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Application of the Privacy Protection Policy

1. Who is covered by this Privacy Protection Policy?
Our clients, our authorized house, condo and apartment tenants, users of our other products and services as well as our company employees.

2. Is this the only Privacy Protection Policy?
Even though this document is as comprehensive as possible, it cannot cover all situations where we process personal information. As a result, it is possible that some of our products or services may also have their own privacy protection policies. Notification of policies specific to a product or service is provided several ways, according to the circumstances.

3. What companies are covered under this Privacy Protection Policy?
This Privacy Protection Policy applies to our entire corporate family, as well as any successor companies following a corporate reorganization or restructuring. Even though our authorized agents and suppliers may have their own privacy protection policies, our contracts ensure that they process your personal information using measures as strict as those stipulated in this Privacy Protection Policy.

4. What information is covered by this Privacy Protection Policy?
Any personal information that we collect, use or disclose about our individual clients, our authored users and our employees is covered by this Privacy Protection Policy. This information may include your name, mailing address, email address and telephone number. Applicable legislation stipulates certain exceptions to what is normally considered personal information.

5. Is any information that identifies me considered protected personal information?
Not necessarily. When certain personal information (such as your name, mailing address, phone number and email address) is listed in a public directory, it not protected by privacy laws. Your business contact information (such as your name, title, as well as your work address, email and telephone number) that is used for your work or company is also excluded. Information about you but that cannot be used to identify you is not considered personal information. For example, information about you that has been made anonymous so that you cannot be personally identified is not considered personal information.

Consent and your personal information

6. Do companies need my consent to collect, use or disclose my personal information?
It depends on the type of personal information and on the circumstances. If your personal information is collected, used and disclosed under reasonable circumstances, your consent is implicitly granted by your actions. For example, if you provide us with your address, we can use it to send you invoices or other important notices about your products and services, given that your consent can be reasonably inferred. In other situations, we may have to obtain your express consent before collecting, using or disclosing your personal information.

7. How do companies obtain my consent?
It depends on the circumstances, including the type of personal information being collected, used or disclosed. Your consent can be inferred, if this is reasonable under the circumstances. We may request your express consent when we collect, use or disclose more sensitive or unexpected personal information. Here are a few examples of implied and express consent: when you register as a client, your implied consent is inferred to follow up on services for invoicing purposes. However, we will request your express consent before using your personal information for individual marketing purposes, based on location, for a third party (unless you have already given your consent to this third party).

8. Do companies need my consent to use my information if it has been made anonymous?
No. We can make your personal information anonymous so that it cannot be used to personally identify you and then use that anonymous information to improve our activities, offer benefits (such as helping municipalities with traffic planning) and create analytical marketing reports for our own and our partners’ use.

Collection, use and disclosure of your personal information

9. Does Brigil have the right to collect my personal information?
Yes, Brigil may collect your personal information to put together a file, but may only collect the personal information necessary for that purpose. Brigil must also inform you of:

• the purpose of the file;
• how the information will be used;
• the types of people who will have access to the information within the company;
• the location where your file will be stored;
• your access and rectification rights.

Here are a few examples of cases where we may collect personal information:
(a) when you provide your personal information, as part of the process for a request for information, activation or search for an apartment, house, condo or other product or service;
(b) automatically, when you visit one of our websites (e.g. through the use of cookies or similar technology), or when visiting sales and rental kiosks.
(c) through third parties you have had a relationship with.

10. How do companies use my personal information?
We use your personal information to provide you with our products and services. We may also use your personal information to:
(a) establish and maintain a responsible business relationship with you and provide you with ongoing service;
(b) understand our clients’ needs and preferences to determine your eligibility for houses, condos, apartments, as well as other products and services;
(c) recommend products and services that meet your needs;
(d) design, improve, market or provide houses, condos, apartments as well as other products and services;
(e) manage and develop commercial activities; and
(f) meet legal and regulatory requirements.
If needed, we will ask for your consent again before using your personal information for any other purpose beyond what is stipulated above.

11. When is my personal information disclosed?
We can disclose certain personal information in several situations, such as when we have obtained your express or implied consent. Your personal information may also be shared with Brigil brands and companies. We may also disclose your personal information to:
(a) a person acting on your behalf (such as a legal representative or authorized user), if we are reasonably convinced that this person is authorized to receive your personal information;
(b) third parties, such as real estate agencies, credit officers or banks, appraisers, notaries, facilitators or any person with whom you have had a payment relationship, to assess your credit or help to cover outstanding amounts owed to us, as well as transport companies to ship you products or services that you have ordered;
(c) any person as permitted or required by law.
If needed, we will ask for your consent again before using your personal information for any other purpose beyond what is stipulated above.

Withdrawing your consent

12. Can I opt out of having companies collect, use or disclose my personal information?
Sometimes. You may withdraw your consent or opt out of having your personal information collected, used or disclosed in certain situations. For example, if you have given your express consent for specific information on your wireless location to be used for marketing purposes, you can withdraw that consent at your discretion. Similarly, you may decide that your personal information cannot be used for a series of our marketing communications, including telemarketing, direct mail marketing, and electronic commercial messages, such as emails and text messages. However, if your personal information is reasonably necessary to offer you the services that you have requested or for our network to operate properly, you cannot continue to use these services and opt out of having your personal information collected, used and disclosed, because those are the terms of service. To stop having your personal information collected, used or disclosed under these circumstances, you must terminate your services.

Accuracy and protection of your personal information

13. How can I know more about my personal information and check that it is accurate?
You simply have to submit a written request to Brigil, at 98 Lois Road, Gatineau, QC J8Y 3R7 or info@brigil.com

We will respond to your written request in a reasonable period of time and give you the opportunity to review the personal information in your file, subject to certain exceptions and limitations. If we cannot give you access to your personal information (for example, if this would involve disclosing someone else’s personal information or other confidential or classified information), we will explain why. Our goal is to ensure that your personal information that we have on file remains accurate, up to date and comprehensive.

14. How is my personal information protected?
We use appropriate operational and technical protection measures that vary according to the sensitivity of the personal information in question. All our employees with access to personal information are required to keep that information confidential. The personal information that we disclose to third parties is regulated by this Privacy Protection Policy and by comparable protection measures in our business agreements. That information is also protected using additional protection measures as needed, based on the sensitivity of the personal information in question.

15. How long is my personal information stored?
Only as long as reasonably necessary or relevant for the purposes for which it was collected, or as required by law. When personal information is no long reasonably necessary or relevant for the purposes for which it was collected, or the retention period required by law has passed, your personal information is destroyed, deleted or made anonymous.

Amendments, questions and contact information

16. Can this Privacy Protection Policy be amended?
We may amend this Privacy Protection Policy (and privacy protection policies specific to other products or services) over time, pursuant to applicable legislation.

17. What legislation covers the collection, use and disclosure of my personal information?
Our privacy protection practices are designed to comply with applicable federal, provincial and territorial legislation in Canada.

18. What steps do I take if I still have concerns about privacy protection after contacting Brigil?
If we are unable to resolve your problem to your satisfaction, you may contact:

https://www.cai.gouv.qc.ca/questions-frequentes/les-obligations-des-entreprises-privees/ [in French only]

19. If I believe that Brigil is collecting personal information that is not necessary to conduct its business, where and how do I lodge a complaint?
You can lodge a complaint about the collection of personal information that you deem unnecessary under the circumstances. You simply have to submit your written complaint to the Commission d’accès à l’information – Direction de la surveillance [link in French only], and include any documentary or other evidence to support your complaint, as well as the contact information of the parties concerned. If you have no evidence, you must submit a written request to the company for them to justify the collection of your personal information under the Act respecting the protection of personal information in the private sector.

https://www.cai.gouv.qc.ca/questions-frequentes/les-obligations-des-entreprises-privees/ [in French only]

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