Privacy Policy

1. Company Presentation

Habitation Plani-Conseil maintains and transforms buildings through thorough planning, coordination and construction processes for owners who value compliance, precision, and fine craftsmanship and who recognize the value of sustainable real estate assets.

2. Context

To respect your right to privacy and the protection of Personal Information, we have adopted a policy on the protection of Personal Information in accordance with the Act respecting the protection of personal information in the private sector (RLRQ, c. P-39.1, hereinafter referred to as the Act).

By communicating Personal Information to us (notably via online service request, email, text message, Messenger, postal mail or by telephone), you agree to our processing of such information in accordance with this Privacy Policy.

3. Responsibility

Habitation Plani-Conseil inc. is responsible for protecting the Personal Information it holds. All Habitation Plani-Conseil inc. employees must take the necessary measures to ensure the security of Personal Information, regardless of the nature of the medium or the form in which it is accessible: written, graphic, sound, visual, computerized, or other. 

4. Objective

The Act protects an individual’s Personal Information, to prevent and counter identity theft, financial fraud, or damage to reputation.

To promote sound, stringent, and preventive practices, the Act stipulates that a company must designate a person to act as Privacy Officer. At our company, Martine Rioux is in charge of ensuring compliance with the Act.

5. Definition

For the purposes of this Policy, the following definitions apply:

Anonymized Information: any information that no longer allows a person to be identified directly or indirectly in an irreversible manner.

Personal Information: any information concerning a natural person that directly or indirectly allows that person to be identified. For example, a person’s last name, first name, social insurance number, date of birth or home address is Personal Information.

Sensitive Information: Personal Information is considered sensitive when, because of its medical, biometric, or other intimate nature, or because of the context in which it is used or communicated, it gives rise to a high reasonable expectation of privacy.

6. Collection

Any person at Habitation Plani-Conseil inc. who collects Personal Information about others must collect only the information required for the purposes identified prior to collection.

At the time of collection, we emphasize transparency so that the person concerned can give informed consent to the transmission of their Personal Information.

In addition, we limit access to Personal Information to those employees of our company who are authorized to do so in the performance of their duties.

7. Roles and responsibilities

The President:

  • ensures that the provisions of the Act respecting the protection of personal information in the private sector are respected and implemented within Habitation Plani-Conseil inc.;
  • may delegate in writing to a staff member responsibility for access to documents and the protection of Personal Information;
  • facilitates the performance of the Privacy Officer’s duties;
  • approves the present Policy and the means of its application;
  • supports the implementation and dissemination of this Policy.

The Privacy Officer 

  • ensures that the provisions of the Act respecting the protection of personal information in the private sector are respected and implemented within Habitation Plani-Conseil inc.;
  • ensures compliance with this Policy and with legal, regulatory and administrative obligations relating to access to documents and the protection of Personal Information;
  • supports managers and assumes an advisory, support and coaching role with the organization’s staff;
  • proposes the tools required to implement this Policy;
  • handles complaints relating to the protection of Personal Information in accordance with the Act, and records them in the Personal Information Management Complaints Register;
  • handles requests for access to documents and Personal Information, as well as requests for rectification in accordance with the Act;
  • conducts privacy impact assessments for all projects involving the acquisition, development or redesign of information systems or the electronic delivery of services involving the collection, use, disclosure, retention or destruction of Personal Information; 
  • conducts a privacy impact assessment for any disclosure of Personal Information outside Québec and determines whether the disclosure is adequately protected.

The Managers:

The managers are the holders of the Personal Information under their responsibility. As such, they are responsible for the management and protection of Personal Information held by staff under their responsibility.  

More specifically, they:  

  • ensure compliance with this Policy and any procedures or directives arising from it;
  • ensure that staff under their responsibility use secure means to collect, use, store, communicate or destroy Personal Information; 
  • take appropriate action in the event of a breach of this Policy or of the rules governing the protection of Personal Information by a member of staff under their responsibility; 
  • sensitize staff under their responsibility to the importance of protecting Personal Information, in collaboration with the Privacy Officer. 

The Staff: 

  • is aware of this Policy and respects its spirit, provisions and procedures;
  • takes the necessary measures to ensure the protection of Personal Information to which they have access;
  • accesses only the Personal Information required to perform their duties;
  • uses the Personal Information to which they have access for the purposes for which it was collected;
  • informs their manager and the Privacy Officer of any incident relating to the protection of Personal Information held by the company;
  • participates in awareness-raising and training activities on the protection of Personal Information made available by Habitation Plani-Conseil inc.

8. Security Measures

We use your Personal Information to fulfill a request for service, for the purposes of the contract between the parties, and we may produce photographic images and a short description of your project (without contact information) for advertising purposes.

We adopt stringent security measures to protect your Personal Information against theft, loss, unauthorized access, use or disclosure, and against any breach of the security of such information.

These security measures consider the nature, purpose, sensitivity, quality, distribution and medium of the Personal Information.

9. Consent

Habitation Plani-Conseil inc. ensures that consent to the collection, use or disclosure of an individual’s Personal Information to a third party is manifest, free, informed and given for specific purposes. Consent must be obvious, freely given, fully informed and precise. It is requested for each of these purposes, in clear and simple terms. The person concerned must be well informed. In the case of sensitive information, consent must be expressly given. 

When the request for consent is made in writing, it must be presented separately from any other information communicated to the person concerned. The latter may request assistance in understanding the scope of the consent requested. Consent is valid only for the time required to achieve the purposes for which it was requested. 

In certain situations, Habitation Plani-Conseil inc. may use Personal Information without the consent of the person concerned 

  • When it is used for purposes compatible with those for which it was collected.  
  • When its use is clearly for the benefit of the person concerned.  
  • When its use is necessary for the prevention and detection of fraud or the assessment and improvement of protection and security measures.  
  • When its use is necessary for the supply or delivery of a product, or the provision of a service requested by the person concerned.  
  • When its use is necessary for the purposes of study, research, or the production of statistics, and when it is depersonalized

9.1 Right to Withdraw Consent

You have the right to withdraw your consent to the disclosure or use of the information collected. To withdraw your consent, please send a written via our contact form. 

10. Retention and Use

Habitation Plani-Conseil inc. ensures that the Personal Information it holds is up-to-date, accurate and used only for the purposes for which it was collected. If you notice any inaccuracies in our records or if your Personal Information changes, please inform us immediately.  

Upon request, the person concerned is informed of the Personal Information collected from them, the categories of persons who have access to this information within Habitation Plani-Conseil inc., the length of time this information is kept, and the Privacy Officer’s contact information. 

In all cases, the information must be transmitted to the person concerned in clear and simple terms, regardless of the means used to collect the information. 

11. Retention, Destruction and Anonymization

Your Personal Information will be retained only as long as necessary for the fulfillment of the purposes for which it was collected and in accordance with applicable laws and regulations governing retention periods. 

When it is no longer necessary to retain Personal Information, we will destroy or anonymize it, depending on the circumstances. 

12. Communication

A person employed by Habitation Plani-Conseil inc. may not communicate Personal Information they hold about another person, unless the person concerned consents, or the law provides for it.  

Habitation Plani-Conseil inc. may communicate, without the consent of the person concerned, Personal Information to any person or organization if such communication is necessary for the exercise of a mandate or the performance of a contract for services or undertakings entrusted to such person or organization. In such a case, Habitation Plani-Conseil inc. undertakes to ensure that the mandate, service contract or contract for services is evidenced in writing and that it indicates measures to protect the privacy of the Personal Information communicated.  

Similarly, Habitation Plani-Conseil inc. may, without the consent of the person concerned, communicate Personal Information it holds on another person: 

  • to its attorney; 
  • to the Directeur des poursuites criminelles et pénales, if the information is required for prosecution of an offence under a law applicable in Québec;    
  • to a person to whom it is necessary to communicate the information under a law applicable in Québec or for the application of a collective agreement; 
  • to a person who, by law, may collect debts for others and who requires it for this purpose in the performance of their duties;  
  • to a person if the information is necessary for the purposes of recovering a debt owed to the company. 

13. Privacy Incident

The following is considered a privacy incident: unauthorized access, use or disclosure of Personal Information, as well as the loss or any other breach in the protection of Personal Information. 

If an incident presents a risk of serious harm, the person responsible for the protection of Personal Information must, with due diligence, notify the Commission d’accès à l’information du Québec as well as any person concerned by the incident. 

However, no notice will be given to a person concerned by a privacy incident presenting a risk of serious prejudice, if this is likely to hinder an investigation by a person or body responsible for preventing, detecting, or repressing crime or offences against the law. 

14. Limitation of Liability

The use of technologies such as the Internet involves considerable risk. As a result, it is impossible to guarantee that the Personal Information you provide is completely secure. However, please be assured that we use all reasonable means at our disposal to protect your data.  

Consequently, you acknowledge that Habitation Plani-Conseil inc. and its employees shall not be held liable for any damages or injury that may arise or result, directly or indirectly, from a breach of confidentiality of data and/or information transmitted over the Internet to our company. 

15. Request for Access to Information and Complaint

If you have any questions or complaints about this Policy, or if you would like to request access to or the correction of your Personal Information, please contact our Privacy Officer, Martine Rioux. 

16. Complaints-Handling Procedure

16.1 Receiving Complaints

16.1.1 Complaints may be made in writing, by telephone, email or any other official communication channel and forwarded to the attention of our Privacy Officer. Upon receipt, they will be recorded in a centralized register, accessible only by the Privacy Officer. 

16.2 Preliminary Assessment 

16.2.1 The designated person in charge reviews each complaint to assess its relevance and seriousness. 
16.2.2 Complaints that are frivolous, defamatory or without obvious basis may be rejected. However, a justification will be provided to the complainant. 

16.3 Investigation and Analysis 

16.3.1 The person in charge of the complaint conducts a thorough investigation by gathering evidence, interviewing the parties involved and collecting all relevant documents. 
16.3.2 The person in charge remains impartial and has the necessary authority to resolve the complaint. 
16.3.3 The person in charge maintains the confidentiality of information related to the complaint and ensures that all parties involved are treated fairly. 

16.4 Complaint Resolution 

16.4.1 The person responsible for the complaint suggests appropriate solutions to resolve the complaint as quickly as possible. 

16.5 Communication with the Complainant 

16.5.1 The person in charge of the complaint communicates regularly with the complainant to inform them of the progress of the investigation and resolution of the complaint. 
16.5.2 All communications must be professional and respectful. 

16.6 Closure of the Complaint

16.6.1 Once the complaint has been resolved, the person responsible for the complaint provides a written response to the complainant, summarizing the measures taken and the proposed solutions. 
16.6.2 All information and documents pertaining to the complaint will be kept in a confidential file. 

17. Cookies

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18. Amendments and Updates to the Privacy Policy

This Privacy Policy may be amended at any time. 

Last updated on: November 19, 2023