Privacy Policy
Groupe Sutton Synergie Inc. (hereinafter referred to as the "AGENCY") provides Internet users with a secure online environment.
The AGENCY is governed by the Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1) (hereinafter referred to as the "Act"). Accordingly, the AGENCY is committed to maintaining the highest standards of confidentiality regarding the personal information provided by its clients, suppliers, and other businesses in connection with its real estate brokerage activities, including, without limitation, through the AGENCY'S website (the "Website"), its social media platforms, advertisements, and for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with its obligations under the Act.
What Is Meant by "Personal Information"?
Personal information is any information relating to an identifiable natural person that directly or indirectly identifies that individual.
A written document, image, video, or audio recording may contain personal information.
In the course of its professional activities, the AGENCY may collect personal information such as a person's name, residential address, date of birth, identification document details, Social Insurance Number, income information, marital status, and similar information.
The privacy principles outlined below apply to the collection, use, and disclosure of personal information that Internet users may provide while using the Website.
1. Accountability
The AGENCY is responsible for protecting the personal information it holds in the course of its real estate brokerage activities.
To this end, the AGENCY has adopted this Privacy Policy, as well as policies and practices governing the management of personal information, with the objective of regulating the collection, use, disclosure, retention, and destruction of personal information.
2. Collection of Personal Information
The AGENCY collects only the personal information necessary to carry out its real estate brokerage activities.
For example, personal information may be collected for the purpose of completing a real estate transaction, maintaining records, enabling professional practice oversight by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ), or for any other purpose determined by the AGENCY and communicated to the individual from whom consent is requested.
The AGENCY encourages its employees, team members, and administrative assistants, as applicable, to explain clearly and simply to the individual concerned the reasons why their personal information is being collected and to ensure that those reasons are understood.
For the purpose of collecting personal information, the AGENCY encourages its employees, team members, and administrative assistants, as applicable, to use the standardized forms developed by the OACIQ.
The AGENCY may also collect personal information verbally during communications with individuals involved in a real estate transaction or through various documents submitted as part of a real estate transaction, including, but not limited to:
- Identification documents;
- Financial documents;
- Powers of attorney; and
- Any other documentation required to complete a real estate transaction.
3. Use and Disclosure of Personal Information
Personal information is used and disclosed only for the purposes for which it was collected and with the consent of the individual concerned.
In certain cases provided for by law, personal information may be used for other purposes, including, but not limited to, detecting and preventing fraud or providing services to the individual concerned.
The AGENCY may be required to disclose personal information to third parties, including suppliers, contracting parties, subcontractors, agents, insurers (such as the Quebec Real Estate Brokerage Professional Liability Insurance Fund (FARCIQ) and the Quebec Real Estate Brokerage Indemnity Fund (FICI)), professionals, financial institutions, credit verification agencies, providers of Electronic Document Management (EDM) systems, other regulatory authorities, or organizations located outside Quebec.
The AGENCY may disclose personal information to a third party without the consent of the individual concerned if such disclosure is necessary for the performance of a mandate or a service or business contract.
In such cases, the AGENCY enters into a written agreement specifying the measures the third party must implement to ensure the protection of the personal information entrusted to it, that such information is used solely for the purposes of carrying out the mandate or contract, and that it is securely destroyed once the mandate or contract has ended.
The contracting party must also undertake to cooperate with the AGENCY in the event of a confidentiality breach involving personal information.
Before disclosing personal information outside Quebec, the AGENCY considers the sensitivity of the information, the purpose for which it is to be used, and the level of protection it will receive in the jurisdiction where it is to be disclosed.
The AGENCY will disclose personal information outside Quebec only if its assessment demonstrates that the information will receive adequate protection in the destination jurisdiction.