TRIMONT QUEBEC INC. (hereinafter referred to as “THE AGENCY”) operates under the Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1) (hereinafter referred to as the “Act”). THE AGENCY is committed to maintaining the highest standards of confidentiality for personal information provided by its clients, suppliers, and other entities as part of its real estate brokerage activities. This includes, but is not limited to, information collected through its website (the “Website”), social media, advertisements, and for Electronic Document Management (EDM) purposes, in compliance with the Act. Personal Information Personal information refers to any information about an individual that can directly or indirectly identify them. This may include documents, images, videos, and audio recordings containing personal details. In its professional activities, THE AGENCY may collect personal information such as names, home addresses, dates of birth, ID details, Social Insurance Numbers, income data, marital status, and more. The following principles govern the collection, use, and transmission of personal information provided by internet users when accessing the Website. Consent THE AGENCY collects, uses, and discloses personal information with the consent of the individual. This consent must be explicit, voluntary, informed, and for specific purposes. By providing personal information, individuals are presumed to consent to its use and disclosure for the purposes for which it was collected. Individuals may withdraw their consent at any time. However, if the collection is necessary to conclude or fulfill a contract with THE AGENCY, the inability to collect such data may result in an inability to provide services. Responsibility THE AGENCY is responsible for protecting the personal information it holds as part of its real estate brokerage activities. To this end, it has adopted a privacy policy and governance practices to manage the collection, use, communication, retention, and destruction of personal information. Collection of Personal Information THE AGENCY collects only the personal information necessary for its real estate brokerage activities. Examples include information needed for real estate transactions, record-keeping, professional practice oversight by the Organisme d'autoréglementation du courtage immobilier du Québec (OACIQ), or other purposes communicated to the individual for which consent is obtained. Personnel are trained to explain, in clear terms, the reasons for collecting personal information and ensure individuals understand them. THE AGENCY also uses standardized forms developed by the OACIQ and may collect information verbally or through documents submitted during transactions. Use and Disclosure of Personal Information Personal information is used and disclosed for the purposes for which it was collected and with the individual's consent. In certain circumstances, such as fraud prevention or service provision, the law allows other uses. THE AGENCY may disclose personal information to third parties such as suppliers, subcontractors, agents, insurers (e.g., FARCIQ), professionals, or regulators, including those outside Quebec. When sharing information outside Quebec, THE AGENCY ensures adequate protection measures are in place. Retention and Destruction of Personal Information Once the purposes for which personal information was collected or used have been fulfilled, THE AGENCY destroys the data unless required to retain it for a legally mandated period. Records are typically retained for a minimum of six years after closure. Security Measures THE AGENCY implements security measures to safeguard the confidentiality of personal information during collection, use, storage, and destruction. These measures include: IT security protocols Policy updates Staff training Secure document management and destruction practices Privacy Incidents A privacy incident involves unauthorized access, use, disclosure, or loss of personal information. THE AGENCY has established a protocol for managing such incidents, identifying responsible parties, and detailing necessary actions to secure the data and comply with legal requirements. Roles and Responsibilities THE AGENCY Maintains confidentiality through proper information management practices, including staff training and policy enforcement. Implements security measures to minimize privacy risks, such as IT security and standardized document handling. Privacy Officer Ensures compliance with privacy policies and laws. Manages privacy incidents and processes requests for access, rectification, or complaints. Provides guidance on privacy impact assessments for projects involving personal information. Personnel Access personal information only when necessary for job duties. Follow established policies for handling, storing, and destroying personal information securely. Report any suspected security breaches to their supervisor immediately. Access, Withdrawal, and Correction Rights Individuals may: Request access to personal information held by THE AGENCY. Withdraw consent for the collection, use, or disclosure of personal information, recorded in writing. Request corrections to personal information deemed inaccurate, incomplete, or ambiguous. Request electronic transfer of their data to a third party. THE AGENCY may deny requests under circumstances outlined in the Act. Complaints Individuals who believe their personal information has been mishandled may file a complaint, which will be addressed within 30 days by the Privacy Officer. A written response will be provided. To request access, correction, or submit a complaint regarding personal information, contact: Peter Mouhteros Trimont Quebec Inc. 4480 Chemin de la Côte-de-Liesse, Suite 290 Mont-Royal (Montréal), QC, H4N 2R1 (514) 736-0511 pmouhteros@trimontcanada.com