Effective: Septembre 2023
LSR GesDev inc. ("GesDev") is committed to handling the personal information it holds in compliance with the Act respecting the Protection of Personal Information in the Private Sector (ref: Bill 25). We attach particular importance to protecting the personal information you entrust to us, and you will see that our standards deserve the trust you place in us in this regard.
The purpose of this Personal information protection policy ("Policy") is to explain our practices regarding the collection, use, disclosure and retention of personal information. By providing us with personal information (through our website, by completing our forms as required by the nature of our business, by responding to a newsletter from us, by email, in person or by telephone), you agree to have your personal information processed in accordance with this Policy, and you authorize GesDev, its third parties and service providers to process your personal information for the purposes set out below.
If you do not consent to GesDev's collection, use and disclosure of your personal information in accordance with this Policy, please do not provide us with any personal information. Of course, certain services can only be offered to you if you provide GesDev with such information; therefore, GesDev may not be able to offer you such services if you choose not to provide GesDev with the necessary personal information.
SCOPE OF APPLICATION
This Policy applies to all personal information collected, used or disclosed by GesDev or others in the course of providing our professional services, subscribing to our communications or browsing our website.
This Policy does not apply to services offered by third parties that can be accessed through links on our website. If you follow a link to a third-party website, that website will have its own privacy policies, which you should review before submitting any personal information.
This Policy does not apply to the processing of personal information of our employees.
PERSONAL INFORMATION COLLECTED
Personal information is any information relating to a physical person which enables that person to be identified, directly or indirectly.
We may collect and process different types of personal information in the course of our activities and provision of services, including:
- identifying and contact information, such as a first name, surname, email and postal addresses, telephone numbers, social insurance, driving licence or passport number, and work/residence permit;
- demographic information, such as date of birth, gender or citizenship;
- financial information, such as a billing address, bank account information or payment details, the state of your finances, the name of your employer, your salary and the information needed to issue tax forms;
- marketing information, such as communication preferences, feedback and survey responses on our website usage, and other technical information, such as details of your visits to our websites, your interaction with our advertising and online content, or information collected through the use of cookies and other tracking technologies;
- emergency contact information, such as names, contact details and the nature of the relationship;
- information relating to recruitment, such as a curriculum vitae, information on education and professional background, details of professional affiliations and other information relevant to potential recruitment.
If you provide us with personal information about other persons (such as a guarantor), you must first ensure that you have duly notified them that you are providing us with their information and that you have obtained their consent to such disclosure.
MEANS USED TO COLLECT YOUR PERSONAL INFORMATION
Data collected automatically
When you browse our website, and provided that you have accepted the use of cookies, we may automatically collect and store the following information directly or via our suppliers, such as Google Analytics:
- your IP address.
Data collected non-automatically
We obtain your personal information directly from you with your consent and during our interactions with you, including as follows:
- when you subscribe to our newsletter;
- when you contact us by email or telephone to obtain information about our offer (housing, land, jobs, etc.);
- when you complete our Rental Application form;
- when you complete a tenancy agreement;
- when you complete any other document enabling us to offer you our rental services.
We also collect personal information that you make publicly available, in particular on social media such as LinkedIn, Facebook and Instagram.
CONSENT
When we collect personal information about you in accordance with this Policy, we obtain your manifest, free and informed consent to use it for the purposes for which it is collected.
GesDev must obtain your consent to use your information for other purposes, to communicate it to third parties other than the exceptions provided for by law.
If you do not consent to the collection, use and sharing of your personal information, we may not be able to provide you with the products you request, or the management of your file may be compromised.
Consent must be given by you or by a duly authorised person, such as a delegate or agent.
PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED
GesDev needs to collect personal information about you in order to provide you with high-quality services, confirm your identity, meet legal requirements, prevent fraud or resolve issues concerning our relationship.
We aim to limit the amount of personal information we collect to that which is strictly necessary and appropriate for the purposes identified. We will not use or disclose your personal information for purposes other than those for which it was collected.
We may use personal information in any of the following ways:
- in order to provide you with our services, offer you a newsletter, communicate information to you or offer you surveys;
- to perform our obligations under any agreement entered into between you and us;
- to facilitate the use of our websites, to ensure that the content is relevant, and to ensure that the content of our websites is presented in the most effective way for you and your device;
- for marketing and business development purposes;
- to carry out analyses to understand the profiles of our customers in order to better develop our services and offers;
- to obtain statistics and performance analyses in respect of our website, in particular, by means of analytical cookies such as Google Analytics, to improve and administer it, and to obtain statistics and performance analyses in respect of our email communications;
- for recruitment purposes and to enable us to process job applications and assess whether an individual meets the requirements of the position for which they may apply;
- to carry out other background checks that may be required at any time under applicable law or regulations and/or according to best practices in the field (if false or inaccurate information is provided or if fraud is observed or suspected, information may be transmitted to fraud prevention agencies);
- to enforce our rights, to comply with our legal or regulatory obligations to provide information or to protect the rights of third parties.
WITH WHOM WE SHARE YOUR PERSONAL INFORMATION
Your personal information is kept for our internal use to enable us to carry out the activities related to our type of business, in particular land sales and residential and commercial rental.
We also share your personal information with our service providers.
We limit the information we provide to these service providers to that which is reasonably necessary for them to perform their functions. The following are the categories of third parties with whom we share your personal information:
- third-party service providers and/or partners, in particular those that enable us to carry out our business activities, such as Hopem (accounting tasks), UseWalter (communication platform), National Bank of Canada (rent collection), CORPIQ (credit investigations), etc.;
- information technology service providers to develop our applications and host and maintain our websites;
- marketing partners such as Google, Facebook and Instagram, Mail chimp or CyberImpact to promote our content and offers when, for example:
- you visit our website;
- you view our videos on a third-party platform such as YouTube;
- you subscribe to our newsletters;
- these third parties may use cookies, invisible pixels or other similar technologies on your hard disk to collect or receive information about your browsing on our website and elsewhere on the Internet. These technologies make it possible to deliver relevant and targeted advertising according to your centres of interest.
We may be obliged to share your personal information with the authorities if we are forced to do so, in particular as a result of a court order requiring us to disclose personal information. Where we can lawfully and reasonably inform you of such disclosure, we will do so.
In certain circumstances, we may use service providers outside Quebec or Canada. We are responsible for ensuring that any personal information transmitted is adequately protected, in particular with regard to generally accepted principles for the protection of personal information.
At GesDev, access to your personal information is granted only to those employees who need to have access to it. Our employees must sign a confidentiality agreement before having access to personal information.
HOW WE USE COOKIES AND INVISIBLE PIXELS (pixel tags or clear GIFs or Web beacons)
We use cookies for various purposes. We use cookies that we set ourselves, but also those set by third parties. If you have consented, these third parties collect data on each website with such a cookie installed in order to provide us with contextual analytical data or to enable us to target you with relevant advertising.
Categories of cookies and their use:
- Essential: essential cookies are used to offer you our online services and in particular to ensure their security. They are essential for accessing and using our website, for example.
- Functional: functional cookies are used in connection with functions or services available via a website. For example, they memorise the display language.
- Analytics: analytical cookies are used to better understand the performance of our website, in particular the content that visitors like, or to measure the impact of our awareness campaigns.
- Marketing: marketing cookies are installed by third parties to collect information about your browsing preferences and areas of interest when you surf the Web. They enable us to target you with relevant advertising.
- Preferences: preference cookies enable a website to retain information that modifies the way the site behaves or is displayed, such as your preferred language or the device used to access the website (mobile phone, computer, tablet, etc.).
When you use the LinkedIn, Twitter or other sharing buttons available, you are directed to a page controlled by those companies, which may also set cookies (including targeting cookies), and you will then be subject to the cookie policies of LinkedIn, Twitter or any other relevant website.
Invisible pixels in HTML emails
Our marketing emails (newsletters) contain a unique campaign-specific "invisible pixel" that notifies us if our emails are opened and, in combination with other technologies, verifies clicks on links within the email. We may use this information for a number of purposes, including to determine which of our emails are of most interest to you and to ask users who do not open our emails whether they wish to continue to receive them. If you do not want the pixel to be downloaded to your device, you should choose not to click on the links we send you.
HOW TO MANAGE YOUR COOKIE PREFERENCES
You can withdraw your consent to cookies at any time by managing your preferences. You can manage your cookie preferences directly in your browser, notably by uninstalling or blocking certain cookies.
CONSERVATION OF PERSONAL INFORMATION
We will only retain personal information for as long as is necessary for the purposes set out in this Policy and to comply with our legal and regulatory obligations.
STORAGE OF PERSONAL INFORMATION
GesDev may store and process your personal information at its offices in Quebec or elsewhere. To ensure the confidentiality of your personal information, GesDev employs security safeguards appropriate to the sensitivity of the information, including technological, physical and organizational measures. These measures include restricting the use of paper documents, training staff accordingly, limiting access to information, disclosing information only on a need-to-know basis, using passwords, and implementing well-defined internal policies and practices.
To the extent that GesDev uses third-party service providers to store or process personal information on our behalf (for example, data storage and processing services, cloud computing or application hosting services, or desktop services), we use contractual means and other measures to ensure that a comparable level of protection is provided while personal information is being stored, handled or processed by these external providers.
SECURITY MEASURES
We follow generally accepted industry standards to protect personal information submitted to us, both at the time of transmission and once we have received it. We maintain appropriate physical, technical and administrative safeguards to protect personal information against accidental or unlawful destruction, alteration, unauthorized disclosure or access, misuse or other unlawful forms of processing of personal information in our possession. We plan to take reasonable physical, administrative and organizational measures to protect personal information, including:
- grant access to personal information as required;
- minimising the computer privileges granted to the minimum required for an employee's function;
- implementing a confidentiality agreement with our employees;
- training employees in the protection of personal information;
- use of technical and operational security measures, such as:
- implementation of a backup protocol;
- use of firewalls and antivirus software;
- strong password policy and use of secure software solutions to manage and share access;
- multi-factor authentication (MFA) to connect to cloud platforms;
- use of the SSL (Secure Sockets Layer) protocol;
- periodic review of privacy protection measures.
However, no method of transmission over the Internet, nor any means of electronic storage, is 100% secure. We therefore cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. Nor can we guarantee that such information will not be accessed, obtained, disclosed, modified or destroyed as a result of a breach of our physical, technical or administrative safeguards. If you have reason to believe that personal information has been compromised, please contact us at
YOUR RIGHTS WITH REGARD TO YOUR PERSONAL INFORMATION
In certain circumstances and in accordance with applicable laws on the protection of personal information, an individual has the following rights:
- right of access: the right to obtain confirmation of the existence of processing of personal information concerning them and the right to obtain communication of this personal information subject, where applicable, to payment of a monetary sum not exceeding the cost of transcription, reproduction or transmission;
- right to withdraw consent: the right to withdraw consent to an identification, localisation or profiling technology and the means offered to activate these functions;
- right of rectification: the right to request rectification of any incomplete or inaccurate personal information held by us;
- de-indexation: the right to ask to cease disseminating personal information or to de-index any hyperlink attached to one's name giving access to information if such dissemination causes prejudice or contravenes the law or a court order (right to erasure or oblivion);
- anonymisation: the fact that our organisation may, instead of destroying it, irreversibly anonymise personal information in order to use it, but only for serious and legitimate purposes;
- right to information-decision: the right to be informed when you are the subject of a decision based exclusively on automated processing;
- right to information-technology: the right to be informed when an identification, localisation or profiling technology is used and of the means offered to activate these functions.
If you contact us, we may request additional personal information in order to validate your identity. If we are unable to accept your request, we will inform you of the reason for refusal. If you do not agree with our decision, you may contact our Privacy Officer again, and we will reconsider your request. Alternatively, you may exercise your rights with the Commission d'accès à l'information, or the authority responsible in your jurisdiction, if you live outside Quebec.
TO CONTACT US
If you have any questions about this Policy or about the collection, use, disclosure or storage of your personal information, or if you would like to know more about our privacy policies and practices, please contact one of our Privacy Officers.
By email:
By post:
LSR GesDev inc. ("GesDev")
To the attention of the Privacy Officer
102-333 Riverside Street
Saint-Lambert, Quebec J4P 1A9
POLICY UPDATE
Privacy laws change quickly and, as a result, this Policy may be changed by GesDev, in its sole discretion, without any notice or liability to you or any other person. GesDev's collection, use and disclosure of your personal information will be governed by the version of this Policy in effect.
This Policy was last updated in September 2023.