered or lost.

Although we take the security measures required by law, no security system is infallible. Accordingly, to the extent permitted by law, we cannot guarantee that personal information will not be lost, misused or altered, and we assume no responsibility for the personal information you transmit, or for its use or misuse by you or third parties. You must always be vigilant when handling and disclosing your personal information, in particular by avoiding sending it by unsecured email.

In the event of a confidentiality incident, we will take the necessary measures to limit the risk of harm and will comply with the obligations of the applicable law. In particular, we will inform you if a confidentiality incident has occurred involving your personal information, to the extent required by law.


Where is your personal information stored?

Your personal information is stored in Canada and the United States at all times. To access your personal information, simply contact our person in charge of the protection of personal information, whose contact details appear below.


How long do we keep your personal information?

We will keep your personal information only for the period during which we reasonably need it for the purposes for which it was collected or processed, in accordance with this policy or to comply with the requirements of applicable laws.

Once the retention period has expired, we ensure that your personal information is destroyed by permanently deleting it. Destruction is carried out safely and securely, in accordance with applicable best practices.

If your personal information is not destroyed in the manner described above, it will be anonymized in accordance with generally recognized best practices and the criteria and terms determined by regulation. Information concerning a natural person is anonymized when it is, at all times, reasonably foreseeable in the circumstances that it irreversibly no longer allows that person to be identified, directly or indirectly.


Your rights regarding your information


Right to access, correct or amend your personal information

You have certain rights regarding your personal information. It is essential that you understand these rights. In certain circumstances and in accordance with applicable laws, you have the following rights:

• The right to request access to the personal information we hold about you and to receive a copy of it;
• The right to request that your computerized personal information be communicated to you in a structured, commonly used technological format;
• The right to request the correction of inaccurate, incomplete or equivocal personal information we hold about you;
• The right to require the correction of personal information whose collection, communication or retention is not authorized by law;
• The right to require that the dissemination of personal information about you cease, or that any hyperlink attached to your name providing access to this information by technological means be de-indexed, in certain circumstances;
• The right to request the deletion of personal information that is outdated or not justified by the purpose of the file;
• The right to make written comments and have them added to your file; and
• The right to withdraw your consent to the communication or use of your personal information for the purposes identified above, in particular the use of your personal information for commercial prospecting purposes.

To do so, we invite you to contact our person in charge of the protection of personal information, whose contact details appear below.


Questions, comments, complaints?


Person in charge of the protection of personal information

You may send your questions, concerns, complaints and requests regarding this privacy policy to Me Stéphanie Auclair, person in charge of the protection of personal information, at the following email address: info@imaginelanse.com

You may also contact the person in charge of the protection of personal information to exercise the rights regarding your personal information set out in the previous section. Please note, however, that we can only consider a request for access to or correction of your personal information if it is made in writing by a person who proves their identity as the person concerned, in accordance with applicable laws.

In all cases, we undertake to respond to you no later than 30 days after the date we receive your request.

In the event of any discrepancy between this English version and the French version of this policy, the French version shall prevail.

Last updated: October 3, 2024