PRIVACY POLICY
Elan provides its Internet users with a secure web environment.
Elan operates in accordance with the Act Respecting the Protection of Personal Information in the Private Sector (RLRQ, c. P-39.1) (hereinafter referred to as the "Act"). In this context, Elan is committed to maintaining high privacy standards regarding the personal information provided by its clients, suppliers, and other businesses in the course of its real estate brokerage activities, including through its website (
https://elanlocatif.ca/), social media, advertisements, and for the needs of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with the obligations arising from the Act.
What is meant by "personal information"?
"Personal information" refers to information related to an individual that allows for identification, either directly or indirectly. This information may be in the form of written data, images, videos, or audio recordings. In the course of its professional activities, Elan may collect personal information such as name, address, date of birth, identification data, social insurance number, financial information, marital status, etc.
The following protection principles apply to the collection, use, and transmission of personal information that Internet users may provide while using the Website.
1. Responsability
Elan assumes responsibility for the protection of the personal information it holds in the course of its real estate brokerage activities. To this end, Elan Locatif has adopted a privacy policy, along with policies and practices governing the management of personal information. These guidelines are intended to regulate the collection, use, disclosure, retention, and destruction of this information.
2. Collection of Personal InformationElan collects only the personal information necessary for the conduct of its real estate brokerage activities. For example, this may include information needed to carry out a real estate transaction, maintain records, monitor professional practice according to the standards set by the Organisme d'auto réglementation du courtage immobilier du Québec (OACIQ), or for other specific purposes that are specified and communicated to the individual giving their consent.
Elan encourages its staff to clearly and simply explain the reasons for collecting personal information to the individuals concerned. The organization also promotes the use of standardized forms developed by the OACIQ for collecting personal information. Personal information may also be collected verbally during correspondence or through documents submitted in the context of a real estate transaction (such as identification, financial documents, powers of attorney, etc.).
3. Utilisation et communication des renseignements personnelsPersonal information is used and disclosed for the purposes for which it was collected, with the consent of the individual concerned. In certain cases provided by law, it may be used for other purposes, such as fraud prevention or providing services to the individual.
Elan may be required to disclose personal information to third parties, such as suppliers, contractors, subcontractors, agents, insurers (such as the Professional Liability Insurance Fund for Real Estate Brokerage in Quebec [FARCIQ], the Real Estate Brokerage Indemnity Fund in Quebec [FICI]), the AMF (Autorité des Marchés Financiers), professionals, financial institutions or credit verification agencies, as well as providers of electronic document management systems (EDM) and other regulatory bodies, both within and outside Quebec.Elan Locatif can share personal information with a third party without the consent of the individual when necessary for the execution of a mandate or service or business contract.
In such cases, Elan establishes a written mandate or contract specifying the measures the third party must take to protect the personal information entrusted to them, committing to use it only within the framework of the mandate or contract and to destroy it after use. The contractor must also cooperate with Elan in the event of a breach of personal information confidentiality.Before transmitting personal information outside Quebec, Elan assesses its sensitivity, the purpose of its use, and the protection measures in place outside the province. Personal information is only disclosed outside Quebec if this analysis demonstrates that it will receive adequate protection at the location of transmission.
4. Retention and Destruction of Personal Information
Once the objectives for which personal information was collected or used have been achieved, Elan Locatif destroys it, unless the law specifies a particular retention period. In accordance with its professional obligations, Elan must retain its records for at least six (6) years after their definitive closure.
5. Data securityWhen collecting, using, storing, and disposing of personal information, Elan implements appropriate security measures to preserve the confidentiality of this data. The personal data collected will be stored on servers and in electronic data management systems that comply with recognized protection mechanisms and standards. This aims to ensure the security of personal information provided by clients, suppliers, and other businesses in the course of its real estate brokerage activities. These activities include, among others, the use of the website, social media, advertising, as well as the use of Customer Relationship Management (CRM) systems and Electronic Document Management (EDM) systems. All of this is in accordance with the legal obligations imposed by the Personal Information Protection Act in the private sector.
Privacy IncidentA privacy incident refers to unauthorized access, use, or communication of personal information in violation of the law, loss of personal information, or any other breach of data protection. Elan has established a privacy incident management protocol. This protocol identifies the individuals who assist the Chief Privacy Officer and outlines concrete measures to be taken in the event of an incident. It also defines responsibilities at each step of incident management, including measures to ensure data security.
6. Roles and ResponsibilitiesA. Elan Locatif, its Staff, Team Members, or Any Administrative Assistants, as Applicable:
Ensure the confidentiality of personal information by adopting best practices in information management. This includes providing guidelines, training, and instructions to staff regarding the collection, use, storage, modification, consultation, communication, and proper destruction of personal information.
Implement necessary protection measures to reduce the risks of privacy incidents. This may include IT security practices, updating personal information policies, staff training, and other actions.
Use standardized filing methods for documents containing personal information.
Apply uniform methods for the retention of documents containing personal information, including scanning procedures.
Manage physical and IT access to personal information based on its sensitivity.
Oversee the secure destruction of personal information by providing guidelines or instructions to staff on appropriate destruction methods, timelines for destruction, etc.
B. Personal Information Protection Officer:
In accordance with the Law, Elan has appointed a Personal Information Protection Officer. The Personal Information Protection Officer ensures compliance with the existing policies and applicable regulations.
They are responsible for managing privacy incidents and take the actions required by the Law in this context. They handle requests for access to and rectification of personal information, as well as complaints related to the processing of personal information by Elan locatif.
They are consulted when assessing privacy factors for any project involving the acquisition, development, or redesign of information systems or electronic service delivery that involves the collection, use, communication, retention, or destruction of personal information. They may suggest measures to protect personal information within the scope of such projects.
C. Membres du personnel, de l'équipe ou tout adjoint administratif :
Members of the staff, team, or any administrative assistant at Elan have access to personal information only to the extent necessary to perform their functions or duties.
They ensure the integrity and confidentiality of the personal information held by Elan.
They comply with all policies and guidelines of Elan regarding the access, collection, use, communication, destruction of personal information, and information security, and follow the instructions provided to them. They adhere to the security measures in place at their workplaces and on any equipment containing personal information.
They exclusively use equipment and software authorized by Elan. They ensure the secure destruction of personal information in a timely manner, in accordance with the directives received, and immediately report to their supervisor any act that may constitute a real or suspected violation of security rules related to personal information.
7. Rights of Access, Withdrawal, and CorrectionAny individual (or their authorized representative) has the right to request access to their personal information held by Elan. An individual may also revoke their consent at any time regarding the collection, use, and communication of their personal information. This revocation must be documented in writing.
Additionally, an individual has the right to request the correction of personal information that they believe to be inaccurate, incomplete, or ambiguous in their file. It is also possible, upon request, to electronically transfer the personal data that Elan Locatif holds about an individual to a third party.
Elan reserves the right to refuse a request for access or correction in cases provided for by the Act (
https://www.legisquebec.gouv.qc.ca/fr/document/lc/P-39.1).
8. ComplaintsAnyone who believes they have suffered harm related to the handling of their personal information by Elan may file a complaint. This complaint will be addressed diligently, and a written response will be provided within a maximum of 30 days by the Person Responsible for the Protection of Personal Information.To submit a request for access, correction of your personal information, or any other request to which you are entitled, or to file a complaint regarding the handling of your personal information, please contact:
Isabelle DroletResponsable de la protection des renseignements personnel
Groupe HD
idrolet@groupehdimmobilier.ca
(514) 390-3224
1751, rue Richardson, Suite 5.109,
Montréal, QC H3K 1G6
