Policies and Practices Governing Personal Information Governance

Mario Conte is governed by the Private Sector Personal Information Protection Act (RLRQ, c. P-39.1) (the Act).

Personal Information: Personal information is information concerning an individual that allows, directly or indirectly, for their identification. Written, visual, video, and audio recordings may contain personal information. In the course of professional activities, Mario Conte may collect personal information such as name, home address, date of birth, identification details, social insurance number, income information, marital status, etc.

Consent: Mario Conte collects, uses, and communicates personal information with the consent of the concerned individual. To be valid, this consent must be clear, free, informed, and given for specific purposes. The person consenting to provide their personal information is presumed to consent to its use and communication for the purposes for which it was collected.

Any individual can withdraw their consent to the collection, use, and communication of their personal information by Mario Conte at any time. In such a case, if the collection is necessary for the conclusion or execution of a contract by Mario Conte, they may not be able to accommodate a service request.

Responsibility: Mario Conte is responsible for the protection of personal information held in the course of real estate brokerage activities. For this purpose, Mario Conte has adopted a privacy policy as well as policies and practices governing personal information governance, aiming to regulate the collection, use, communication, retention, and destruction of personal information.

Collection of Personal Information: Mario Conte only collects personal information necessary for the exercise of its activities in the real estate brokerage field. For example, this may include information collected for real estate transactions, record-keeping, monitoring professional practice by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ), or any other purpose disclosed by Mario Conte to the individual whose consent is sought.

For the collection of personal information, Mario Conte encourages its staff or administrators to use standardized forms developed by the OACIQ. Mario Conte may also collect personal information verbally during correspondences with individuals involved in a transaction or through various documents submitted in the context of a real estate transaction (identification documents, financial documents, powers of attorney, etc.).

Use and Communication of Personal Information: Personal information is used and communicated for the purposes for which it was collected and with the consent of the concerned individual. In certain cases provided by law, personal information may be used for other purposes, such as detecting and preventing fraud or providing a service to the individual concerned.

Mario Conte may be required to communicate personal information to third parties, such as suppliers, contractors, subcontractors, agents, insurers (such as the Fonds d'assurance responsabilité professionnelle du courtage immobilier du Québec [FARCIQ]), professionals, other regulators, or outside Quebec.

Mario Conte may, without the consent of the concerned individual, 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, Mario Conte establishes a written mandate or contract indicating the measures the agent must take to ensure the protection of the entrusted personal information, for use only in the exercise of the mandate or contract, and for destruction after its completion. The contractor must also commit to collaborating with Mario Conte in case of a breach of the confidentiality of personal information.

Before communicating personal information outside Quebec, Mario Conte takes into account its sensitivity, the purpose of its use, and the protective measures it will benefit from outside Quebec. Mario Conte will only communicate personal information outside Quebec if its analysis demonstrates that it will receive adequate protection in the location where it is to be communicated.

Retention and Destruction of Personal Information: When the purposes for which personal information was collected or used have been fulfilled, Mario Conte must destroy it, subject to a retention period provided by law. In this regard, Mario Conte's professional obligations require it to retain its records for at least six (6) years following their final closure.

Security Measures: During the collection, use, retention, and destruction of personal information, Mario Conte applies necessary security measures to protect the confidential nature of personal information. Specifically, the following measures apply:

• The collection of personal information should be limited to what is necessary or mandatory.
• Mario Conte's staff ensures the secure collection of information, avoiding public places.
• Personal information will be stored in electronic document management on secure servers for a period of 6 years in accordance with the requirements of the Real Estate Brokerage Act and securely destroyed afterward.

Confidentiality Incident: An incident of confidentiality is unauthorized access, use, communication of personal information as per the law, or the loss of personal information or any other breach of the protection of personal information.

Roles and Responsibilities: Mario Conte:

• Ensures the confidentiality of information through good information management practices. Specifically, provides directives, training, and instructions to staff regarding the collection, use, storage, modification, consultation, communication, and permitted destruction of personal information.
• Implements appropriate protective measures to reduce the risk of confidentiality incidents, such as computer security, updating policies related to personal information, staff training, etc.
• Has standardized methods for classifying documents containing personal information.
• Has standardized methods for retaining documents containing personal information, especially regarding the scanning procedure. Manages physical and computer access to personal information based on their sensitivity.
• Carries out the secure destruction of personal information. Specifically, provides directives or instructions to staff regarding the method of secure destruction, destruction deadlines, etc.

Log Files and Cookies: Certain information is collected through log files and cookies, including IP address, operating system, pages visited, and queries, connection time and day. The use of such files allows for service improvement, personalized reception, consumption profile, and statistics.

Right of Access, Withdrawal, and Rectification: An individual (or their authorized representative) may request access to personal information held by Mario Conte. An individual can withdraw their consent to the collection, use, and communication of their personal information at any time. This withdrawal is then recorded in writing. An individual may request the correction of personal information they believe to be inaccurate, incomplete, or ambiguous in a record concerning them. Mario Conte may refuse a request for access or rectification in cases provided by law.

Complaints: An individual who considers themselves harmed can file a complaint regarding the processing of their personal information by Mario Conte. This complaint will be processed promptly within a maximum period of 10 days by the Privacy Officer, and a written response will be addressed to you.

To request access or rectification of your personal information or to submit a complaint regarding the processing of personal information, please contact us via our contact page.