Privacy policy.

Last updated: October 23, 2023

Introduction

This policy describes how RE/MAX CRYSTAL (“the Agency”) manages and protects its clients' personal information through direct contacts with its representatives and its website alainbrunelle.com.

The policy aims to inform clients about the collection, use, disclosure and retention of their personal data.

1. By what means does the Agency collect personal information?

The Agency collects information through three main methods:

1. Voluntary disclosure to an employee or representative (in writing, by email or in conversation)
2. Collection from other businesses and public bodies, including affiliated RE/MAX group entities
3. Use of the Website (directly via forms or automatically)

2. What personal information does the Agency collect?

• Identification data : last name, first name, contact details (addresses, emails, phone numbers)
• Personal information : date of birth, gender, preferred language
• Identity verification documents : government identity documents, proof of address, bank account/credit card confirmations
• Status : Canadian citizenship or residency
• Sensitive data : real estate project details, financial information (credit card numbers, mortgage approvals, credit reports)
• Communications : call recordings, chat sessions, instant messages
• User-generated information : complaints, requests, comments, survey responses
• Employment data : résumé, education, professional experience, affiliations
• Administrative data : social insurance number (employees), financial information (employees), photographs (website), identity documents (administrators)
• Automatic data : information collected while using the website

3. Information collected automatically or through cookies

The Agency automatically collects during website visits:

• Internet service provider's domain name
• IP address
• Browser type and operating system
• Date and time of the showing
• Country of origin
• Pages viewed and viewing duration
• Referring site address
• Crash data

This information is collected via “cookies” (temporary tracking files) and “web beacons” (invisible pixels) to improve the site's performance and features.

4. For what purposes does the Agency collect personal information?

The Agency collects data to:

• Provide support, information, advice and tools for real estate transactions (“Services”)
• Carry out real estate transactions and be compensated
• Comply with applicable laws and regulations
• Issue notifications and alerts via profiling technology (enabled by the client)
• Assess eligibility for programs (Tranquilli-T, Intégri-T, Programme Clé)
• Communicate with clients about the Services and offer relevant products/services
• Carry out periodic satisfaction follow-ups
• Develop, improve and promote the Services
• Generate and publish de-identified statistical data
• Assess the effectiveness of visitor-acquisition efforts
• Identify the information and actions that interest visitors
• Identify which partner sites generated traffic
• Improve the performance and efficiency of the website
• Identify the legislative regime applicable to visitors
• Review applications for employment or engagement

The Agency obtains consent for any use other than those listed above.

5. To whom may the Agency disclose your personal information?

The Agency uses data for internal purposes but may disclose it to:

1. Employees and representatives who need access to fulfill the listed purposes
2. External service providers (through contractual agreements) required to:
   • Ensure confidentiality
   • Use the data only for contractual purposes
   • Not to keep the data after the end of the contract
   • Notify the Agency of any breach
   • Allow privacy verifications
3. RE/MAX group entities (RE/MAX Québec inc., RE/MAX Promotional Fund inc., RELONAT inc., RE/MAX LLC) to the extent necessary
4. Other persons/entities if required by law or with the client's consent

6. How does the Agency protect the confidentiality of your personal information?

The Agency puts in place physical, technological and administrative measures:

• Identity and criminal-record verification of all employees and representatives
• Confidentiality undertaking signed by all who access personal data
• Access control limited to authorized employees
• Physical data stored in locked premises
• Secure storage of electronic data via an identification and authentication system

Website security

• Encryption of all exchanges between servers and user devices
• Encryption of all user passwords
• Obligations of the IT supplier including periodic validation of practices and continuous monitoring of software components

7. Measures in the event of a privacy incident

The Agency maintains a register of privacy incidents in compliance with applicable legislation. In the event of an incident presenting a risk of serious harm, the Agency notifies clients as required by law. The risk assessment considers the sensitivity of the data, the anticipated consequences and the likelihood of harmful use.

8. Retention period of your personal information

The Agency keeps the data only as long as necessary to:

• Fulfill the purposes listed in section 4
• Comply with statutory obligations (whichever of these deadlines is later)

File closing

• For non-employee clients: usually 6 years after the file is closed
• For employees: at least 7 years from the end of employment
• Subject to statutory obligations providing for a different minimum period

On closing, the data is completely destroyed or anonymized. Anonymization is the process that makes direct or indirect identification of the client impossible, irreversibly.

9. How to access, correct, update and obtain a copy of your personal information?

Clients have the right to access, correct, update and obtain a copy of their data by sending a written request to the Agency (contact details in section 14).

Response time: a maximum of 30 days after receipt. Any request not processed within this period is deemed refused after identity verification.

Grounds for a correction request

• Inaccurate data
• Outdated data
• Ambiguous data
• Incomplete data
• Data collected without justification

Copy format: for computerized data, the Agency provides a copy in a structured, commonly used technological format (unless this raises serious practical difficulties).

Refusal: the Agency communicates the reasons for a refusal and the available recourse, and helps the client understand the grounds.

De-indexing: the client may request that the dissemination of a piece of personal data be stopped and/or that hyperlinks to their name be de-indexed, subject to legal criteria.

Fees: free in principle, but reasonable fees may be charged for transcription, reproduction or transmission (the client is notified before processing).

10. How to withdraw your consent

Subject to contractual commitments and applicable legislation, the client may withdraw or modify their consent by sending a written request to the Agency (section 14).

11. How to file a complaint?

Clients may file a complaint about data-protection methods, practices and policies with the Privacy Officer (section 14).

Processing

• Response within 30 days
• If accepted, a summary of the changes made
• If unsatisfied: a complaint may be filed with the Commission d'accès à l'information du Québec

12. Priority of protection within the RE/MAX Québec Group

For more information on data processing by other RE/MAX group entities:

• RE/MAX Québec inc. : remax-quebec.com/fr/politique-confidentialite
• RE/MAX Promotional Fund inc. : copy on request
• RELONAT inc. : relonat.com/confidentialite

13. No liability for Third-Party Products

The website may contain links to other third-party sites or services that have their own terms of use and privacy policies.

The Agency is not responsible of:

• Third-party terms of use or privacy policies
• Personal data collected by third parties
• Quality, safety, suitability or reliability of third-party products

14. Contacting the privacy officer

To exercise your rights, ask questions, share comments or file a complaint, contact:

The Agency will verify your identity before processing any request.