Privacy Policy

Last Updated: October 23, 2023

This Policy outlines the measures and practices implemented by RE/MAX Crystal (the "Agency," "we," or "us") to govern its handling of personal information and to protect the personal information of its clients—individuals from whom the Agency collects personal information through direct or indirect contact with an authorized representative of the Agency or via the website https://remaxcrystal.com/ ↗ (the "Website") (the "Clients," "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 primary purpose of this Policy is to inform Clients about:

• The methods used by the Agency to collect personal information;
• The nature of the personal information collected by the Agency and the purposes for such collection;
• How the Agency may use personal information and the third parties to whom it may disclose such information, if applicable;
• The rights you have regarding the personal information collected by the Agency, including the right to access or request corrections to inaccurate personal information, if applicable;
• The 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 ask questions, provide feedback, or file a complaint regarding this Policy.

By providing personal information to the Agency through direct or indirect contact with an authorized representative or by using the Website, you consent to the Agency’s collection, use, disclosure, and retention of such personal information in accordance with the terms and conditions of this Policy.

The Agency reserves the right to modify the terms, conditions, and provisions of this Policy at any time and at its sole discretion. In such cases, the Agency will provide you with an updated version of this Policy. Your continued use of the Services (as defined in Section 4 below) after receiving the updated version will constitute your express acceptance of the changes.

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

1. How Does the Agency Collect Personal Information?

The Agency collects personal information through the following means:

• Voluntary submission of personal information to an employee or authorized representative of the Agency in writing, by email, or verbally;
• Information collected from other businesses and public organizations, including companies within the RE/MAX group affiliated with the Agency (RE/MAX Québec Inc., Fonds promotionnel RE/MAX Inc., Les Services de relogement national (RELONAT) Inc., and RE/MAX, LLC (Denver, CO)); and
• Your use of the Website.

Personal information provided through the Website may be submitted directly (e.g., via a web form or email) or collected automatically (see Section 3 for details on automatically collected personal information).

2. What Personal Information Does the Agency Collect?

The personal information the Agency may collect includes:

• Name, surname, and contact details (physical addresses, email addresses, phone numbers);
• Date of birth, gender, and preferred language;
• Identity verification information required by real estate brokerage laws, including:
  • Profession or primary occupation;
  • A government-issued photo ID that is authentic, valid, and up-to-date;
  • Documents from reliable sources containing your name and address, name and date of birth, or confirmation of a deposit account, prepaid payment product, credit card, or loan account with a financial institution;
• Citizenship or Canadian residency status;
• Sensitive personal information related to real estate transactions, such as:
  • Details about your real estate transaction project;
  • Financial information required for credit checks, deposits, and payments (credit card numbers, mortgage approvals, tax statements, credit reports, etc.);
• Communication history (call recordings, chat sessions, instant messaging, including via social media);
• Feedback and interactions (complaints, inquiries, reviews, comments, and survey responses);
• Employment or engagement application details (resume, education, professional experience, and affiliations);
• Mandatory or requested personal information based on your relationship with the Agency (e.g., social insurance numbers for employees, financial details, photographs for the Website, or identity documents for directors under corporate transparency laws);
• Automatically collected personal information when using the Website (see Section 3).

3. Automatically Collected Personal Information or Cookies

To ensure Website functionality and achieve the purposes outlined in Section 4, the Agency collects the following personal information from visitors:

• Internet service provider domain name;
• IP address;
• Browser (Explorer, Firefox, etc.) and operating system (Windows, Mac OS, etc.);
• Date and time of visit;
• Country of origin;
• Pages visited and time spent;
• Referral website address; and
• Crash data.

This information is collected automatically upon accessing the Website. Some data is gathered via temporary cookies or web beacons (also called "invisible pixels"), which help improve Website performance and features.

4. For What Purposes Does the Agency Collect Personal Information?

The Agency collects personal information for the following purposes:

• Providing real estate services (advice, tools, and support for transactions);
• Completing real estate transactions and receiving payment;
• Complying with legal and regulatory requirements;
• Sending notifications and alerts (using profiling technology, which must be enabled by the Client);
• Assessing eligibility for programs (e.g., Tranquilli-T, Intégri-T, Programme Clé) to help save money and protect against hidden defects in property purchases;
• Communicating about services, promotions, and offers;
• Conducting satisfaction follow-ups;
• Improving and promoting services (using anonymized statistical data);
• Analyzing Website traffic and visitor engagement;
• Evaluating marketing effectiveness;
• Determining applicable legal jurisdictions; and
• Reviewing employment applications.

The Agency will obtain consent before using personal information for purposes not listed above, unless permitted by law.

5. To Whom May the Agency Disclose Your Personal Information?

Generally, the Agency uses personal information for internal purposes only. However, it may disclose personal information to:

• Employees and authorized representatives needing access for the purposes in Section 4;
• External service providers under contractual agreements requiring confidentiality, limited use, and secure disposal of data;
• RE/MAX-affiliated entities (RE/MAX Québec Inc., Fonds promotionnel RE/MAX Inc., RELONAT Inc., and RE/MAX, LLC) as necessary for contractual and legal compliance;
• Other parties as required or permitted by law, or with your consent.

If personal information is transferred outside Quebec, the Agency ensures the recipient provides adequate protection, including contractual safeguards.

6. How Does the Agency Protect Your Personal Information?

The Agency implements physical, technological, and administrative safeguards, including:

• Employee background checks and confidentiality agreements;
• Restricted access to personal information;
• Secure storage (locked premises and encrypted digital systems); and
• Regular security audits by IT providers.

The Website also uses:

• Encrypted server-client communications;
• Encrypted passwords; and
• Continuous software monitoring and updates.

7. How Does the Agency Handle Confidentiality Incidents?

The Agency maintains a confidentiality incident log. If an incident poses a serious risk of harm, affected individuals will be notified as required by law. Risk assessments consider factors like data sensitivity and potential misuse.

8. How Long Is Your Personal Information Retained?

Personal information is kept only as long as necessary for the purposes in Section 4 or to meet legal obligations.

• Client files are closed after real estate transactions conclude, with data typically anonymized or destroyed after six (6) years (or longer if required by law).
• Employee records are retained for at least seven (7) years post-employment.

Anonymization means irreversibly removing identifiers linking data to an individual.

9. How Can You Access, Correct, or Obtain a Copy of Your Personal Information?

You may request access, corrections, or a copy of your personal information in writing (see Section 13 for contact details). The Agency will:

• Verify your identity;
• Respond within 30 days (untreated requests are deemed refused);
• Provide explanations for denials and available recourse options;
• Assist in understanding refusal reasons, if requested;
• Cease dissemination or de-index hyperlinks upon request, where applicable; and
• Charge reasonable fees for transcription, reproduction, or transmission costs (with prior notice).

10. How Can You Withdraw Consent?

You may withdraw or modify consent (subject to contractual and legal obligations) by written request (see Section 13). Note that withdrawal may impact service delivery.

11. How to File a Complaint

Complaints about privacy practices should be submitted in writing to the Privacy Officer (Section 14). The Agency will respond within 30 days. If unsatisfied, you may escalate to the Commission d’accès à l’information du Québec (https://www.cai.gouv.qc.ca ↗).

12. Privacy Policies of RE/MAX Québec Affiliates

For details on how other RE/MAX Québec entities handle personal information, consult their policies:

• RE/MAX Québec Inc.: https://www.remax-quebec.com/fr/politique-confidentialite ↗
• Fonds promotionnel RE/MAX Inc.: Available upon request.
• RELONAT Inc.: https://www.relonat.com/confidentialite ↗

13. Third-Party Products

The Website may link to third-party products/services with separate terms and privacy policies. The Agency is not responsible for third-party data practices. Links do not imply endorsement.

14. Contact the Privacy Officer

For questions, requests, or complaints regarding personal information, contact:

Privacy Officer
RE/MAX Crystal: Mehdi Jamal
Phone: 450 430-4207
Email: rp@remaxcrystal.com ↗

Note: Identity verification is required for all requests.