Privacy Policy

Last Update: September 27, 2023

This Policy outlines the measures and practices that RE/MAX 2000 (the "Agency" or "we" or "our") has put in place to govern its handling of personal information and protect the personal information of its clients, namely individuals from whom the Agency collects personal information through direct or indirect contact with an authorized representative of the Agency and the website www.remax-2000.com (the "Website") (the "Clients" or "you" or "your"), for the purposes described in section 4 below.

In this Policy, the term "personal information" refers to any information collected by the Agency that, alone or in combination with other information, directly or indirectly identifies a Client.

The main purpose of this Policy is to inform Clients:

• of the means used by the Agency to collect personal information;
• of the nature of the personal information collected by the Agency and the purposes for which this collection is carried out;
• how the Agency may use personal information and third parties to whom the Agency may disclose this personal information, if any;
• of the rights you have regarding personal information collected by the Agency, including accessing your personal information or requesting the correction of inaccurate personal information, if any;
• of the different security measures implemented by the Agency to protect the confidentiality of personal information;
• how personal information is retained, destroyed, and/or anonymized; and
• how you can contact the Agency to address your questions, share your comments, or, if necessary, file a complaint in connection with this Policy.

By transmitting one or more pieces of personal information to the Agency through direct or indirect contact with an authorized representative of the Agency or through your use of the Website, you consent to the Agency collecting, using, disclosing, and retaining this personal information in accordance with the terms, conditions, and conditions set out in this Policy.

The Agency reserves the right to modify the terms, conditions, and conditions set out in this Policy at any time and at its sole discretion. In such a case, the Agency will provide you with a version of this Policy containing the modifications made. Your use of the Services (as defined in section 4 below) upon receipt of this version will be deemed to constitute an express acceptance of the modifications made.

This Policy and any modified version of it are subject to the applicable laws in the province of Quebec.

1. How does the Agency collect personal information?

The Agency collects personal information through the following means:

1. (i) when voluntarily transmitting such personal information to an employee or authorized representative of the Agency in writing, by email, or verbally,
2. (ii) the information we collect from other companies and public organizations (including companies in the RE/MAX group to which the Agency is affiliated (RE/MAX Québec inc., Fonds promotionnel RE/MAX inc., Les Services de relogement national (RELONAT) inc., and RE/MAX, LLC (Denver, CO)), or (iii) when you use the Website.

Personal information communicated when using the Website can be communicated directly (for example through a web form or email) or automatically (see for this purpose, the list of personal information collected automatically in section 3).

2. What personal information does the Agency collect?

The personal information that the Agency may collect includes:

• Your name, first name, and your contact details (home addresses, email addresses, phone numbers);
• Your date of birth, gender, and language preference;
• Personal information allowing the Agency, through its authorized representatives, to verify your identity and that of any other person in compliance with applicable real estate brokerage legislation, including the Real Estate Brokerage Act (R.S.Q., c. C-73.2) and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17) and their respective regulations, including but not limited to:
• Your profession or main occupation;
• A government-issued photo ID that is authentic, valid, and up-to-date;
• A document from a reliable source containing your name and address, a document from a reliable source containing your name and date of birth, and a document containing your name along with confirmation that you hold a deposit account, a prepaid payment product account, or a credit card or other loan account with a financial entity;
• Your Canadian citizenship or residence;
• Personal information that you provide to us in the course of performing the Services (as defined in section 4 below) and that may constitute sensitive personal information, such as:
• Information about your real estate transaction project;
• Financial information necessary for credit checks and to collect deposits and payments (Credit card number, mortgage approval, tax statements, credit report, etc.);

Your exchanges and communication history with us (call recordings, chat sessions, and instant messaging conversations, including via our social media);

Personal information generated by you in the course of using the Services (complaints, inquiries, notices, comments, and responses to surveys);

Personal information provided in connection with a job or engagement application with the Agency (resume, education information, work experience, and professional affiliations);

Personal information that you are required or invited to transmit to the Agency due to the nature of your relationship with it (for example, if you are an administrator or employee of the Agency: social insurance number for employees and financial information for employees, photographs of employees for publication on the Website, and identification for each of the Agency's administrators in accordance with the Act mainly aimed at improving business transparency);

Personal information automatically collected during your use of the Website (see section 3).

3. Automatically Collected or Cookie Information:

To ensure the functionality of the Website and the purposes of the personal information below, the Agency must collect the following personal information from Clients visiting the Website:

• The domain name of their Internet service provider;
• Their IP address;
• Their browser (Explorer, Firefox, etc.) and their operating system (Windows, Mac OS, etc.);
• The date and time of their visit;
• Their country of origin;
• The pages they viewed and the time spent on those pages;
• The address of the referring site; and
• Crash data.

All of this information is collected automatically from the moment a Client connects to the Website. Some of this personal information is collected through the placement of temporary "cookies" or "web beacons" (also sometimes called "invisible pixels"). These files or beacons also allow us to improve the performance of the Website and some of its features.

4. For what purposes does the Agency collect personal information?

The Agency collects your personal information for the following purposes:

• Provide guidance, information, advice, and tools related to real estate transactions that you request us to perform (collectively: "Services");
• Conduct real estate transactions and be compensated for our Services;
• Comply with applicable laws and regulations;
• Issue notifications and alerts in the use of Services to provide you with specific information. In doing so, the Agency uses technology for profiling, the functions of which must be activated by the Client from the Website;
• Evaluate your eligibility for programs such as Tranquilli-T [www.tranquilli-t.com], Integri-T [www.integri-t.com], and Programme Clé [quebec.programmecleremax.com] with the aim, among other things, of helping you save money and protecting you from hidden defects when purchasing your property.
• Generally, communicate with you to transmit various information related to the Services and offer you products and/or services that may interest you;
• Conduct periodic follow-ups with you to ensure you are satisfied with the provision of Services;
• Develop, improve, and promote the Services, including generating and publishing de-personalized statistical data from the personal information of multiple Clients;
• Evaluate the effectiveness of the Agency's efforts to acquire visitors to the Website;
• Evaluate which information and actions offered by the Agency are of interest to visitors to its Website;
• Identify which steps of our partner sites have allowed the acquisition of visitors;
• Improve the performance and efficiency of the Website in retaining visitors;
• Identify the legislative regime to which the personal information of visitors is subject; and
• If applicable, review your job or engagement application with the Agency.

Subject to exceptions provided in applicable legislation, the Agency will seek your consent before using personal information about you for purposes other than those listed above.

5. To whom may the Agency disclose your personal information?

In general, the Agency uses the personal information of its Clients for internal purposes only. However, the Agency may disclose personal information about you to the following individuals or entities:

1. To its employees and representatives who need access to this personal information in pursuit of the purposes listed in the above section 4;

2. To external service providers with whom the Agency has entered into a contractual agreement under which the relevant external service provider is required to take appropriate measures to:

   1. Ensure the protection of the confidential nature of the disclosed personal information;
   2. Ensure that the disclosed personal information is used only for the purpose of performing the services it is called upon to perform for the Agency;
   3. Ensure that the disclosed personal information is not retained after the termination of the aforementioned contractual agreement;
   4. Promptly notify the Agency of any breach or attempted breach by a person of any obligation regarding the confidentiality of the disclosed personal information;
   5. Enable the Agency to conduct any verification regarding the confidentiality of the disclosed personal information.

   For example, the service provider hosting the Website and performing maintenance on said Website may have access to personal information as part of the specific performance of its services under a contractual agreement with the Agency;

3. To entities that are part of the RE/MAX group to which the Agency is affiliated (RE/MAX Québec inc., Fonds promotionnel RE/MAX inc., Les Services de relogement national (RELONAT) inc., and RE/MAX, LLC (Denver, CO)), to the extent necessary to allow the latter to fulfill its contractual and statutory obligations;

4. To any other person or entity, when prescribed or permitted by applicable legislation, or with the consent of the concerned Client.

To achieve the aforementioned purposes, the Agency may disclose your personal information outside of Quebec. However, the Agency will only do so if a privacy impact assessment demonstrates that the receiving party is able to ensure adequate protection of such personal information, particularly with regard to generally recognized personal information protection principles. In such circumstances, the Agency will contractually obligate the entity receiving your personal information to comply with various conditions ensuring the protection of your personal information, including, but not limited to, all the conditions provided in the above section 5(b).

6. How does the Agency protect the confidentiality of your personal information?

The Agency takes appropriate physical, technological, and administrative protection measures to safeguard your personal information and reduce the risks of unauthorized and/or illegal access, use, communication, and destruction.

Without limiting the generality of the foregoing, the Agency:

• Verifies the identity and criminal backgrounds of all its employees and representatives;

• Requires each of its employees and representatives with access to personal information to sign a confidentiality agreement;

• Implements access controls limiting access to personal information to authorized employees and representatives who require access to personal information;

• Stores personal information on physical media kept in locked premises accessible only to authorized employees and representatives of the Agency; and

• Stores personal information on a secure technological platform, namely the information system provided by Document Management Service Providers, on which an identification and authentication system is implemented to limit access to your personal information to authorized individuals who need such access for one or more purposes listed in section 4 above.

In addition, the Website has certain security mechanisms in place to protect your personal information, including:

• All exchanges between RE/MAX servers and user devices are encrypted;

• All user passwords are encrypted;

• The Agency's IT service provider is required to comply with various security obligations, including periodic validation of security practices and processes and continuous monitoring of the software components of the Website and their updates.

7. What measures has the Agency implemented regarding privacy incidents?

The Agency maintains a register of privacy incidents in compliance with applicable legislation. In the event of a privacy incident that poses a risk of serious harm to you, the Agency will take necessary measures to notify you in accordance with applicable legislation. The risk assessment of serious harm considers criteria such as the sensitivity of the personal information involved in the privacy incident, the anticipated consequences of its use, and the probability of its use for harmful purposes.

8. What is the retention period for your personal information?

In accordance with our secure procedures for the retention and destruction of personal information, we retain your personal information only for the period necessary to accomplish the purposes outlined in section 4 of this Policy or for the duration required to comply with our statutory obligations, whichever is later.

The Agency reserves the right to close a Client's file when the entire real estate transaction process is completed or, in the case of Agency employees, for a consecutive period of at least seven (7) years from the date of the end of employment, subject to any statutory obligation specifying a different minimum retention period. The closure of a file involves the complete and permanent destruction of the personal information it contains, or its anonymization for use for serious and legitimate purposes. In the case of closing a file for a Client who is not an employee or representative of the Agency, the personal information it contains will typically be destroyed or anonymized after a period of six (6) years following the date of closure of the file due to retention periods imposed by law.

In this Policy, the term "anonymization" means the process by which personal information no longer allows, in an irreversible way, the direct or indirect identification of the Client to whom it relates.

9. How can you access, correct, update, and/or obtain a copy of your personal information?

The Agency acknowledges the right of its Clients to access, correct, update, and obtain a copy of their personal information by submitting a written request to the Agency at the contact information provided in section 13 below. In the event such a written request is submitted to the Agency, it must, under the Law, verify your identity and will respond in writing no later than thirty (30) days after receiving the request. Any request not processed within this period is deemed to have been refused.

A request for correction of 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 was collected without justification.

If the Agency agrees to any request for a copy of computerized personal information made by a Client, the Agency will ensure to provide it (or any person or organization authorized by law to collect such personal information, as requested by the Client) in a structured and commonly used technological format. This paragraph does not apply (i) if providing such a copy in such a technological format poses serious practical difficulties and/or (ii) with respect to any computerized personal information that has been created or inferred from other personal information.

If the Agency refuses to comply with any request for access, correction, or update made by a Client, the Agency will communicate the reasons for this refusal to the Client, along with the remedies available to the Client in the circumstances and the timeframe within which these remedies can be exercised. To the extent the Client requires, the Agency will also provide assistance to help the Client understand the reasons for the refusal.

If a written request to this effect is submitted by a Client, the Agency may also cease the dissemination of personal information concerning the Client and/or delist or relist, as the case may be, any hyperlink associated with the name of the Client, subject to the criteria established by the then-applicable legislation.

In principle, the exercise of a right provided in this section is free of charge. However, reasonable fees may be required from the concerned Client to offset the costs of transcription, reproduction, or transmission of their personal information. In such a case, the Client will be informed of the amount of the fees before their request is processed.

10. How to withdraw your consent to the use or disclosure of your personal information?

Subject to your contractual commitments with the Agency and applicable legislation, you can withdraw or modify your consent to the use or disclosure of your personal information. To do so, you must submit a written request to the Agency at the contact information provided in section 13 below.

Please note that withdrawing or modifying your consent may impact the Agency's ability to adequately pursue the purposes of collecting your personal information described in section 4 of this Policy and may therefore affect our services to you.

11. How to file a complaint?

You can file a complaint about our methods, practices, and policies for the protection of personal information by writing to our Privacy Officer whose contact information is provided in section 14 of this Policy.

Any complaint will be handled directly by our Privacy Officer. A response will be provided to you within 30 days of the complaint. If the complaint is accepted, a brief summary of the changes made to the subject of the complaint will be provided to you.

If you are not satisfied with the handling of your complaint, you can also contact the Commission d'accès à l'information du Québec. A written complaint can be filed with the Commission by consulting the following page: Commission d'accès à l'information du Québec.

12. Protection of Your Personal Information is a Priority for All Entities within Groupe RE/MAX Québec Inc.

For more information regarding the processing of your personal information by other entities within Groupe RE/MAX Québec Inc., we invite you to consult the privacy policy of each of these entities:

• RE/MAX Québec inc.
• Fonds promotionnel RE/MAX inc. – A copy of the privacy policy of this entity will be provided upon request.
• Les Services de Relogement National (RELONAT) inc.

13. The Agency Has No Responsibility or Obligation Regarding Third-Party Products

The Website may contain links to other websites or products and services of third parties (collectively: "Third-Party Products"). Third-Party Products may be subject to terms of use and a privacy policy that differ from those of the Agency. The Agency cannot be held responsible or subject to any obligation related to the content of the terms of use and/or the privacy policy of these Third-Party Products. Without limiting the generality of the foregoing, the Agency has no responsibility or obligation regarding your personal information that may be collected, used, disclosed, and retained by any person or entity in connection with your access or use of Third-Party Products.

Any link available on the Website directing to a Third-Party Product does not imply or signify in any way that the Agency assumes or accepts responsibility for the content or use of that Third-Party Product. The Agency makes no representation regarding the quality, safety, adequacy, or reliability of Third-Party Products, nor the content or material they contain. When you access or use Third-Party Products, you should review the terms of use and privacy policy associated with them.

14. How Can You Contact the Agency's Privacy Officer?

We are responsible for your personal information. Therefore, we have appointed an individual who serves as the Privacy Officer within the Agency. To exercise any of your rights, ask questions, provide comments, or file a complaint regarding this Policy or our processing of your personal information, please contact this individual at the following address:

Please note that the Agency is required to verify your identity before responding to any request, question, comment, or complaint addressed to its Privacy Officer.