Privacy Policy

POLICY ON PROTECTION OF PERSONAL INFORMATION
Groupe, including its subsidiaries and affiliated companies (“Groupe”), is committed to protecting personal information and respecting the privacy of its clients, tenants, employees, and suppliers. Groupe undertakes to comply with the Act Respecting the Protection of Personal Information in the Private Sector (the “Act”).

This Privacy Policy (the “Policy”) governs the processing, retention, and expected conduct relating to personal information held by the organization.

DEFINITIONS
For the purposes of this Policy, the following terms and expressions shall mean:

Personal Information: Personal information refers to any information that relates to a natural person and enables that person to be identified.

Third Party: Any individual or legal entity that collects, uses, retains, discloses, or destroys personal information on behalf of Groupe, or that manages personal information held by Groupe.

SCOPE OF APPLICATION
This Policy applies to all employees, officers and directors of Groupe who collect, use, disclose, retain or destroy personal information in the course of their respective duties within Groupe, or when they otherwise have access to personal information held by Groupe, including information retained by a third party. It applies to all information, regardless of its format, from its collection to its destruction.

It also applies to any individual or legal entity to whom Groupe entrusts personal information in the performance of a mandate or service agreement.

COLLECTION AND USE OF PERSONAL INFORMATION
Groupe will limit the collection and use of personal information to what is necessary to meet the objectives and purposes identified by it. Groupe will collect and use personal information in compliance with the Act and in full transparency.

Groupe will not use or disclose personal information for purposes other than those identified in this Policy and for which the information was collected unless the Act authorizes it to do otherwise.

RETENTION AND DURATION
Personal information collected is retained in a manner that ensures the protection of personal information that it collects, uses, retains and destroys, and that is reasonable under the circumstances. Access to such information is limited to individuals who need to access it in the course of their employment or mandate.

Personal information is retained only for the period necessary—determined from time to time—to fulfill the purposes for which it was collected and to comply with our legal obligations.

Once the retention period ends, all personal information will be destroyed.

ACCESS AND WITHDRAWAL OF CONSENT
Any individual may, at any time, contact the Privacy Officer to access or update the personal information that Groupe holds about them, as well as to withdraw their consent.

LIMITATION OF LIABILITY
Groupe undertakes to take reasonable measures to ensure the confidentiality and security of personal information in accordance with the appropriate technological standards for its sector of activity. However, no information system is entirely secure, and some level of risk is always present when transmitting personal information over the public Internet. Groupe cannot be held liable for any breach of confidentiality, hacking, viruses, loss, theft, misuse, or alteration of personal information transmitted or hosted on its systems or those of a third party.

CONTACT
To ask questions, provide comments or file a complaint regarding this Policy or the handling of personal information, exercise your rights, or obtain information about this Policy, please contact our Privacy Officer at the following address:

Me Amy Gauthier
Director of Legal Affairs and Corporate Secretary
6505 Zéphirin-Paquet Street, Suite 200
Québec, Québec G2C 0M2
agauthier@groupedallaire.ca

PUBLICATION AND UPDATES TO THE POLICY
This Policy is available and will be brought to the attention of all individuals concerned by the Policy.
Groupe reserves the right to update or modify this Policy from time to time.

Adopted on November 28, 2023