Data Privacy Policy

SOCIÉTÉ DE DÉVELOPPEMENT ANGUS is committed to protecting all personal information collected and used as part of its operations, in accordance with the applicable privacy legislation. This Privacy Policy applies to the services offered and business activities managed by the Société de développement Angus and its subsidiaries or affiliates for which the Société de développement Angus is a project proponent (collectively,“SDA”). It also applies to personal information collected when visiting the following domains and sub-domains: https://www.sda-angus.com, www.sda-pat.ca, www.technopoleangus.com, https://ateliers3333.com or other sites added to this Privacy Policy from time to time (collectively the“Website”) and when contacting us by any other means of communication or when visiting building or facilities mananged by SDA.

Your privacy is important to us. Our goal is to ensure the privacy and security of the personal information you provide, to protect this information in accordance with applicable privacy legislation and to use such information only for the purposes set out in this Privacy Policy. This Privacy Policy outlines our privacy practices in clear and simple terms. In this Privacy Policy, personal information refers to information that can identify an individual, directly or indirectly, regardless of the medium or form in which it is held, whether written, graphic, audio, visual, electronic or other.

By browsing our Website, contacting us or visiting our buildings or facilities, you accept and agree to the practices outlined in this Privacy Policy. If you do not agree with this policy, we do not recommend using our Website, contacting us or visiting our buildings or facilities.

This Privacy Policy does not apply to the personal information of our employees, former employees or job applicants in relation to their past, present, or future employment, as another policy applies specifically to them. That policy can be accessed by contacting our Privacy Officer using the contact information listed at the end of this Privacy Policy.

POLICY STATEMENT

Personal information under the custody or control of SDA is only inferred, collected, retained, used, disclosed and destroyed in a manner that complies with the Personal Information Protection and Electronic Documents Act , S.C. 2000, c. 5, the Act Respecting the Protection of Personal Information in the Private Sector, CQLR, c. P‑39.1 and other similar provincial legislation (the“Privacy Laws”) We respect the right to privacy of individuals whose personal information is in our possession, in accordance with these Privacy Laws.

In accordance with the Privacy Laws, everyone working with, for or on behalf of SDA are required to respect the confidentiality of personal information and right to privacy of any individual, when collecting, using, disclosing, retaining or destroying such personal information in the performance of their duties.

CONSENT

The SDA obtains written or electronic consent from individuals in the following situations:

Prior to collecting personal information, except where a request for consent would result in the collection of inaccurate information, defeat the purpose of collection, or compromise the use of the information collected. For example, the SDA will generally consult the originator of a complaint to indirectly collect personal information for the purpose of conducting an investigation.

Prior to using or disclosing personal information for purposes other than those for which the personal information was collected or prepared.

Prior to any disclosure of a complaint received by the SDA or any privileged or confidential information obtained during an investigation or proceeding. In this case, we obtain the written consent of all persons whose rights or interests might reasonably be affected.

Obtaining an individual’s consent to collect personal information neither replaces nor establishes the authority to collect this information under the Privacy Laws. SDA ensures that the personal information to be collected is directly related and necessary to SDA’s business and the services it provides to the individuals concerned.

COLLECTION OF PERSONAL INFORMATION

Personal information can only be collected or inferred under the following conditions:

The personal information is directly related to SDA’s business activities or services provided to that individual.

The collection of this personal information is necessary to allow SDA to fulfill the purposes required by law or to achieve its objectives.

Before collecting or creating new personal information, SDA shall:

Determine which personal information will be collected.

Determine the purposes for collecting each type of personal information.

Collect only such personal information that is necessary for those specific reasons.

SDA collects or creates personal information for use directly from the data subject, except in any of the following instances:

The person authorizes SDA to collect personal information from a third party.

The personal information is collected for a purpose that may be disclosed to SDA.

The collection of personal information directly from the person concerned could result in the collection of inaccurate information.

The collection of personal information directly from the person concerned may defeat or compromise the purpose for which the personal information is collected. For example, SDA will generally consult the originator of a complaint to indirectly collect personal information for the purpose of conducting an investigation.

We limit the collection, use, and disclosure of your personal information solely to the indicated purposes. Only certain authorized persons can view your personal information, strictly within the scope of their duties and on a need-to-know basis.

COLLECTION OF PERSONAL INFORMATION AND PURPOSE

We collect personal information:

When you contact us (by email, phone, mail, chat or in person), we may collect your name, email, address, phone number, language of communication, and profile corresponding to your product preference(s). This information enables us to provide information or services related to your request and contact you, if necessary.
When you subscribe to our newsletter or sign up for a promotional or social/cultural activity offered by SDA, we will collect your name, phone number and email address to send you communications about our promotions and activities. You can modify your preferences by clicking on the“Unsubscribe” link at the bottom of the email or communication received. We use this information to provide you with details about current and future activities, products and services or other SDA developments or projects.
When you contact us about housing that meets certain criteria related to your physical health, we may collect personal health information (mobility issues, elevator requirement, handicap parking space availability, etc.). We use this information to find a building that fits your needs.
When you fill out an SDA survey, we use the information collected to better understand how to improve our products and services (including through surveys conducted by us or on our behalf), develop and guide our business, operations and projects, and achieve other internal or corporate business objectives.
When you express an interest in one of our products (offices, commercial space or housing), we collect the personal information required to process the transaction, including your name and/or the name of your business, relevant current address, email address, phone number, photo ID, banking or financial information, and more.
When you visit our Website, we automatically collect information about you through cookies. Cookies are bits of information stored on your computer or other device used to connect to the Internet (such as a smart phone, tablet or other mobile device) when you visit a website, which store and sometimes track information about your site usage. For more information, please see the section Cookies and IP addresses below.
When you visit our facilities or buildings, we may collect audiovisual, CCTV or other similar information (such as security camera footage, service call recordings, etc.). We use CCTV monitoring in the areas surrounding our offices or buildings for security purposes, including to detect theft, fraud or vandalism, and damage to our property, clientele or employees.

INFORMATION ABOUT YOU COLLECTED FROM THIRD PARTIES

Your personal information will generally be collected directly from you. However, we may collect personal information from third parties, to the extent permitted by law.

We may also collect personal information to comply with applicable legal and regulatory requirements, or for other purposes permitted by law. We do not collect personal information for other purposes, unless consent is obtained from the person concerned.

USE AND DISCLOSURE OF PERSONAL INFORMATION

We use or disclose personal information only to the extent that is reasonably necessary to achieve the purposes listed above. We may share your personal information with our affiliates or subsidiaries when required to achieve these objectives.

You have the right to opt out of receiving future communications from us at any time. If you would like to stop receiving all emails from us, you can unsubscribe by clicking on the designated link.

In some cases, we may share personal information with third party service providers acting on our behalf, including IT services, security and surveillance camera services, mail delivery services, building management services, legal and human resources services, or analysis or marketing services.

We may also disclose your personal information as part of a business transaction, in connection with the proposed or actual financing, debt collection, insurance, sale, assignment or other disposition of all or part of SDA, its subsidiaries or affiliates, or their business or assets, for the purposes of evaluating and/or executing the proposed transaction. Assignees or successors of SDA, its subsidiaries or affiliates, or their businesses or assets, may use and disclose your personal information for purposes similar to those outlined in this Privacy Policy.

Finally, your personal information may be disclosed as necessary to meet legal, regulatory, insurance, audit and security requirements or as permitted or required by law (including as required by Canadian and foreign laws applicable to us or our service providers). Consequently, in response to a verified request from law enforcement authorities or a government official regarding a criminal investigation or suspected illegal activity, we may (and you authorize us to), to the extent permitted by law, disclose your name, city, province, telephone number, email address and the content of our discussions with you regarding your product preferences, without a subpoena.

We do not sell, lease or exchange your personal information to third parties. Your personal information is communicated without your consent only to the extent outlined in this Privacy Policy and as permitted or required by law.

DISCLOSURE OF PERSONAL INFORMATION

Personal information held by SDA will not be disclosed to third parties without the consent of the person concerned, except where such disclosure is authorized or required under Privacy Laws.

Any person subject to this Privacy Policy must:

Disclose only the minimum personal information required to fulfill the purposes described above.

Consult our privacy officer prior to disclosing personal information other than the information required to fulfill the purposes described above.

RETENTION OF INFORMATION

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected. We destroy this information in accordance with the law and with our personal information retention policy. When we destroy your personal information, we take the necessary steps to maintain confidentiality and ensure that no unauthorized persons can access such information during the destruction process.

We will retain personal information on our internal servers or with service providers. The personal information collected about you may be stored and/or processed outside of Quebec and/or Canada. Our service providers may store and process personal information outside of Quebec and Canada. Please note that the privacy legislation of these jurisdictions may differ from the Privacy Laws. We have taken the appropriate technical, organizational and contractual measures to secure this personal information.

We ensure that our service providers comply with all applicable legislation regarding the protection of personal information, and our contract clauses require them to adhere to obligations similar to those described in this Privacy Policy. For more information on the processing of your personal information outside the country or the retention of your personal information, please contact our Privacy Officer (contact details below).

HOSTING AND TRANSFER OF PERSONAL INFORMATION

Cookies and IP addresses

Visitors should also know that anonymous technical data may be collected when visiting our Website. This may include the visitor’s IP address, browser type and operating system, domain name, access times, and referring website addresses. We use this data to identify the person, collect general demographic information on Website users, diagnose problems with our systems and administer the Website.

We will not attempt to link or correlate this anonymous technical data with personally identifiable information, unless we (or our service providers) have obtained your consent, or in accordance with the Privacy Laws.

We also use Google Analytics to better understand who uses our Website and how people use it. Google Analytics uses cookies to collect information such as site pages visited, locations where users click, time spent on each site page, IP address, type of operating system used and your location. Please visit http://www.google.com/policies/privacy/partners to read about how Google Analytics uses this information. Google can track your activity over time and across different websites. This information is used to send targeted ads and content likely to be of interest to you and to provide statistical information through functionalities such as Google Analytics and Google Ads.

Many web browsers allow you to manage your preferences. You can configure your browser to refuse or delete cookies. You may be able to manage other tracking technologies in the same way. In some cases, tracking tools used by third-party service providers can be deactivated. For example, Google allows you to deactivate cookies used to target ads by accessing the deactivation page on its main site. Google Analytics can also be deactivated by downloading an available browser add-on for this purpose. You can also refuse cookies from other third-party providers by visiting the Consumer Opt Out page of the Network Advertising Initiative.

Third-party websites

Our Website may contain links to other third-party websites which may collect personal information. This Privacy Policy does not include the privacy practices of those third parties (or absence thereof). We cannot and will not be held accountable for the policies, practices and actions of such third parties. Please be aware that you remain responsible for the protection of your personal information when you view the content of third-party websites, and we encourage you to read any privacy notices or policies governing such third parties.

ACCURACY

SDA takes reasonable steps to ensure that personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used, and to minimize the possibility that inaccurate or incomplete information will be used to make a decision that directly affects an individual.

SDA has documented procedures that allow individuals to request correction of their personal information if they believe that there is an error or omission.

We do not systematically update personal information unless necessary to fulfill the purposes for which it was collected. The accuracy, recency and completeness of your personal information will depend on the information you have provided to us.

RESPONSIBILITY

We are responsible for the personal information in our possession or custody, including the personal information we entrust to third parties for processing. We require that such third parties retain this information according to strict privacy and security standards, in compliance with this Privacy Policy.

Our Privacy Officer supervises this Privacy Policy and the associated processes and procedures to be followed to protect personal information.

Our staff has been informed and adequately trained on our privacy policies and practices.

SECURITY MEASURES

SDA is obligated to protect the personal information in its custody or control from risks such as unauthorized access, collection, use or disclosure, taking reasonable steps to do so. This includes a combination of technical, administrative and physical measures. The reasonableness of these security measures takes into account factors such as the sensitivity, quantity, distribution, format and storage method of the personal information to be protected.

We have put in place and continue to develop rigorous security measures to ensure that your personal information remains strictly confidential and is protected against loss or theft, and any unauthorized access, communication, copying, use or modification.

However, it is important to note that any information transmitted via the Internet, including through our Website or by email, may be intercepted by a third party. Consequently, we cannot and will not be held accountable for the theft, loss, misuse or alteration of any personal information transmitted over the Internet.

The safety and security of your personal information is also your responsibility. If you create a profile on our Website, your password is a key tool for protecting your account. We recommend creating a password with a combination of unique numbers, uppercase and lowercase letters and special characters, and not to share that password with anyone.

These security measures include organizational measures such as restricting access to what is necessary, backing up and archiving data (using an external system, etc.), and technology measures such as the use of passwords and encryption (e.g., frequent password changes and firewalls).

Accessing personal information

SDA requires that access to personal information be based on roles, the need to know and limited to the minimum amount of information necessary for authorized purposes.

SDA monitors access to and use of personal information to rapidly detect any inappropriate or unauthorized access or processing of personal information, using methods such as audits.

SDA requires that its service providers fulfill the legal obligations of SDA with respect to the processing and protection of personal information, and service providers must comply with this Privacy Policy.

RIGHTS CONCERNING YOUR PERSONAL INFORMATION

Accessing your personal information

Subject to the exceptions set out in the Privacy Laws, any individual may access, review or receive a copy of their personal information held by SDA by submitting a written request to our Privacy Officer.

We will send you such information within a maximum of 30 days from the date your written request is received. You may access your personal information free of charge, but reasonable costs may be charged for the transcription, copying, or transmission of your personal information.

In the specific circumstances set out in the Privacy Laws, we may refuse to provide you with the requested information.

Correcting personal information

You can verify the accuracy and completeness of your personal information and, if applicable, request a change. Change requests will be processed within 30 days.

More information on the processing of your personal information

You are entitled to receive additional information about the processing of your personal information. If you do not find the answers to your questions in this Privacy Policy, you may contact our Privacy Officer using the contact information listed below.

Be notified if you are the subject of a decision based exclusively on automated processing

If we use your personal information to make a decision based exclusively on automated processing, we will advise you no later than the moment we inform you of that decision. In this case, you also have a right to request:

• Notification of the information used to make the decision.

• The reasons and primary factors and parameters that led to the decision.

• Correction of the personal information used to make the decision.

• Submit your observations to a member of our team who can review the decision, if applicable.

You may exercise this right by contacting our Privacy Officer using the contact information below.

Withdrawing consent

In some cases, you may refuse or withdraw your consent to the collection, use, and disclosure of your personal information, request the deletion of any personal information we hold about you, at any time upon reasonable notice, subject to any legal or contract requirements.

If we are unable to approve your request, we will notify you of the reasons, subject to any legal or regulatory requirements.

De-indexing, re-indexing and ceasing dissemination of your personal information

You have the right to require that we cease disseminating your personal information or that we de-index any hyperlink attached to your name providing access to your information by technological means if the dissemination of your information contravenes the law or a court order.

This right also exists to the extent that:

The dissemination of the information causes serious harm to your reputation or privacy.
This harm clearly outweighs the public’s interest in knowing the information or any person’s interest in expressing themselves freely.
Ceasing dissemination, re-indexing or de-indexing does not go beyond what is necessary to stop perpetuating the harm.

You may exercise this right by contacting our Privacy Officer using the contact information below. We generally respond to these requests within 30 days of receipt of your request. If we are unable to respond to your request, or if additional time is required to respond to a request, we will inform you in writing.

Right to portability

You have the right to receive the computerized personal information we have collected directly from you in a structured, commonly used technological format. You may also request that this personal information be sent directly to another person.

Contact us

If you have questions or concerns about this Privacy Policy, or if you would like to file a complaint, please contact our Privacy Officer:

Privacy Officer

Marylène Couture

confidentialite@sda-angus.com

514−528−5230 ext. 244

200‑2600 rue William-Tremblay

Montreal, QC, H1Y 3J2

COMPLAINTS AND QUESTIONS

You may contact the Privacy Officer using the contact information listed above.

Any complaint regarding the protection of personal information must be forwarded to the Privacy Officer at the address above.

We will investigate all complaints. If a complaint is found to have merit, we will take appropriate action including amending our policies and practices, if necessary.

Training and awareness

SDA promotes best practices and respect for privacy rights in a number of ways:

Informing all staff on its team of their obligations

Posting the name and contact information of the Privacy Officer

Implementing different awareness measures, including privacy information sessions, reminders during team meetings, staff training, a privacy action plan, a log, etc.

Application

If for any reason you believe that SDA has not adhered to this Privacy Policy, please inform us by contacting our Privacy Officer. We will do whatever is necessary to identify and correct the problem within a reasonable timeframe. Please use the subject“Privacy”.

POLICY UPDATES

This Privacy Policy is updated every three years. It shall also be updated when any substantial change is made to the Privacy Laws and to any legislation or regulations applicable to SDA.

Updated: October 4, 2024