Privacy and Personal Information Protection Policy

General Information

1. Introduction 

Purpose of this Policy. Privacy protection is important to 6881530 Canada Inc. and its affiliates (Brigil) (hereinafter the “Company”, “We”, “Our”, “Us”). For this reason, We have implemented protective measures and sound management practices for your Personal Information in accordance with applicable laws in Quebec and Canada. 

Consent. By using our websites https://brigil.com/, https://carrieres.brigil.com/, and https://carrieres.zohorecruit.com/jobs/Brigil (the “Website”) or any of our Services, you agree that We may collect, use, disclose, communicate, and retain (hereinafter “Process” or “Processing”) your Personal Information under the terms described herein. If you do not agree to comply with and be bound by this Policy, you are not authorized to visit, access, or use our Website or Services, nor to share your Personal Information with us. 

Policy Limitations. This Policy does not apply to the Personal Information of the Company’s employees, representatives, and consultants, or any other person affiliated with the Company, as well as any information that does not constitute Personal Information as defined by applicable laws in Quebec and Canada.

2. Personal Information Protection Officer

Contact Information of the Personal Information Protection Officer. All comments, questions, and complaints regarding the Policy and the Company’s privacy practices can be addressed to our Personal Information Protection Officer at the following contact details:

To process your request, you may be asked to provide appropriate identification or otherwise identify yourself.

  • Definitions 

The following terms and expressions, when appearing with an initial capital letter in the Policy, have the meanings attributed to them below, unless an implicit or explicit exception is made in the text:

  • “Company”, “We”, “Our”, “Us”: Brigil and its related companies
    • “Service Provider”: any natural or legal person who processes Personal Information on behalf of the Company. These are third-party companies or individuals employed by the Company to facilitate the Services, provide the Services on behalf of the Company, perform services related to the Services, or assist the Company in analyzing the use of the Services.
    • “Cookie Banner”: a pop-up window requesting your consent to certain collections of your Personal Information on the Website.
    • “Personal Information”: any information that relates to an individual and allows them to be identified, i.e., that reveals directly or indirectly something about the identity, characteristics, or activities of that person, regardless of the nature of the medium and the form in which this information is accessible (written, graphic, sound, visual, computerized, or other).
    • “Personal Information Protection Officer”: the person responsible for implementing this Policy and whose contact details are identified in section 1b of this Policy.
    • “Services”: Services refer to the applications of the Websites, our social media pages, and all programs and services provided to you, including:
      • Our real estate projects available for sale or rent;
      • Our various built communities;
      • Organizing property visits;
      • Allowing you to apply for our job or internship offers;
      • Allowing you to fill out our information and service requests;
      • Registering and receiving our informative newsletter;
      • Allowing you to view our explanatory videos;
      • Our blog informing you about the real estate market;
      • Our customer service;
  • “Website”: The present Websites, namely: https://brigil.com/, https://carrieres.brigil.com/, and https://carrieres.zohorecruit.com/jobs/Brigil.
    • “Cookie”: Cookies are text files installed on your computer or mobile device. They may contain information about your browsing history, the web pages you visit, and your web browser.
    • “Process”, “Processing”: any operations that may affect or concern personal information, including: collection, use, retention, destruction, communication, or transmission.
    • “You”, “Your”, “Yours”: The persons benefiting from our Services, the visitors to the Website, and all users using the Company’s Services.

3. Processing of Personal Information 

3.1 Collection of Personal Information 

3.1.1 Means of Collection 

We collect your Personal Information through our Website or other technological means in various ways, including:

  • Automatically. When you connect to our Website, the device you use to connect will communicate Personal Information to us;
    • Electronic Forms. By filling out and submitting one of our electronic forms;
    • Emails Communicated. Through the emails you send to us using one of the email addresses available on our Website;
    • Cookies. Through cookies (“Cookies”), including those identified in our Cookie Policy;
    • Partners. Through third parties who collect your Personal Information for us, as identified in section 3.2 of this Policy.

Our Website has features that allow us to profile your activities on our Website, identify you, and locate you. These features are used by third parties identified in section 3.5 through cookies. We disable these features by default. You can enable them through the Cookie Banner.

3.1.2 Personal Information Collected Categories of Information Collected. 

In the course of our activities, We may collect and process different types of Personal Information, including the information listed below:

  • Your contact details and identifiers, including your first and last name, address, email address, phone number. The collection of this personal information is mandatory for anyone wishing to access certain of our Services. We will ask you to provide this information when you wish to register for Services that require it;
    • Information necessary for the provision of our Services, such as details about the Services We have provided or are currently providing to you;
    • Information you choose to provide or transmit to us, for example, when:
      • You fill out an online form to schedule a visit or request information. This information mainly concerns your purchase or rental preferences, interests, budget, and contact details.
      • You contact us regarding a donation or sponsorship request;
      • You communicate with us by phone or email;
      • Your financial information for a lease agreement or a sale, including:
        • Your bank details (account number, institution name, etc.);
        • Your credit history and financial background;
        • Your addresses (current and previous);
        • Your email address and phone contact details.
  • Information collected automatically when using the Websites and our Services, including:
    • Connection information and other details about your activities on our Websites, such as your IP address, the pages you visited, the time and date of your visits, the number of connections, the type of browser you use, your browsing preferences, your device’s operating system, and other hardware and software information;
    • Demographic data and geolocation data, a precise or approximate location determined from your IP address or the GPS of your mobile device (depending on your device settings).

Limitation of Processing to Necessary and Legitimate Purposes. In each case, this Personal Information is processed in accordance with the legitimate and necessary purposes listed in section 3.4 below.

3.2 Collection of Personal Information by a Third Party

  • Zoho Recruit, LinkedIn, and Indeed (HR Tech) communicate certain of your identifiers and contact details to us. We use these services to allow you to apply for jobs. When you apply through these platforms, you may transmit, in addition to your identifiers and contact details, information such as your professional experiences, educational background, other relevant professional information, your resume, and links to your LinkedIn and Facebook profiles.
  • Kijiji Canada: We use their services to promote our products and services, and they collect your identification information for us.
  • Cookie Providers (Google Analytics, DoubleClick, etc.): They collect your identification and profiling information on our behalf.
  • Meta: We use their services to collect information about you via different social networks such as Facebook and Instagram, notably for advertising purposes.

For more details on how these third parties use your data, see section 3.5.3 below.

3.3 Refusing Collection Refusing to Consent. 

Unless required by law or your contractual obligations, you may refuse or withdraw your consent to certain specific uses or communications of your Personal Information:

  • By not entering your Personal Information in our electronic or paper forms where the communication of such information is indicated as optional;
  • By selecting “refuse” in the Cookie Banner; or
  • By communicating a request to our Personal Information Protection Officer at the contact details identified in section 1b) of this Policy.

Measures Offered to Refuse Means of Collecting Personal Information. You may also communicate your Personal Information to us by means other than technological means such as our website. You can communicate this information to us by email, phone, or in person.

3.4 Use of Personal Information Purposes of Personal Information. 

We may use your Personal Information for the purposes described below:

  • Operating, supervising, developing, improving, and offering the functionalities of our Website;
  • Presenting and providing our Services as described in section 2;
  • Evaluating a job application;
  • Fulfilling our contractual obligations to you;
  • Managing billing and processing payments;
  • Handling and resolving complaints and dissatisfaction;
  • Exercising our rights as a landlord;
  • Offering personalized recommendations based on purchase profiles;
  • Developing, improving, and offering new Services;
  • Sending you messages, updates, and security alerts;
  • For marketing and business development purposes, if you have previously consented to the processing of your Personal Information for these purposes;
  • Responding to your questions and providing assistance as needed;
  • Conducting research, analysis, and statistics related to our Company and Services;
  • Detecting and preventing fraud, errors, spam, abuse, security incidents, and other harmful activities;
  • For any other purpose imposed or permitted by applicable laws.

3.5 Access, Communication, and Transfer of Personal Information Possible Access and Communications. 

We may transfer, communicate, or allow access to your Personal Information to our employees and Service Providers who need this information to help us operate our Website, provide our Services, conduct our activities, or serve you.

3.5.1 Access to Personal Information within the Company Limitation of Access to Personal Information.

Your Personal Information is only accessible to our administrators, employees, representatives, and related companies who need access to your Personal Information to perform their duties.

3.5.2 Communication of Personal Information Protective Measures When Communicating to Third Parties. 

We only communicate your Personal Information to our Service Providers if they have previously agreed in writing to ensure the confidentiality of your Personal Information in accordance with applicable laws and our Information Governance Program by implementing various protective and governance measures. These measures are proportionate to the sensitivity of the Personal Information processed or communicated. Without limitation, our Service Providers may only use your Personal Information confidentially according to our instructions and solely for the purposes for which they were provided. Furthermore, We only provide our Service Providers with the Personal Information necessary to perform their mandate or contract and require these Service Providers to appropriately destroy the Personal Information once the contract ends or their use is no longer necessary.

3.5.3 Service Providers and Other Third Parties 

Although We try to avoid communicating your Personal Information to third parties, We may use Service Providers to perform various services on our behalf, such as IT management and security, marketing, and data analysis, hosting, and storage. We have outlined below the cases in which such sharing may occur. Click on the hyperlinks to view their privacy policies:

  • Google Analytics for analyzing website traffic and generating statistics. See their table of cookies for advertising and measurement (in English only). This Cookie communicates to Google the personal information indicated in our Cookie Policy.
  • Google Ads for analyzing our Services’ audience, generating statistics, and communicating with clients and prospects. See their table of advertising and measurement cookies (in English only). These Google Ads Cookies can identify you and profile your web activities to deliver targeted advertising. These Cookies communicate to Google the personal information indicated in our Cookie Policy.
  • DoubleClick for analyzing our Services’ audience, generating statistics, and communicating with clients and prospects. This Cookie can identify you and profile your web activities to deliver targeted advertising. This Cookie also communicates to Google for the purposes identified in our Cookie Policy.
  • Facebook and Instagram of the Meta group, Twitter (X), Kijiji Canada for communicating about our products and Services;
  • Facebook Pixel to understand and deliver ads, generate statistics, and communicate with clients and prospects. This Cookie can identify you and profile your web activities for targeted advertising purposes. This Cookie also communicates to Meta the personal information indicated in our Cookie Policy for the purposes identified therein;
  • YouTube of Google to present our products and Services. Some Google Cookies can identify you and profile your web activities for targeted advertising purposes. These Cookies also communicate to Google the personal information indicated in our Cookie Policy;
  • NoovoMoi of Bell Media to share articles from our blog;
  • PubMatic Cookies for advertising purposes. These Cookies can identify you and profile your web activities to deliver targeted advertising. These Cookies communicate to PubMatic the personal information indicated in our Cookie Policy;
  • Salesforce for managing our clients and Website. All categories of personal information identified in section 3.1.3 may be communicated or retained through this service;
  • LinkedIn and Indeed of HR Tech for recruitment purposes;
  • ZohoRecruit through our page https://carrieres.zohorecruit.com/jobs/Brigil for recruiting our employees. See their privacy policy (in English only);
  • We use services for our newsletter;
  • ComTech Group for IT services;
  • We use Microsoft (Outlook) services to store our documents and emails. All categories of personal information identified in section 3.1 may be communicated or retained through this service;
  • We use Microsoft (Azure) services to host our web services. All categories of personal information identified in section 3.1 may be communicated or retained through this service.

3.5.4 Communication Outside Quebec 

We may communicate your Personal Information outside Quebec and mandate an entity located outside Quebec to collect, use, or retain your Personal Information on our behalf. 

Protections When Communicating Outside Quebec. Before communicating your Personal Information to third parties outside Quebec, We conduct a privacy impact assessment to evaluate the risks that may affect the security of your Personal Information. This assessment also identifies adequate security measures to mitigate or eliminate these risks. The communication will then be subject to a written agreement binding these third parties to comply with such measures.

3.5.5 Compliance with Legislation, Responding to Legal Requests, Preventing Harm, and Protecting Our Rights Specific Communications of Your Personal Information. 

We may communicate your Personal Information when We believe such disclosure is authorized, necessary, or appropriate, including:

  • To respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;
  • To protect our operations;
  • To comply with legal processes;
  • To protect our rights, the privacy of our employees, officers, and directors, our security, and our property;
  • To protect your privacy and rights, or the privacy and rights of third parties;
  • To allow us to pursue available remedies or limit the damages We may sustain; and
  • When it is consistent with or required by applicable laws, including laws outside your country of residence.

3.5.6 Business Transaction Possibility of Business Transactions

We may share, transfer, or communicate, in strict compliance with this Policy and the provisions of the Act respecting the protection of personal information in the private sector, RLRQ c P-39.1 (the “Private Sector Act”) and the Act to modernize legislative provisions as regards the protection of personal information, LQ 2021, c 25 (the “Act 25”, sanctioned on September 22, 2021), your Personal Information in the event of a sale, transfer, or assignment, in whole or in part, of the Company or our assets (for example, following a merger, consolidation, change of control, reorganization, bankruptcy, liquidation, or any other business transaction, including during the negotiation of such transactions). In this case, We will inform you before your Personal Information is transferred and governed by another privacy policy.

3.6 Consent Consents for the Collection, Use, or Communication of Personal Information. 

Unless otherwise provided by law, the Company obtains your consent to collect, use, and communicate your Personal Information. However, if you provide us with Personal Information about others, you must ensure that you have duly notified them that you are providing their information and obtained their consent to such communication. 

Criteria for Required Consent. We will seek your explicit, free, informed, and specific consent before using or communicating your Personal Information for purposes other than those stated herein. We will also seek your explicit consent whenever sensitive Personal Information is involved in one of the Company’s processing activities. We will request your consent for each specific purpose in simple and clear terms, distinctly from any other information communicated to you.

BY USING OUR WEBSITES, TRANSMITTING YOUR PERSONAL INFORMATION BY EMAIL OR USING AN ONLINE FORM, YOU CONSENT TO THIS PRIVACY POLICY AND THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PRIVACY POLICY.

Refusal to Use the Website. If you do not consent, please stop using the Websites. Unless otherwise provided by law, you may withdraw your consent at any time, upon reasonable notice. Please note that if you choose to withdraw your consent to the collection, use, or communication of your Personal Information, some features of our Website may no longer be accessible to you, or We may no longer be able to offer you some of our services.

3.7 Retention of Personal Information Retention of Personal Information

Subject to applicable laws, We retain your Personal Information only for the time necessary to achieve the purposes for which this information was collected, unless you consent to your Personal Information being used or processed for another purpose.

  • Your Rights List of Rights

 As a data subject, you can exercise the rights listed below by contacting our Personal Information Protection Officer in writing at the contact details provided in section 1b) of the Policy. Please note that We may ask you to verify your identity before responding to any of these requests:

  • Right to Information: You have the right to be informed about the Personal Information we hold about you, its use, communication, retention, and destruction, subject to exceptions provided by applicable law.
    • Right to Access: You have the right to access your Personal Information, request a copy of documents containing your Personal Information, subject to exceptions provided by applicable law, and obtain, if applicable, additional details on how We use, communicate, retain, and destroy it by submitting a written request to our Personal Information Protection Officer at the contact details identified in section 1b) of this Policy.
    • Right to Rectification: You have the right to have your Personal Information corrected, modified, and updated if it is incomplete, ambiguous, outdated, or inaccurate by submitting a written request to our Personal Information Protection Officer at the contact details identified in section 1b) of this Policy.
    • Right to Withdraw Consent: You have the right to withdraw or modify your consent to the collection, use, and communication of certain Personal Information collected (as identified in section 3.1 of this Policy) at any time, subject to applicable legal and contractual restrictions.
    • Right to File a Complaint: You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions provided by applicable law.
  • Cookies and Other Similar Technologies Use of Cookies

Cookies allow us to collect certain information during your visit to the Website, including your preferred language, the type and version of your browser, the type of device you use, and the unique identifier of your device. While some cookies are deleted after your browser session ends, other cookies are stored on your device or browser to recognize your browser during your next visit to the Website. We use cookies and other similar collection technologies like Pixels (collectively “Cookies”) to help us operate, protect, and optimize the Website and the Services We offer. They help ensure the Website’s functionality, improve user browsing experience, and provide certain data that helps us better understand traffic and interactions on our Website and detect certain types of fraud. Cookies do not cause any damage to your device and cannot be used to extract your Personal Information. 

Possible Browser Configuration. You can configure your browser to be informed of the placement of Cookies during your visit to the Website, allowing you to decide, in each case, whether to accept or refuse the use of some or all Cookies. Please note that disabling Cookies on your browser may affect your browsing experience on the Website and prevent you from using some of its features. Cookie Policies. For more information on how We use Cookies, please refer to our “Cookie Policy.”

  • Security Measures Objectives of Our Security Measures

 We have implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of your Personal Information against loss, theft, unauthorized access, breaches, disclosure, reproduction, communication, use, modification. These measures include:

  • Administrative Measures. Administratively, We have adopted a series of measures, policies, and procedures as part of our information governance program, which includes managing access, communication, retention, de-identification, and destruction of personal information. This program defines the roles and responsibilities of our employees and establishes procedures for handling privacy incidents, as well as for data protection requests and complaints.
    • Technical Measures. Technically, We use a secure server, firewalls, backup systems, network monitoring systems, task separation systems, access controls, and regular audits of our systems.

We have not exhaustively listed all the measures We have implemented due to the public nature of this Policy.

Despite the measures described above, We cannot guarantee the absolute security of your Personal Information. If you have reasons to believe that your Personal Information is no longer protected, please contact our Personal Information Protection Officer immediately using the contact details provided in section 1b).

  • Modification of this Privacy Policy

 We reserve the right to modify this Policy at any time in accordance with applicable legislation. In case of modification, We will publish the revised version of the Privacy Policy and update the update date in the footer of the Policy. We will inform you reasonably before the new version of our Policy takes effect. If you do not approve the new terms of the Privacy Policy, We invite you to stop using our Website and Services. If you continue to use our Website or Services after the new version of our Policy takes effect, your use of our Website and Services will then be governed by this new version of the Policy.

  • Links to Third-Party Websites 

Occasionally, We may include references or links on our Websites to our Facebook page, third-party websites, products, or services (the “Third-Party Services”). These Third-Party Services are not operated or controlled by the Company and are governed by separate and independent privacy policies from ours. We assume no responsibility for the content and activities of these sites. This Policy applies only to the Websites and Services We offer. We invite you to review their privacy policies. The Policy does not extend to Third-Party Services like our Facebook, LinkedIn, and YouTube pages.

  • Individuals Under 14 Years Old, Consent of Minors 

We do not knowingly collect or use Personal Information from individuals under 14 years old. If you are under 14, you should not provide us with your Personal Information without your parents’ or guardian’s consent. If you are a parent or guardian and learn that your child has provided us with Personal Information without consent, please contact us to request that we delete the Personal Information from our systems.

  1. Applicable Laws Laws of Quebec and Canada

The laws of Canada and Quebec, excluding its conflict of law rules, will govern this agreement and your use of the Website. Your use of the Website may also be subject to other local, provincial, national, or international laws.

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