Who we are
Our website address is: https://melissatromba.com.
At THE AGENCY MONTRÉAL, agence immobilière, and Melissa Tromba, Residential Real Estate Broker The Agency Montreal, we respect your right to privacy.
We recognize the importance of protecting your personal information provided during your visit to our website and are committed to maintaining the confidentiality and security of the personal information we collect. This Privacy Policy describes, among other things, the type of personal information we collect, how we use that information, the safeguards we have in place, the right of access to personal information and to whom personal information may be disclosed. This Privacy Policy applies to any personal information we receive from or about individuals, such as you, who are not employed by us.
For the purposes of this statement, “personal information” means information about an identifiable individual, including, but not limited to, contact information, such as name, address, e-mail address, telephone number, demographic or household information, and financial and credit information.
THE AGENCY MONTRÉAL is governed by the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1) (hereinafter, the “Act”) and as such THE AGENCY MONTRÉAL strives to maintain the highest standards of confidentiality with respect to personal information provided to it by its customers, suppliers and other businesses in the course of its real estate brokerage activities, including but not limited to, through THE AGENCY MONTRÉAL’s website (the “Website”), its social networks, its advertisements and for the purposes of its
Customer Relationship Management (CRM) and Electronic Document Management
(EDM) systems, in accordance with its obligations under the Act.
What do we mean by “personal information”?
Personal information is information about a natural person that directly or indirectly allows that person to be identified. A written document, an image, a video or a sound recording may contain personal information. In the course of its professional activities, THE AGENCY MONTRÉAL may collect personal information such as a person’s name, home address, date of birth, identity document information, social insurance number, income information, marital status, etc. This information may be used by THE AGENCY MONTRÉAL to identify a person.
The protection principles listed below apply to the collection, use and transmission of personal information that Internet users may provide in the course of using the Website.
1. Responsibility
THE AGENCY MONTRÉAL is responsible for protecting the personal information it holds in the course of its real estate brokerage activities. To this end, THE AGENCY MONTRÉAL has adopted the Privacy Policy, as well as policies and practices governing the governance of personal information, the purpose of which is to govern the collection, use, communication, retention and destruction of personal information.
2. Collection of personal information
THE AGENCY MONTRÉAL collects only the personal information required to carry out its real estate brokerage activities. For example, information may be collected for the purposes of carrying out a real estate transaction, maintaining files, monitoring professional practice by the Organisme d’autoréglementation du courtage immobilier du Québec (OACIQ) or any other purpose determined by THE AGENCY MONTRÉAL and made known to the person whose consent is being sought.
THE AGENCY MONTRÉAL invites its staff, team members or any administrative assistant, as the case may be, to explain in simple and clear terms to the person concerned the reasons for the collection of his or her personal information and to ensure that they understand.
For the purposes of collecting personal information, THE AGENCY MONTRÉAL encourages members of its staZ, team or any administrative assistant, as the case may be, to use the standardized forms developed by the OACIQ. Access to your personal information will be limited to only those persons who need the information to carry out our business activities. We do not disclose your personal information without your consent, which is why your real estate broker will ask you to sign the OACIQ consent form to this effect. A specific reference is made when you provide such personal information, or if the disclosure of such personal information to third parties is directly related to our business activities or necessary to provide you with information, products or services, and would constitute a situation where the form would not necessarily be required. We may also disclose your personal information where we are required to do so by law.
THE AGENCY MONTRÉAL may also collect personal information verbally through correspondence with persons involved in a transaction or through various documents submitted in connection with a real estate transaction (identification, financial documents, powers of attorney, etc.).
3. Use and disclosure of personal information
Personal information is used and communicated for the purposes for which it was collected and with the consent of the person concerned. In certain cases provided for by law, personal information may be used for other purposes, for example, to detect and prevent fraud or to provide a service to the person concerned.
THE AGENCY MONTRÉAL may be required to communicate personal information to third parties, for example, suppliers, co-contractors, subcontractors, agents, insurers (such as the Fonds d’assurance responsabilité professionnelle du courtage immobilier du Québec [FARCIQ], the Fonds d’indemnisation du courtage immobilier du Québec [FICI]), professionals, financial or credit verification institutions as well as providers of electronic document management systems (EDMS) and other regulators, or outside Quebec.
THE AGENCY MONTRÉAL may, without the consent of the person concerned, communicate personal information to a third party if such communication is necessary for the execution of a mandate or a contract for services or business. In such cases, THE AGENCY MONTRÉAL will draw up a written mandate or contract in which it will indicate the measures that its agent must take to ensure the protection of the personal information entrusted to it, to ensure that it is used only for the purposes of the mandate or contract and that it is destroyed once the mandate or contract has ended. The co-contractor must also undertake to cooperate with THE AGENCY MONTRÉAL in the event of a breach of confidentiality of personal information.
Before disclosing personal information outside Quebec, THE AGENCY MONTRÉAL considers the sensitivity of the information, the purpose for which it is to be used and the safeguards that will be in place outside Quebec. THE AGENCY MONTRÉAL will only disclose personal information outside Quebec if its analysis demonstrates that the information will be adequately protected in the location where it is to be disclosed.
4. Retention and Destruction of Personal Information
When the purposes for which the personal information was collected or used have
been fulfilled, THE AGENCY MONTRÉAL must destroy it, subject to a retention
period stipulated by law. In this regard, THE AGENCY MONTRÉAL’s professional
obligations require it to keep its files for at least six (6) years following their final
closing.
5. Safety measures
When collecting, using, storing and destroying personal information, THE AGENCY
MONTRÉAL applies the necessary security measures to protect the confidentiality
of personal information. The personal data collected will be stored on servers and in
electronic data management systems equipped with mechanisms and using
recognized standards of protection to ensure the security of personal information
provided to THE AGENCY MONTRÉAL by its customers, suppliers and other
companies in the course of its real estate brokerage activities, including but not
limited to, through the Website, its social networks, its advertisements and for the
purposes of its Customer Relationship Management (CRM) and Electronic
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Document Management (EDM) systems, in accordance with its obligations under
the Act.
Privacy incident
A confidentiality incident is any access, use or disclosure of personal information
that is not authorized by the Act, or the loss of personal information or any other
breach of the protection of personal information.
THE AGENCY MONTRÉAL has set up a protocol for managing a confidentiality
incident, which identifies the people who assist the Privacy OZicer and sets out the
concrete actions to be taken in the event of an incident. This protocol sets out the
responsibilities expected at each stage of incident management, including the
measures to be taken to ensure data security.
6. Cookies
A “cookie” is a small amount of data that our website can send to your web browser,
which may then be stored on your computer’s hard drive so that we can recognize
you when you return to our website. We may use cookies to store visitors’
preferences, record session information, record user-specific information about
which web pages users access or visit, alert visitors to new areas that may be of
interest to them when they return to our website, record past activity on a site in
order to provide better service when visitors return to our site, customize website
content based on visitors’ browser type or other information that the visitor sends.
You can set your web browser to notify you when you receive a cookie, or to refuse to
accept certain cookies. You are not required to accept cookies to access or search
our website. However, there may be a minimal loss of functionality if you have
disabled or deleted all cookies.
7. Roles and responsibilities
A. THE AGENCY MONTRÉAL its staZ, members of its team or any administrative
assistant, as the case may be
• Ensures confidentiality of information through good information
management practices. In particular, it provides guidelines, training and
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instructions to staZ members regarding the collection, use, storage,
modification, consultation, communication and permitted destruction of
personal information.
• Deploys appropriate safeguards to reduce the risk of privacy incidents, e.g.
computer security, updated personal information policies, staZ training, etc.
• Has standardized methods for filing documents containing personal
information.
• Has standardized methods for retaining documents containing personal
information, including digitization procedures.
• Manages physical and computer access to personal information, based in
particular on its sensitivity.
• Securely destroys personal information. In particular, it gives directives or
instructions to staZ members concerning the secure destruction method,
destruction deadlines, etc.
B. Privacy OZicer
In accordance with the Act, THE AGENCY MONTRÉAL has appointed a Privacy
OZicer.
In particular, he or she ensures that these policies are respected and that they
comply with applicable regulations. The name and contact details of this person are
given in the “Complaints” section.
The Privacy OZicer is responsible for managing incidents of confidentiality and, in
this context, takes the actions provided for in the Act.
The Privacy OZicer handles requests for access and rectification of personal
information. He also handles complaints about THE AGENCY MONTRÉAL’s handling
of personal information.
The Privacy OZicer is consulted as part of a privacy impact assessment for any
project involving the acquisition, development or redesign of an information system
or the electronic delivery of services involving the collection, use, disclosure,
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retention or destruction of personal information. It may suggest measures to ensure
the protection of personal information in the context of such a project.
C. StaZ, team members or administrative assistants
A member of THE AGENCY MONTRÉAL’s staZ, team or any administrative assistant
may view personal information only insofar as it is essential to the performance of
his or her duties or mandate.
THE AGENCY MONTRÉAL staZ member, team member or administrative assistant:
• Ensures the integrity and confidentiality of personal information held THE
AGENCY MONTRÉAL.
• Complies with all THE AGENCY MONTRÉAL policies and guidelines on
access, collection, use, disclosure, destruction of personal information and
on information security and complies with the instructions presented to it.
• Respects the security measures in place at the workstation and on any
equipment containing personal information.
• Use only equipment and software authorized by THE AGENCY MONTRÉAL.
• Ensures the secure destruction of personal information in accordance with
instructions. Immediately report to his/her superior any act of which he/she
is aware that may constitute an actual or suspected breach of security rules
relating to personal information.
8. Right of access, withdrawal and rectification
An individual (or his/her authorized representative) may request access to his/her
personal information held by THE AGENCY MONTRÉAL. An individual may withdraw
his or her consent to the collection, use and disclosure of his or her personal
information at any time. Such withdrawal shall be recorded in writing by contacting
our Privacy OZicer at the coordinates indicated below. Subject to legal or
contractual restrictions and reasonable notice, we will ensure that your name is
removed from our mailing list(s).
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An individual may request the correction of personal information in a file concerning
him or her that he or she believes to be inaccurate, incomplete or equivocal.
An individual may request that THE AGENCY MONTRÉAL electronically transfer his
or her personal data to a third party.
THE AGENCY MONTRÉAL may refuse a request for access or rectification in the
cases provided for by law
(https://www.legisquebec.gouv.qc.ca/fr/document/lc/P39.1).
9. Complaints
A person who considers himself/herself aggrieved may file a complaint regarding
the processing of his/her personal information by THE AGENCY MONTRÉAL. This
complaint will be handled diligently within a maximum of 30 days by the Privacy
OZicer and a written response will be sent to you.
To make a request for access, rectification of your personal information or any other
request to which you are entitled, as well as to submit a complaint regarding the
processing of personal information, please contact:
Stéphane Arbour
Privacy OZicer
THE AGENCY MONTRÉAL
4115 Sherbrooke West
Montreal, Qc H3Z 1K9
514-923-7793
stephane.arbour@theagencyre.com
10. Revision of this Privacy Policy
We reserve the right to update the privacy policy at any time to reflect changes in
legal obligations or changes in the way we treat personal information, without prior
notice, and we encourage you to refer to our privacy policy regularly.
Update: October 2024
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