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Confidentiality Policy
(Hereinafter the “policy”)
Summary
Means
Personal information is collected:
  1. when voluntarily sending such personal information to a RELONAT employee or authorized representative by the means of communication of your choosing to disclose your information;
  2. automatically or using cookies when using the website;
  3. when you create your user account with a Web form and when you upload documents to the website’s portal;
  4. when you authorize a RELONAT partner to share such personal information (i.e., RE/MAX Québec Inc., Fonds Promotionnel RE/MAX Inc., or RE/MAX, LLC (Denver, CO)) (hereinafter collectively referred to as “RE/MAX Group”).
Purposes
Personal information is collected and used to:
  • provide support, information, advice and tools relating to any relocation project, whether or not it is carried out by an employer (usually referred to as “services”);
  • allow you to create a user account to access the website’s portal section to upload documents required to carry out the services;
  • communicate with you, in a general manner, to send various information relating to the services and offer products and/or services that are likely to interest you;
  • schedule appointments and follow up periodically with you to ensure that you are satisfied with the services being provided;
  • measure the effectiveness of RELONAT’s efforts to attract visitors to its website;
  • determine what information should be made available by RELONAT and the efforts it is taking to raise visitors’ interest in its website;
  • identify which of our partner sites’ efforts have attracted visitors;
  • improve the website’s performance and its ability to effectively retain visitors;
  • identify the legal regime to which visitors’ personal information is subject;
  • fulfill our legal obligations;
  • review your employment application with RELONAT as necessary; and
  • respond to your information requests or follow up on your comments as necessary.
Communications
Personal information is communicated to the following entities:
  • RELONAT employees and representatives who need to access this personal information for the aforementioned purposes;
  • external service providers used by RELONAT;
  • members of RE/MAX Group, to the extent necessary so that they can fulfill their contractual and statutory obligations as the RE/MAX Group’s mortgage referral partner;
  • Sage Software Canada Ltd. (to ensure that the in-house management software is operating properly);
  • Cologix Canada, Inc. (so they can provide RELONAT with cloud hosting services);
  • Datto Inc. (so they can provide RELONAT with cloud hosting services); and
  • any other person or entity, when prescribed or allowed by applicable legislation, or with the client’s consent.
Your personal information may be communicated to persons or entities located outside the province of Québec.
Your rights
  • You have the right to access, correct and withdraw consent to use your personal information. Please consult sections 10 and 11 of this policy for more information regarding the terms and conditions governing your rights.
  • You can also make a complaint by following the instructions set out in section 13 of this policy.
Consent
By providing personal information to RELONAT through (i) direct or indirect contact with an authorized RELONAT representative; (ii) your use of the RELONAT website; (iii) the use of an online form when you create your user account and when you upload documents to the RELONAT website’s portal; and/or (iv) your authorizing the RELONAT partner to communicate them; you consent to RELONAT compiling, using, disclosing and retaining this personal information in compliance with the terms and conditions set forth in this policy.
 
 
Confidentiality Policy
(Hereinafter the “policy”)
Updated: July 17, 2023
This policy documents the measures and practices that LES SERVICES DE RELOGEMENT NATIONAL (RELONAT) INC. (hereinafter “RELONAT” or “we” or “us”) has implemented to govern the use and safeguarding of its clients’ personal information. Clients (or “you” or “your”) are individuals from whom RELONAT collected personal information through (i) direct or indirect contact with an authorized RELONAT representative; (ii) https://www.RELONAT.com (hereinafter the “Website”) and (iii) its partners who are authorized to communicate such personal information for the purposes described in section 5 below.
In this policy, the term “personal information” refers to all personal information collected by RELONAT that allows it to directly or indirectly identify a client, either independently or with other information.
The main purpose of this policy is to inform clients of:
  • the means by which RELONAT collects personal information;
  • the nature of the personal information collected by RELONAT and the purposes for which it is collected;
  • how RELONAT may use personal information as well as third parties with which RELONAT is likely to share this personal information if required;
  • your rights with regard to the personal information compiled by RELONAT, particularly to access your personal information or request that inaccurate personal information be corrected if necessary;
  • the various safeguards implemented by RELONAT to safeguard the confidentiality of the personal information;
  • how personal information is retained, destroyed and/or anonymized;
  • how you can contact RELONAT to ask questions, share your comments or, if necessary, make a complaint regarding this policy.
By providing personal information to REOLONAT through (i) direct or indirect contact with an authorized RELONAT representative; (ii) your use of the website; (iii) the use of an online form when you create your user account with a Web form and when you upload documents to the website’s portal; and/or (iv) your authorizing the RELONAT partner to communicate them, you consent to RELONAT compiling, using, disclosing and retaining this personal information in compliance with the terms and conditions set forth in this policy.
RELONAT reserves the right to modify the terms and conditions set forth in this policy at any time and at its sole discretion. In this situation, RELONAT will send a version of this policy that includes the changes made. Your use of the services (as defined in section 5 below) as of the receipt of this version is deemed to constitute your express acceptance of the changes made.
This policy as well as all of its modified versions are subject to applicable legislation in the province of Québec.
1.     Through what means does RELONAT collect personal information?
RELONAT collects personal information through the following means: (i) when voluntarily sending such personal information to a RELONAT employee or authorized representative; (ii) when using the website; and/or (iii) when you authorize a RELONAT partner to share such personal information (such as RE/MAX Québec Inc. and Fonds Promotionnel RE/MAX Inc.).
2.     What personal information does RELONAT collect?
RELONAT may collect the following personal information:
  • your first and last name and your contact information (street addresses, email addresses, telephone numbers);
  • your date of birth (age), sex (or gender identity), citizenship/status in Canada and language preference;
  • any personal information that allows RELONAT, through its authorized representatives, to verify your identity and that of any other person in compliance with applicable legislation (profession or primary occupation, authentic, valid and current government-issued photo ID, a document from a trusted source with your name and address, a document from a trusted source with your name and date of birth and a document with your name as well as confirmation that you have a deposit account, a prepaid payment product account, or a credit card or another loan account with a financial entity);
  • personal information that you share with us to carry out services (as defined in section 4 below) and that are likely to constitute sensitive personal information (information regarding a relocation project, information regarding a client’s family situation and financial information to make credit checks and withdraw instalments and payments);
  • your conversations and communications history with us (call recordings, email exchanges) or on third-party platforms;
  • personal information generated by you when using the services (proof of consent, notices, comments and answers to surveys);
  • personal information provided as part of an employment application with RELONAT (resume, educational background, professional experience and affiliations);
  • personal information that you are required to share with RELONAT due to the nature of your relationship with it (e.g., if you are a RELONAT employee, you will be asked to provide your social insurance number and certain financial information. If you are a director, you must provide a piece of ID in accordance with the Act mainly to improve the transparency of enterprises);
  • personal information automatically collected through your use of the website (see sections 3 and 4).
3.     Personal information collected automatically or with cookies
To ensure that the website functions properly, RELONAT must collect the following information from clients that visit the website:
  • their IP address;
  • their browser (Explorer, Firefox, etc.) and their operating system (Windows, Mac OS, etc.);
  • the date and time of their visit; and
  • their country of origin.
All this information is collected automatically from the time a client logs on to the website. Certain personal information is collected through temporary cookies or “web beacons” (aka “invisible pixels”). These files or beacons also allow us to improve the website’s performance as well as some of its functions.
 
4.     Personal information collected on the portal through web forms or by uploading documents
RELONAT will collect users’ personal information when they are asked to provide information in a web form to create their user account. RELONAT will also collect users’ personal information when they and you upload documents to the website’s portal.
5.     For what purposes does RELONAT collect personal information?
RELONAT collects your personal information to:
  • provide support, information, advice and tools relating to any relocation project, whether or not it is carried out with the assistance of an employer (usually referred to as “services”);
  • allow clients to create a user account to access the website’s portal section to upload documents required to carry out the services;
  • communicate with you, in a general manner, to send various information relating to the services and offer products and/or services that are likely to interest you;
  • schedule appointments and follow up periodically with you to ensure that you are satisfied with the services being provided;
  • measure the effectiveness of RELONAT’s efforts to attract visitors to its website;
  • determine what information should be made available by RELONAT and the efforts it is taking to raise visitors’ interest in its website;
  • identify which of our partner sites’ efforts have attracted visitors;
  • improve the website’s performance and its ability to effectively retain visitors;
  • identify the legal regime to which visitors’ personal information is subject;
  • fulfill our legal obligations;
  • review your employment application with RELONAT as necessary; and
  • respond to your information requests or follow up on your comments as necessary.
Subject to exceptions under applicable legislation, RELONAT will ensure that it obtains your consent prior to using your personal information in any way for any purpose other than those listed above.
Clients are asked to use the website’s portal section only to upload documents containing personal information requested by RELONAT for the purposes described above. Should a client upload documents containing other personal information, RELONAT reserves the right to refuse access to or to retain these documents.
Please note that you are responsible for obtaining an individual’s consent prior to communicating any personal information about this individual to RELONAT, including your family members. Similarly, RELONAT does not knowingly collect any personal information regarding minors younger than fourteen (14) years old, unless (i) consent has been obtained from the holder of parental authority or the guardian, as the case may be, or (ii) the collection of this information is clearly to the benefit of the minor involved.
6.     With whom is RELONAT likely to share your personal information?
Generally, RELONAT uses its clients’ personal information for internal purposes only. However, RELONAT is likely to share your personal information with the following persons or entities:
a.    its employees and representatives who need access to this personal information to carry out the purposes listed in section 5 above;
b.    its partners and external service providers with whom RELONAT has entered into a contractual agreement under which the external service provider is required to take appropriate measures to:
i) safeguard the confidential nature of the personal information shared;
ii) ensure that the personal information shared is only used for the purposes of carrying out the services it is asked to render for RELONAT;
iii) ensure that the personal information shared is not kept after the aforementioned agreement has ended;
iv) immediately notify RELONAT of any violation or attempted violation by an individual of any obligation relating to the confidentiality of the personal information shared; and
v) allow RELONAT to perform all checks relating to the confidentiality of the personal information shared. For example, RELONAT may share your personal information with appraisal and home inspection firms, companies specializing in moving or temporary housing and real estate professionals to carry out an agreement that is part of service delivery.
c.    entities that are part of the RE/MAX group with which RELONAT is affiliated (RE/MAX Québec Inc., Fonds Promotionnel RE/MAX Inc. and any other real estate brokerage agency affiliated with RE/MAX Group), to the extent necessary so that they can fulfill their contractual and statutory obligations as the RE/MAX Group’s mortgage referral partner;
d.    any other person or entity, when prescribed or allowed by applicable legislation, or with the client’s consent.
RELONAT shares your personal information outside Québec. However, RELONAT only does so if a privacy impact assessment shows that the receiving party is able to adequately safeguard said personal information, particularly with regard to generally accepted privacy principles. In such circumstances, RELONAT contractually requires the entity with whom your personal information is shared to comply with various conditions to ensure that your personal information is safeguarded, including but not limited to all conditions under section 7.
7.     How does RELONAT protect the confidentiality of your personal information?
RELONAT takes appropriate physical, technological and administrative privacy measures to safeguard your personal information and reduce the risk of unauthorized/illegal access, use, disclosure and destruction.
Without limiting the generality of the foregoing, RELONAT:
  • checks the identity and criminal record of all its employees;
 
  • requires each of its employees and representatives with access to personal information to sign a confidentiality agreement;
 
  • retains personal information on storage devices contained on premises that are locked and only accessible by authorized employees and representatives of RELONAT;
 
  • restricts access to your personal information to authorized individuals who need such access to carry out one or several of the purposes listed in section 5 of this policy; and
 
  • retains personal information on secure devices, i.e.: (i) the Sage software provided by Sage Software Canada Ltd.; (ii) the cloud servers located in Montréal and provided by Cologix Canada, Inc. and (iii) the cloud servers located in Toronto and provided by Datto Inc.
Furthermore, the website is equipped with certain security mechanisms aimed at safeguarding your personal information, i.e.:
  • the website’s data are encrypted when idle;
 
  • all communications between the website’s various components are encrypted;
all privacy settings applicable to your use of the website offer, by default, the highest level of privacy, without any intervention from you. Therefore, any technology that can identify, locate or profile you is deactivated by default and will only be activated if you expressly consent to it. Please note that these principles do not apply to cookies, web beacons and log files, which are addressed in section 3 of this policy.
8.     What measures has RELONAT implemented to address confidentiality incidents?
RELONAT maintains a current confidentiality incident log, in compliance with applicable legislation. Should a confidentiality incident that presents a serious risk of harm to you occur, RELONAT will take necessary measures to notify you, in compliance with applicable legislation. The risk that serious harm has been caused to you is determined based on criteria such as awareness of the personal information that is involved in the confidentiality incident, the likely consequences of its use and the probability that it is used for harm.
9.     How long is personal information retained?
Pursuant to our procedures for safely retaining and disposing of personal information, we only retain your personal information for the duration necessary to accomplish the purposes listed in section 5 of this policy or for the term required for us to comply with our statutory obligations, whichever occurs later.
RELONAT reserves the right to close a client’s file on which no administrative action has been taken for a consecutive period of at least three (3) years or, in the case of RELONAT employees, a consecutive period of at least seven (7) years as of the last day of employment, all of which is subject to a statutory obligation providing a different minimum retention period. The closure of a file means that the personal information contained therein will be completely and definitively disposed of, or will be anonymized so it can be used for serious and legitimate purposes. When closing a file regarding a client who is not a RELONAT employee or representative, the personal information contained therein must be destroyed or anonymized usually seven (7) years after the date said file is closed due to the retention period imposed by law.
Under this policy, the term “anonymization” means the process in which personal information no longer allows for the client to which it is tied to be directly or indirectly identified, in a way that is irreversible.
10.     How can you access, correct, update and/or obtain a copy of your personal information?
RELONAT acknowledges its clients’ right to access, correct, update and obtain a copy of their personal information by presenting a written request to this effect to RELONAT using the contact information in section 15 below. Should such a written request be sent to RELONAT, the company would carefully respond to it in writing within thirty (30) days of receipt of said request.
A request to correct personal information will be granted under certain circumstances including:
  • the personal information is inaccurate;
  • the personal information is outdated;
  • the personal information is ambiguous;
  • the personal information is incomplete; or
  • the personal information has been unjustifiably collected.
Should RELONAT acquiesce to any client request to obtain a copy of computerized personal information, RELONAT will ensure to send them (or any other person or agency authorized by law to collect such personal information, according to the client’s request) a copy in a structured and commonly used technological format. This subsection is not applicable (i) if sending the copy in such a technological format presents serious practical challenges and/or (ii) regarding any computerized personal information that was created or inferred from other personal information.
Should RELONAT refuse to acquiesce to any client request to access, correct or update personal information, RELONAT will ensure to share with them the reasons for this refusal as well as any recourse the client has under the circumstances and the timeframe in which it may be exercised. To the extent the client requires, RELONAT shall also provide them with assistance to help understand the reasons for the refusal.
Should a written request to this effect be sent by the client, RELONAT may also cease dissemination of the client’s personal information and/or deindex or reindex, as the case may be, any hyperlinks tied to this client’s name, subject to criteria established by applicable legislation in force at the time.
In principle, the exercise of a right provided for in this section by the client is free of charge. However, the client in question may be required to pay reasonable fees to offset the cost of transcribing, reproducing or transmitting their personal information. In such a case, the client will be notified of the amount of the fees in question before their request is processed.
11.     How can you withdraw your consent for the use or sharing of your personal information?
Subject to your contractual commitments with RELONAT and applicable legislation, you can withdraw or modify your consent for the collection, use and/or sharing of your personal information. To do so, you must submit a written request to this effect to the privacy officers at RELONAT using the contact information in section 15 below.
Please note that withdrawing or modifying your consent is likely to restrict or prevent RELONAT from providing services to you, including access to and use of the website.
12.     How to file a complaint
You can make a complaint about the personal information safeguarding methods, practices and policies by writing to our privacy officer using the contact information in section 15 of this policy.
All complaints will be handled directly by our privacy officer. A response will be sent within 30 days of receiving the complaint. If the complaint is accepted, a summary of the changes made to the subject of the complaint will be sent to you.
13.     RELONAT has no responsibility or obligation towards third-party products
The website is likely to contain links to other websites or third-party products and services (collectively referred to as “third-party products”). Third-party products may be subject to conditions of use and a confidentiality policy that differs from RELONAT’s. RELONAT cannot in any case be held responsible or subject to any obligation regarding the content of these third parties’ terms of use and/or confidentiality policy. Without limiting the generality of the foregoing, RELONAT has no responsibility or obligation regarding any of your personal information that may be collected, used, disclosed or retained by any person or entity in relation to your access or use of third-party products.
Any link on the website leading to a third-party product does not imply or mean in any way that RELONAT assumes or accepts responsibility for the content or use of this third-party product. RELONAT makes no representations regarding the quality, safety, adequacy or reliability of third-party products, or the content or equipment they contain. When you access or use third-party products, you should consult the related conditions of use and confidentiality policy.
14.     How can you contact RELONAT’s privacy officer?
We are responsible for your personal information. Consequently, we have designated a privacy officer at RELONAT. To exercise one of your rights, ask questions, make comments or file a complaint regarding this policy or in relation to our handling of your personal information, please contact this person at the following address:
TO: Julie Smythe, Privacy Officer
LES SERVICES DE RELOGEMENT NATIONAL (RELONAT) INC.
1500 Cunard
Laval, QC, H7S 2B7
 
Toll-free: 1-877-777-0770
Email: renseignements.personnels@relonat.com
 
Please note that RELONAT is required to verify your identity before responding to any request, question, comment or complaint filed with its privacy officer.
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