Legal Notice
PRIVACY POLICY
This policy aims to ensure the protection of personal information and to define the procedures for the collection, use, disclosure, retention, destruction, and management of information by JAPAQ-Immobilier, including management, employees, suppliers, etc. Furthermore, it aims to inform any concerned individual about the handling of their personal information by JAPAQ-Immobilier, whether they are clients, employees, or any other persons.
RESPONSIBILITY
JAPAQ-Immobilier assumes full responsibility for the protection of personal information under its control. The collection, use, disclosure, retention, or destruction of information is governed by this policy with the aim of safeguarding the privacy of individuals. To ensure the optimal protection of personal information, the person responsible for information protection at JAPAQ-Immobilier must:
- Supervise and review internal practices and procedures for handling personal information and compliance with current laws.
- Propose measures to ensure ongoing protection of personal information that align with privacy impact assessments.
- Implement necessary measures within the company to ensure information protection.
- Ensure compliance and provide training to staff on best practices for protecting personal information.
- Coordinate, investigate, and respond to requests and complaints regarding the protection of personal information.
- Communicate with the individuals concerned and the Access to Information Commission (CAI) in the event of a data breach or any incident.
- Maintain a record of personal data incidents.
Protecting personal information is everyone’s responsibility. No retaliation shall be taken against an individual who files a complaint regarding the protection of personal information or participates in a CAI investigation.
COLLECTION OF PERSONAL INFORMATION
The personal information collected enables the functions of JAPAQ-Immobilier and the conduct of its activities in accordance with applicable laws and standards. JAPAQ-Immobilier collects personal information only when necessary and for specific and defined purposes. Personal information is collected directly from the individual concerned and with their consent, unless an exception is provided by law.
You will find in the Index a non-exhaustive list of collected information and the intended use of the data. Most of the collected personal information pertains to employees to meet the legal obligations of the company. The disclosure of personal information of other individuals may be requested to assist employees in case of emergency, for example. It is the responsibility of employees to obtain consent before providing us with their contact information.
As for customer information, data is provided to populate our CRM, contracts, and billing, but they are mainly professional or business-related information such as email and phone numbers for contacting them or payment methods for services rendered. Payment information is typically entered by the customer into the CRM and is masked from other members of the company to ensure confidentiality. For customers who have filled out a form including their credit card or business or professional bank account number, the data is accessible only to a small number of employees such as administration and owners to process the records.
CONSENT AND ACCURACY OF PERSONAL INFORMATION
JAPAQ-Immobilier ensures that the collection of personal information is done for justified, clear, and specific reasons and with the obtaining of the free and informed consent of the individual. Consent is required for any collection, use, or disclosure of personal information. Before collecting personal information, we will ensure to obtain your informed consent in writing and separately, by providing clear details on the purpose of the collection and how the information will be used. Your consent is essential to ensure the protection of your personal data.
LIMITATION OF USE OF PERSONAL INFORMATION
We collect and use your personal information only when necessary and for the purposes for which consent has been obtained. JAPAQ-Immobilier must provide certain information to meet legal and regulatory verification processes and requirements. The use may vary but could notably serve various purposes as illustrated in the Index.
Information may be disclosed to third parties to the extent necessary for the purposes mentioned in the Index. JAPAQ-Immobilier cannot be held responsible for the behavior and use undertaken by third parties.
Personal information will not be used or disclosed for purposes other than specific objectives unless required by law.
PROTECTION OF YOUR PERSONAL INFORMATION
JAPAQ-Immobilier takes all reasonable precautions and has implemented significant physical and technical measures to prevent unauthorized or unlawful use and access to personal information. Thus, measures in place include, among others:
- Using information only when necessary.
- Ensuring the confidentiality and protection of personal information that an individual may become aware of in the course of their duties, unless authorized to disclose it by the individual concerned.
- Protecting records with selective and limited access to authorized persons.
- Securing access to offices with door locks and access codes.
- Secure shredding of paper records.
- Two-factor authentication in all platform connections.
- Immediate removal of access following the end of a business relationship.
All individuals are required to contribute to the protection of personal information. If you suspect that sensitive information has been compromised, you must immediately notify the person responsible for the protection of personal information.
RETENTION PERIOD FOR YOUR PERSONAL INFORMATION
JAPAQ-Immobilier undertakes to respect the minimum retention periods provided for according to the category of personal information and applicable laws. However, if the information collected is no longer useful for JAPAQ-Immobilier and its retention is not necessary or required according to different legislative frameworks, it will be destroyed, erased, or converted in such a way as to maintain anonymity.
COMMITMENT TO TRANSPARENCY
JAPAQ-Immobilier is committed to being transparent regarding the processing, procedures, and purposes of use that govern personal information with clients, employees, interns, and business partners.
ACCESS TO YOUR PERSONAL INFORMATION
An individual may request access to personal information concerning them and the means used to collect it. Depending on the content of the individual’s file, exceptions may apply, such as personal information about others, but the individual will be informed. If there are inaccurate information(s) in the file, the individual concerned may request correction.
For any consultation, withdrawal, and/or modification of personal information, you can write to the email address info@JAPAQ-Immobilier.com. At any time, you can withdraw your consent to the disclosure of your personal information. A written request must be submitted to the person responsible for the protection of personal information at info@JAPAQ-Immobilier.com. A response will be provided within 30 days of its receipt. When it is not possible to share the requested information, legal justification and support must be provided to support the decision to the requester.
FILING A COMPLAINT
An individual who believes that their personal information has been collected, retained, used, disclosed, or destroyed in a manner inconsistent with the provisions of this policy may file a confidential complaint with the person responsible for the protection of personal information at the email address info@JAPAQ-Immobilier.com. The individual must provide their name, contact information, including a phone number, as well as the subject and reasons for the complaint. Sufficient details must be provided for the complaint to be properly assessed. A response will be provided within 30 days of the date of receipt of the complaint. If the complaint is insufficiently precise, the person responsible for the protection of personal information may request any additional information deemed necessary to evaluate the complaint. The person in charge will conduct an investigation into the complaints received, minimize damages, and make necessary corrections.
It is also possible to file a complaint with the Access to Information Commission of Quebec. However, JAPAQ-Immobilier encourages individuals to first contact the person responsible for the protection of personal information and to wait for the conclusion of the processing procedure.
APPROVAL
This policy is approved by the person responsible for the protection of personal information within JAPAQ-Immobilier.
Person responsible for the protection of personal information: 212B – 35 Allée de Hambourg, Gatineau, Qc, J9J 4J6 info@JAPAQ-Immobilier.com
For any requests, questions, or comments regarding this policy, please contact the responsible person by email.
INDEX
Persons concerned | Information categories | Types of information | Purposes for which information is retained |
Employees | Dotation | Recruitment information, such as curriculum vitae, educational and professional background, details of previous employers to verify employment for potential recruitment. | Internal management (evaluation of applications) |
Hiring (Employees and internships) | Information to be included in the employee file, such as first and last name, contact details, SIN, salary, bank details, employment or internship contract, emergency contacts, etc. | Internal management (payroll operations, legal obligations, CNESST, RRSPs, pay equity, performance management, etc.). | |
Customers and suppliers | Accounting, CRM and project management systems | Information relating to services requested and/or rendered.
Billing and financial information, such as billing address, bank account information or payment details. | Internal management (IT services, cybersecurity, billing, project management, communication management, program information gathering, contracts and service agreements) |