PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL INFORMATION

Last update: May 2023
In accordance with Bill 25 - An Act to modernize legislative provisions regarding the protection of personal information in the private sector - coming into force on September 22, 2021


Who are we?
Groupe Mercille is a family business based in Longueuil and owns a large real estate portfolio on the South Shore of Montreal. We have 1,234 residential tenants in seven (7) buildings as well as a commercial building of nearly 375,000 square feet including commercial tenants. We own, rent and manage our properties.

Introduction
1. We recognize that your privacy is very important and take it seriously. This Policy on the confidentiality of personal information ("Policy") describes the procedures of Groupe Mercille ("the Company") on the collection, use and disclosure of your information when you enter into a business relationship with the Company or visit and/or use the latter's website accessible from the following address https://groupemercille.com/ ("Website").
2. We will not use or share your personal information with anyone except for the purposes described in this Policy.

Collection and use
3. We may collect and process different types of personal data in the course of operating our business and providing our services. We only collect the personal information that is necessary to provide you with our various services. As far as possible, we indicate the mandatory fields and the optional fields. We may collect the following personal information in particular:

  • basic personal details like your name and job title;
  • contact information such as your telephone number and your postal or e-mail address;
  • financial data such as payment information or bank details;
  • judicial data such as information on your criminal and penal history;
  • demographic data such as your address, preferences or interests;
  • identification information and other background verification information such as a copy of passport or utility bill or source of funds as part of our client acceptance procedures;
  • recruitment-related data such as your resume, education and work history and other information relevant to potential recruitment within the company;
  • website usage and other technical data such as details of your visits to our site; and
  • any other personal data about you that you may provide.

4. We guarantee that we put everything in place to comply with all the requirements of the regulations that affect you and that we respect the main principles of data protection as currently in force throughout the world.

How we collect personal data about you
5
. We may collect or receive your personal data in several different ways:

  • when you provide it to us directly, for example by communicating with us by email, telephone or through other direct interactions with us such as filling out a form, making a request on our website or registering for one of our tools online like the Pronotif e-mailing system and use it;
  • when we provide information about you such as your name and e-mail address when you request rental and/or maintenance service via the Website. We may use your email address to send you Website-related notices (including notices required by law, in lieu of postal mail) and to respond directly to your inquiries, all subject to the rules of the Canada's Anti-Spam Legislation;
  • when we monitor the use of our websites, via a third-party provider, or other email communications sent or received by the Company, or interactions with them;
  • third-party sources, for example, when we collect information about you for our qualification checks which are part of our tenant acceptance procedures or when we receive information about you from agencies or sites recruitment for recruitment purposes;
  • publicly available sources – we may, for example, use such sources to help us verify the qualification criteria of our tenants (including credit inquiries or criminal records) and to keep the contact details we have up to date and accurate already in your regard and for identity verification purposes.

How we use your personal data

6. Unless we have your consent, we use your personal data only where applicable law permits us to do so. Here are the different applications that justify our use of your personal data:

  • Execution of a rental lease and renewal: when your information is necessary to negotiate, enter into, execute or renew the lease with you.
  • Legitimate interests: where we use your information to pursue a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Legal recourse: when your information is necessary for us to defend ourselves in an action brought against us or to bring a lawsuit or make a claim against you or against a third party, as the case may be.
  • With your consent: when you have consented to the use of your information (you will have been given a consent form or a means of expressing your consent in relation to this use and you can withdraw your consent using a similar way).
  • We may also use your personal data for these purposes:
  • To provide you with services such as customer service, maintenance or leasehold improvements or in an emergency;
  • To facilitate the use of our website and to ensure that content is relevant – to respond to inquiries or questions from visitors to our website and to ensure that its content is presented in the most appropriate manner. more efficient for you and for your device (see our Company Website and Cookies section for more information);
  • For research and development purposes – survey and analysis to better understand your needs in order to develop our services and our service offerings;
  • For recruitment purposes – to enable us to process submitted job applications and to assess whether you are suitable for the position with the Company for which you have applied;
  • To fulfill our legal obligations as a Landlord – to comply with our obligations under the rental lease; also, as part of our obligations, we may be required to carry out relevant background checks (if false or inaccurate information is provided and fraud is identified or suspected, details may be forwarded to competent courts and may be registered by us or them); in order to enforce our legal rights, to comply with our legal reporting obligations and/or to protect the rights of third parties;
  • To ensure we get paid – to collect money owed to us and, if necessary, to enforce such collection by engaging the services of debt collection agencies or taking other legal action ( including initiating and conducting legal and court proceedings);
  • To get in touch with you – to notify you of changes in our procedures and regulations, of work of any kind affecting the buildings or your unit and/or affecting our services in general;
  • To reorganize or make changes to the Business – if we reorganize (for example, if we merge or combine our business with another company or if we divest part or all of our business), we may need to transfer some or all of your personal data to the relevant third party (or its advisers) as part of a due diligence process or transfer to the resulting entity or third party reorganizing your personal data for the same purposes as set out in this Privacy Notice or in order to analyze any proposed reorganization;

How and with whom we share your personal information

7. The Company is a local property owner and as such personal data that we collect or that you provide to us may be shared within the Company by employees assigned to particular verification functions for the purposes described more high. That said, measures are put in place by the Company so that only employees who need to access your personal information in the course of their work can do so, and that they are aware of the measures to be taken to ensure this. protection;
8. We may also share your personal data with the following various categories of third parties:

  • our legal advisers, third parties authorized to carry out criminal and financial background checks, our auditors and the courts if necessary;
  • third-party service providers to whom we outsource certain functions such as information and records management, administrative support, technology and IT services, maintenance and fire protection services (we have agreements in place with these service providers to protect the privacy and security of the information (including personal data) that is shared with them);
  • other third-party external advisors or experts who are engaged as part of the services we provide to our clients and with their prior consent, such as lawyers, local legal advisors and technology service providers such as eDiscovery platforms and document review.

9. We may also process your personal data to fulfill our obligations, which may include disclosing your personal data to government, regulatory or law enforcement agencies in connection with inquiries, proceedings or investigations of their leaves anywhere in the world or where we are obliged to. When we are authorized to do so, or unless doing so would compromise the prevention or detection of a crime, we will transmit such a request to you or notify you before responding to it.
10. The Company may share your personally identifiable information with third parties for the purpose of improving your experience when accessing and/or using the Website. If so, the use of your information by such third parties will be subject to this Policy. We may store personal information in places outside of the Company's direct control (for example, on servers or databases hosted by third-party hosting providers).
11. The Company may disclose your personal information if required to do so by law or subpoena or if we believe it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the rights or property of the Company.
International Hosting and Transfer of Personal Information
12. In order to allow us to provide our services to you, we may, through our third-party service providers, process and host the information collected outside of Quebec. Where applicable, we make sure to comply with applicable laws in Quebec regarding the transfer of personal information and ensure that our service providers comply with applicable laws regarding the protection of personal information. We also implement contractual clauses to ensure the protection of the personal information thus transferred.
13. By providing your personal information to or interacting with the Company, you consent to such transfer and hosting.

How We Protect Your Information

14. The Company uses commercially reasonable physical, administrative, and technical measures to maintain the integrity and security of your personal information and to protect it from being accessed, disclosed, altered, or destroyed as a result of a breach of any of our measures. physical, administrative or technical. However, we cannot guarantee the absolute security of the information you transmit to the company via its various platforms.
15. As mentioned, although zero risk does not exist in IT, the company has taken the necessary measures to guarantee the security of your personal information:

  • The Website, the extensions, the scripts and the other programming codes allowing the various functionalities of the Site are regularly updated to correct any possible security breach;
  • Access to the administration of this Website and related services (such as Google Analytics, mailbox etc.) is secured by a password;
  • Access to the interfaces for managing your personal information requires a regularly updated secure Web browser and devices equipped with security devices (automatic locking, antivirus software and applications, passwords, etc.);
  • This Website uses an SSL security certificate which guarantees the encryption of your data when it is sent from your device to the computer server;
  • Tools have been installed on the Website to continuously analyze, detect and eradicate potential malicious threats. These threats include malicious code (malware), malicious URLs and hacking attempts.

16. The safety and security of your personal information is also your responsibility. In the event that you have access to a section of the Site protected by a password specific to you, you are responsible for protecting it. We ask that you do not share your password with anyone else. If you suspect that your password has been compromised, please notify us using the contact details at the bottom of this Policy.

How long we keep your personal data

17. We will retain your personal data for as long as necessary to fulfill the purposes for which that data was collected and other related permitted purposes (for example, certain transaction details and correspondence related to legal services we provide may be retained until the limitation period applicable to claims in respect of the transaction has expired or in order to comply with regulatory requirements with respect to the retention of such data).
18. Your personal information is kept by the Company only for the time corresponding to the purposes for which it was collected, unless a longer retention period is required or authorized by law. If we no longer have a legitimate business interest in continuing to process your personal information, we will delete or anonymize it as required by law.
19. If your personal data is used for multiple purposes, we will keep it until the fulfillment of the purpose requiring the longest period; but we will stop using them for specific purposes as soon as the purposes in question have been fulfilled. Our retention periods are also based on our business needs and best practices.

Your choices regarding your data

20. You can, of course, refuse to submit personally identifiable information through the Website or change your preferences regarding the collection of your information, in which case the Company may not be able to provide you with access to certain web pages or features. If you choose to withdraw your consent to the collection of your personal information, we will notify you of the impacts of this decision to inform you on this subject.
21. If you wish to review, verify, correct or withdraw your consent to the use of personal information about you, you may also email us at rprp@groupemercille.com to request access, correction or deletion of any personal information. that you provided to us. We may not accept a request to change information if we believe the change would violate any law or legal requirement or result in incorrect information in our records.
22. Before granting you access to your information, providing you with the personal information we hold about you, or making any requested changes, we may ask you for information to help us confirm your identity and your right to access this information. In some cases, applicable laws may require us to refuse to provide you with access to some or all of the personal information that we hold about you, or that we may have destroyed, erased or made anonymous in accordance with our legal obligations to record keeping and privacy best practices.
23. If we are unable to provide you with access to your personal information, we will inform you of the reasons, subject to any legal or regulatory restrictions. These restrictions may include, for example, the involvement of information about another person that would reveal their personal information or confidential business information, or information that is difficult to obtain and would be prohibitively expensive to obtain.

Company website and cookies (“cookies”)

24. Our policy on the use of cookies allows you to better understand the provisions that we implement in terms of navigation on our Website.
25. Each time you log on to the Website, we use cookies (more commonly known as "cookies") to store or retrieve information from your browser. A cookie is a small piece of information (text file) that a website, when you use it, asks your browser to store on your device in order to remember information about you, such as your preferences for language, the computer device you are using, your IP address, your country of origin, your type of browser or operating system, the date and time you access the site and the pages visited. The types of cookies used are generally classified into four categories:

  • A. Strictly necessary cookies: They are useful for the Website to function normally and cannot be desactivated.
  • B. Performance cookies (example: Google Analytics): These make it possible to count the visits and the sources of traffic on our Website. If these are deactivated, we will not be able to know when you visited our Website. These cookies are anonymous.
  • C. Functionality cookies: In the event of deactivation, these cookies will ensure that our functionalities will not be optimal, or even faulty.
  • D. Targeting cookies (example: Facebook, LinkedIn): These are used to aggregate information about your activities on our Site and other sites in order to build a profile of your interests. By opting out, you opt out of our targeted advertising on other websites.

26. Once created, cookies generally do not contain any personal information other than the URL of the website that created the cookie file, the duration relating to the capabilities and effects of the file, and a random, encrypted and unique. The Website's computer server can only read the cookies it has placed on your device; it does not have access to any other information on your computer or mobile device. Thus, cookies cannot scan your device and search it to discover your personal information. Due to the limited information contained in a cookie file, it generally cannot be used to reveal your identity or personally identifying information.
27. In summary, cookies are used to facilitate navigation through the pages of the Website, to measure our performance, as well as to compile statistical data.
28. You can, at any time, configure your browser to block cookies. However, you should be aware that this action may deprive you of certain functions offered on the Website or that it may cease to function. If necessary, the Company declines all responsibility for the consequences related to the deterioration of your browsing conditions that occur because of your choice to refuse, delete or block the cookies necessary for the operation of the Site. These consequences do not constitute damage and you will not be able to claim any compensation as a result.
29. Each time you access a web page, information about all events that occur during your navigation are automatically reported by your browser. When you use the Website, our servers automatically record certain information that your browser sends each time you visit our website in server logs. These server logs may contain information such as your web request, IP addresses, browser type, referring/exit pages, number of clicks, domain names, landing pages, page views, and other information.
30. The Company may use Google Analytics to help understand the use of the Website. Google Analytics collects information sent by your browser as part of a web page request, including cookies and your IP address. Google Analytics also receive this information and their use of it is governed by their privacy policies.
Links to other websites
31. We are not responsible for the practices employed by websites linked to or reachable from the Website, or the information or content found there. Remember that when you use a link to go from the Website to another site, our privacy policy no longer applies. Browsing and interaction on any other website, including those which have a link on our Website, is subject to its own rules and policies, and we encourage you to familiarize yourself with them.
Changes to our privacy policy
32. If we change our privacy policies and procedures, we will post those changes on this page to keep you aware of what information we collect, how we use it, and under what circumstances we may disclose it. Changes to this Privacy Policy will be effective when posted on this page.
Contact Us
29. If you have any questions about our approach to the protection of personal information or if you wish to exercise any of the rights mentioned in this Policy, you can contact our Data Protection Officer at one of the following ways:

Groupe Mercille
1111 St-Charles Ouest, Suite 100
Longueuil QC J4K 5G4
Attention : Data Protection Officer
Email : rprp@groupemercille.com