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FLASH – AGENCE IMMOBILIÈRE

Privacy Policy and Personal Information Governance

1. Purpose and Scope

This policy sets out the principles and practices applied by Flash Immobilier inc. (hereinafter "Flash" or the "Organization") with respect to the collection, use, disclosure, retention and destruction of personal information, in accordance with the Act respecting the protection of personal information in the private sector (LPRPSP) and its successive amendments, as well as the professional obligations governed by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ).

This policy applies to all personal information processed by the Organization in the course of its activities, whether in relation to individuals engaging the real estate brokerage services of Flash, visitors and users of its digital platforms, or any other individual whose personal information the Organization may process in the exercise of its functions.

2. Definitions

For the purposes of this policy, the following terms shall have the meanings ascribed to them below:

“Personal information” : any information that concerns a natural person and allows, directly or indirectly, that person to be identified, including name, contact details, financial or patrimonial data, identity documents, family situation, or any other identifying element.

“Processing” : any operation performed on personal information, including its collection, use, disclosure, retention, modification and destruction.

“Third party” : any natural or legal person, entity or external body to whom personal information may be disclosed under the conditions set out in this policy and applicable law.

“Digital platform” : any website, online form, interactive tool or electronic interface operated by or on behalf of Flash.

3. Guiding Principles

The Organization grounds its personal information practices in the following principles:

  • Purpose limitation: personal information is collected for specified, explicit and legitimate purposes and is not processed in a manner incompatible with those purposes.
  • Data minimization: only the information necessary to accomplish the stated purposes is collected.
  • Accuracy: the Organization takes reasonable steps to ensure that personal information is accurate, complete and up to date.
  • Security: appropriate safeguards, proportionate to the sensitivity of the information, are implemented at every stage of processing.
  • Transparency: individuals are informed, at the time of collection, of the purposes pursued and of their rights with respect to their personal information.

4. Collection of Personal Information

4.1 Nature of Information Collected

In the course of its activities, Flash may collect various categories of personal information, including identification details, contact information, financial or patrimonial data, and any other information relevant to the delivery of the services requested or to the completion of a real estate transaction.

4.2 Collection Methods

Personal information may be collected through various channels, including direct interactions with representatives of the Organization, forms and tools available on Flash's digital platforms, documentation submitted in the context of a transactional process, or any other means adapted to the nature of the service provided.

4.3 Consent

The collection of personal information is carried out with the consent of the individual concerned, which must be manifest, free, informed and given for specific purposes. In certain circumstances provided for by law, including the performance of a contract or a legal obligation, collection may occur without express consent.

Any individual may withdraw consent at any time. Such withdrawal is recorded in writing and takes effect within a reasonable timeframe. The Organization will inform the individual of any potential consequences on their ability to receive the services in question.

5. Use and Disclosure of Personal Information

5.1 Purposes of Use

Personal information collected is used for the purposes for which it was gathered, including enabling the completion of real estate transactions, maintaining records in accordance with applicable professional obligations, responding to service requests, and satisfying applicable legal and regulatory requirements.

5.2 Disclosure to Third Parties

In the ordinary course of its activities, Flash may disclose personal information to third parties whose involvement is necessary or beneficial to the achievement of the purposes pursued. Such third parties may include professional partners, service providers, regulatory or oversight bodies, and any other party whose participation is required in the context of the services offered.

Where disclosure is made pursuant to a mandate or service agreement, the Organization ensures that the contractual terms adequately govern the processing of the information entrusted, its use limited to the purposes of the mandate, and its destruction upon the conclusion thereof.

5.3 Disclosure Outside Quebec

Prior to any disclosure of personal information outside Quebec, the Organization conducts a privacy impact assessment to ensure that such information will benefit from adequate protection in the destination jurisdiction, having regard to its nature, sensitivity and the safeguards available.

5.4 Digital Platforms

Personal information collected through Flash's digital platforms, including in the context of information requests or referral inquiries, may be processed for the purpose of responding to such requests and, where applicable, disclosed to the appropriate representatives of the Organization or to relevant partners in the context of the request submitted.

Flash may also use cookies and similar technologies on its platforms to enhance the user experience, analyze service usage and optimize communications. The settings for these technologies may be adjusted by the user through their browser preferences.

6. Retention and Destruction

Personal information is retained for the period necessary to fulfill the purposes for which it was collected, subject to applicable legal and regulatory obligations. In the field of real estate brokerage, files are retained for a minimum period of six (6) years following their definitive closure, in accordance with applicable professional requirements.

Upon the expiry of the applicable retention period, personal information is destroyed or anonymized using secure procedures designed to prevent any reconstitution or subsequent use.

7. Security Measures

Flash implements administrative, physical and technological safeguards proportionate to the nature and sensitivity of the personal information processed. These measures are designed to protect personal information against unauthorized access, use, disclosure, modification or destruction.

The Organization keeps these measures current and adapts them in response to evolving identified risks and recognized best practices in the sector.

8. Privacy Incident Management

A privacy incident refers to any unauthorized access to, use or disclosure of personal information, or any loss of personal information or other breach of its protection.

The Organization maintains a privacy incident management protocol setting out the measures to be taken to contain the incident, assess the risk of harm, notify affected individuals and, where required, the Commission d'accès à l'information du Québec, in accordance with applicable legal requirements.

9. Rights of Individuals

Any individual whose personal information is processed by the Organization holds the following rights, subject to the limitations provided by law:

  • Right of access: to obtain confirmation that their personal information is being processed and to receive a copy thereof.
  • Right of rectification: to have inaccurate, incomplete or ambiguous personal information corrected.
  • Right of withdrawal: to withdraw consent to the collection, use or disclosure of their personal information.
  • Right to portability: to receive, in a structured and commonly used technological format, personal information collected from them, in the cases provided for by law.
  • Right to de-indexation: to request that a hyperlink providing access to their personal information be de-indexed, in the cases provided for by law.

Requests to exercise these rights are processed within the timeframes prescribed by law and are responded to in writing.

10. Privacy Officer

In accordance with applicable legal requirements, Flash has designated a Privacy Officer responsible for overseeing the application of this policy, handling access and rectification requests, and managing incidents and complaints.

For any question, request or complaint regarding the processing of your personal information, please contact the designated Privacy Officer:

Carl Hozjan

Agency Director, Flash Immobilier inc.

Privacy Officer

T: 819 208-9354

Complaints are handled diligently within a period not exceeding thirty (30) business days following receipt. A written response is provided to the individual upon completion of the review.

11. Amendments to This Policy

Flash reserves the right to amend this policy at any time to reflect changes in its practices, applicable legal or regulatory requirements, or any other relevant circumstance. The current version is available at all times on the Organization's digital platforms. In the event of a material amendment, affected individuals will be notified through appropriate channels.

Flash Immobilier inc. — Privacy Policy