Privacy Policy

Governance rules and confidentiality policy of Evolo Flex regarding the protection of personal information

Preamble

The purpose of these rules of governance and the confidentiality policy regarding the protection of personal information (the “Policy”) is to determine the principles that Evolo Flex and its representatives will follow when collecting, using, communicating, retaining, and destroying personal information.

Among other things, the Policy provides a framework for Evolo Flex’s obligations, particularly with respect to the roles and responsibilities of the person responsible for access to and protection of personal information (the “PPI Manager”) and his or her employees in handling personal information. The rights of people concerned by personal information collected, used, communicated, retained, and destroyed by Evolo Flex are contained in the Policy, as is the process for handling complaints relating to the protection of personal information.

The Policy applies to all personal information relating to customers, suppliers, platform users, staff and employees (the “Data Subjects”).

1. Consent

By visiting or using the Evolo Flex’s website or otherwise communicating with us, including to obtain information or conduct a transaction on properties for sale or rent, you agree to be bound by this Policy and consent to the collection, use, disclosure, retention, and destruction of your personal information as described in the Policy.

2. Responsibilities of Evolo Flex Inc. and the person responsible for the PPI

Evolo Flex is responsible for the protection of personal information in its possession, whether it is held by Evolo Flex or by a third party, and regardless of the form in which it is held (written, graphic, sound, visual, computerized, or other).

As such, Evolo Flex takes appropriate security measures to protect such information in a manner commensurate with its sensitivity and has adopted this Policy.

The PPI Manager of Evolo Flex ensures that these rules and Evolo Flex obligations regarding the protection of personal information are respected and implemented. In particular, he or she participates in the prevention and appropriate management of privacy incidents, the complaint handling process and Privacy Impact Assessments (“PIAs”) as required.

3. Changes of policy

Evolo Flex reserves the right to make changes to the Policy at any time by notifying its users on this page and/or by sending a notice to the Persons concerned through any contact information at our disposal. It is recommended that you consult this page regularly, referring to the date of the last modification. If the modifications affect the initial consent, Evolo Flex will collect a new consent, if necessary.

4. The information we collect

Evolo Flex only collects personal information that is necessary to carry out its activities in the sale and management of Evolo Flex condominium real estate development. For example, information may be collected for the purpose of completing a real estate transaction, for record-keeping purposes, for the monitoring of professional practice by the “Organisme d’autoréglementation du courtage immobilier du Québec” (OACIQ), or for any otherpurpose determined by Evolo Flex Inc. and made known to the person whose consent is being sought. Your information may also be used to invite you to our events.

We collect the following information, in whole or in part, when you use our platforms or otherwise communicate with us.

• First name and surname
• Date of birth
• Marital and family status
• Telephone number
• E-mail
• Personal mailing address
• Principal occupation and professional title
• Social insurance number
• Property purchased or sold
• Financial information
• Transaction Price
• Comments and e-mails
• Driver’s license no.
• Permanent resident card
• Passport
• Health insurance card

5. Accuracy of personal information

We are committed to keeping your personal information accurate, complete, and up to date. If your information changes, please notify us immediately so that we can make the necessary changes.

6. Access and rectification

To access or obtain a copy of the personal information we hold about you, or to have inaccurate personal information amended, you may send us a written request. You may also ask how this information is used and ensure that it is accurate and complete, and update it if necessary, to the extent permitted by law.

7. Security measures

Evolo Flex maintains strict security measures to protect your personal information from unauthorized access, use, disclosure, modification, loss, theft, or any other breach of security. The information we collect is protected bycomputer security measures that are reasonable in light of its sensitivity.

Physical and physical security measures include:

• Access-controlled offices and locked filing cabinets;
• restricting access to your personal information to a select group of people;
• written contractual obligations with third parties who require access to your personal information, requiring them to protect, through security measures, the confidentiality and security of your personal information and to use it only for the purposes of the contract, mandate or service they are performing.

Computer security measures include:

• the use of passwords;
• regular review of our security practices;
• regular upgrading of our technological equipment;

8. Disclosure to third parties

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 for the person concerned.

Evolo Flex may be required to disclose personal information to third parties, for example, suppliers, contractors, subcontractors, agents, insurers (such as the “Fonds d’assurance responsabilité professionnelle du courtage immobilier du Québec” [the FARCIQ]), professionals, other regulators, or outside Quebec.

Evolo Flex 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, Evolo Flex will draw up a written mandate or contract in which it will indicate the measures to be taken by its agent to ensure that the personal information entrusted to it is protected, 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 Evolo Flex in the event of a breach of confidentiality of personal information.

Before disclosing personal information outside Quebec, Evolo Flex 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. Evolo Flex 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.

9. Withdrawal of consent

You may change or withdraw your consent to the collection, use and disclose your personal information at any time by sending written notice to the PPI Manager. We will process your request as soon as possible.

10. Destruction or anonymization

Once the purposes for which the information was collected have been fulfilled, Evolo Flex will securely destroy or anonymize the information as permitted by law to use it for serious and legitimate purposes. In this respect, Evolo Flex’s professional obligations require it to keep its files for at least ten (10) years following their final closing.

11. Confidentiality incident

A privacy incident is any access, use or disclosure of personal information that is not authorized by law, or any loss or other breach of the protection of personal information.

Evolo Flex has established a protocol for managing a privacy incident, which identifies the persons who assist the Privacy Officer 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.

12. Evaluation process

Evolo Flex will carry out a PIA assessment in the event of any acquisition project or redesign of our computer systems involving personal information. This will be done in consultation with the PPI Manager, based on the sensitivity of the information concerned, its quantity and its purpose.

13. Complaints and processing

Any Person concerned by personal information collected, used, communicated, or retained by Evolo Flex inc. may file a complaint with the PPI Manager. The complaint must be made in writing and must indicate the nature of the facts complained about the date on which the incident occurred, and the expectations as to the outcome of the complaint. The PPI Manager will acknowledge receipt of the complaint and process it within a maximum of 20 days.

Evolo Flex inc. investigates all privacy complaints and takes appropriate measures to resolve them. For further information on how we handle personal information, please contact:

Danick Rivet,Danick Rivet,
PPI Manager, Evolo Flex Inc.
14 Place du Commerce, Suite 320
L’Île-des-Soeurs, Quebec
H3E 1T5
514 769-6000 ext. 3011

drivet@proment.com