Privacy Policy
Trillion Real Estate Brokerage inc. (hereinafter “TRILLION”) provides a secure web environment to its Internet users. TRILLION is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (hereinafter, the “Act”) and as such TRILLION strives to preserve the highest standards of confidentiality. higher in relation to the personal information that its clients, suppliers and other companies provide to it as part of its real estate brokerage activities, in particular but without limitation, through the TRILLION website (the “Website”), of its social networks, its advertisements as well as for the purposes of its Customer Relationship Management (CRM) and Electronic Document Management (EDM) systems, in accordance with its obligations under the Law.
What do we mean by “personal information”?
Personal information is information which concerns a natural person and which allows, directly or indirectly, to identify them. A writing, an image, a video and a sound recording may contain personal information. In the course of its professional activities, TRILLION may collect personal information such as name, home address, date of birth, identification document information, social insurance number, information on income, marital status of a person, etc.
The protection principles listed below apply to the collection, use and transmission of personal information that Internet users may provide when using the Website.
1. Responsibility
TRILLION is responsible for the protection of the personal information it holds in the course of carrying out real estate brokerage activities. For this purpose, TRILLION has adopted the confidentiality policy as well as policies and practices governing governance with regard to personal information and the objective of which is to govern the collection, use, communication, conservation and destruction of personal information.
2. Collection of personal information
TRILLION only collects personal information necessary to carry out its activities in the field of real estate brokerage. For example, this may involve information collected for the purposes of carrying out a real estate transaction, for the purposes of record keeping, and for the monitoring of professional practice by the Real Estate Self-Regulatory Organization. of Quebec (OACIQ) or any other purpose determined by TRILLION and brought to the attention of the person whose consent is requested.
TRILLION invites members of its staff, its team or any administrative assistant, as the case may be, to explain in simple and clear terms to the person concerned the reasons for collecting their personal information and to ensure their understanding.
For the purposes of collecting personal information, TRILLION encourages members of its staff, its team or any administrative assistant, as applicable, to use the standardized forms developed by the OACIQ.
TRILLION may also collect personal information verbally during correspondence with persons involved in a transaction or through various documents submitted as part of the completion of a real estate transaction (identification documents, financial documents, powers of attorney, etc. .).
3. Use and communications of personal information
Personal information is used and communicated for the purposes for which it was collected and with the consent of the person concerned. In certain cases provided for by law, personal information may be used for other purposes, for example, for the purpose of detecting and preventing fraud or for the purpose of providing a service to the person concerned.
TRILLION may be required to communicate personal information to third parties, for example, suppliers, co-contractors, subcontractors, agents, insurers (such as the Professional Liability Insurance Fund of Real Estate Brokerage of Quebec [le FARCIQ], the Fonds d’assurance compensation for real estate brokerage in Quebec [le FICI]), to professionals, financial or credit checking institutions as well as suppliers of electronic document management (EDM) systems as well as other regulators, or outside the Quebec.
TRILLION may, without the consent of the person concerned, communicate personal information to a third party if this communication is necessary for the execution of a mandate or a service or business contract. In this case, TRILLION establishes a written mandate or contract in which it indicates the measures that its agent must take to ensure the protection of the personal information entrusted to it, so that it is only used in the exercise of the mandate. or contract and that they are destroyed after its end. The co-contractor must also undertake to collaborate with TRILLION in the event of a violation of the confidentiality of personal information.
Before communicating personal information outside Quebec, TRILLION takes into account its sensitivity, the purpose of its use and the protection measures it will benefit from outside Quebec. TRILLION will only communicate personal information outside of Quebec if its analysis demonstrates that it will benefit from adequate protection in the place where it must be communicated.
4. Retention and destruction of personal information
When the purposes for which the personal information was collected or used have been fulfilled, TRILLION must destroy it, subject to a retention period provided for by law. In this regard, TRILLION’s professional obligations require it to keep its files for at least six (6) years following their final closure.
5. Security measures
When collecting, using, retaining and destroying personal information, TRILLION applies security measures necessary to protect the confidentiality of personal information. The personal data collected will be stored in particular on servers and in electronic data management systems having mechanisms and using recognized standards of protection to ensure the security of the personal information that its customers, suppliers and other companies provide to it in within the framework of its real estate brokerage acts, in particular but without limitation, through the Website, its social networks, its advertisements as well as for the purposes of its Customer Relationship Management (CRM) and Management systems Electronic Documents (GED) and this according to its obligations under the Law.
Privacy incident
A confidentiality incident is the access, use, communication of personal information not authorized by law or the loss of personal information or any other breach of the protection of personal information.
TRILLION has implemented a confidentiality incident management protocol in which the people who assist the Personal Information Protection Officer are identified and which provides for the concrete actions that must be taken in the event of an incident. This protocol provides in particular the responsibilities expected at each stage of incident management, including the measures to be taken to ensure data security.
6. Roles and responsibilities
A. TRILLION, it's staff, team members or any administrative assistant, as applicable
• Ensures the confidentiality of information through good information management practices. More specifically, it provides directives, training and instructions to staff members relating to the collection, use, storage, modification, consultation, communication and permitted destruction of personal information.
• Deploys appropriate protection measures to reduce the risk of confidentiality incidents, for example, IT security, updating policies relating to personal information, training of its staff, etc.
• Has standardized methods for filing documents containing personal information.
• Has standardized methods for preserving documents containing personal information, particularly regarding the scanning procedure.
• Manages physical and computer access to personal information based in particular on its sensitivity.
• Performs secure destruction of personal information. More specifically, it gives directives or instructions to staff members relating to the method of secure destruction, destruction times, etc.
B. Responsible for the protection of personal information
In accordance with the Law, TRILLION has appointed the Personal Information Protection Officer.
In particular, it ensures that these policies are respected and that they comply with applicable regulations. The name and contact information for this person can be found in the “Complaints” section.
The Personal Information Protection Manager is responsible for managing confidentiality incidents and, in this context, takes actions provided for by law.
The Personal Information Protection Officer processes requests for access and rectification of personal information. It also handles complaints relating to the processing of personal information by TRILLION.
The Personal Information Protection Officer is consulted as part of an assessment of the factors relating to privacy for any project for the acquisition, development and redesign of an information system or electronic delivery of services involving the collection, use, disclosure, retention or destruction of personal information. He may suggest measures to ensure the protection of personal information in the context of such a project.
C. Staff members, team members or any administrative assistants
A member of the staff, team or any administrative assistant of TRILLION may access personal information only to the extent that it is essential to the execution of their functions or mandate.
The TRILLION staff member, team member or administrative assistant:
• Ensures the integrity and confidentiality of personal information held by TRILLION.
• Complies with all TRILLION policies and directives on access, collection, use, disclosure, destruction of personal information and information security and follows the instructions presented to it.
• Respects the security measures put in place at their workstation and on any equipment containing personal information.
• Use only equipment and software authorized by TRILLION.
• Ensures, when the time comes, the secure destruction of personal information in accordance with the instructions received. Immediately report to his superior any act of which he becomes aware that may constitute a real or suspected violation of security rules relating to personal information.
7. Right of access, withdrawal and rectification
An individual (or their authorized representative) may request access to their personal information held by TRILLION. An individual may withdraw their consent to the collection, use and disclosure of their personal information at any time. This withdrawal is then recorded in writing.
A person may ask to correct, in a file that concerns them, personal information that they consider to be inaccurate, incomplete or ambiguous.
A person may request to transfer to a third party, electronically, the personal data that TRILLION holds about them.
TRILLION may refuse a request for access or rectification in the cases provided for by law (https://www.legisquebec.gouv.qc.ca/en/document/cs/p-39.1).
8. Complaints
A person who considers themselves wronged may submit a complaint regarding the processing of their personal information by TRILLION. This complaint will be processed diligently within a maximum period of 30 days by the Personal Information Protection Officer and a written response will be sent to you.
To request access, rectification of your personal information or any other request to which you are entitled as well as to submit a complaint regarding the processing of personal information, please contact:
Carla Brown
Responsible for the protection of personal information
Trillion Real Estate Brokerage Inc.
215-655, Centropolis promenade,
Laval (Quebec) H7T 0A3
514-289-8222
info@agencetrillion.com