Privacy Policy

Effective Date: September 2023
Last Updated: April 2026
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1. Introduction
In the course of our property holding and management activities, Sovima Investissement Inc. (hereinafter "we" or "us") collects and processes personal information concerning its tenants, rental applicants, employees, and suppliers.
This policy is intended to inform you of our practices regarding the collection, use, disclosure, retention, and destruction of your personal information, in accordance with the Act respecting the protection of personal information in the private sector (Law 25).
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2. Privacy Officer
We have designated a person responsible for ensuring compliance with the legislation:

• Name: Camille Legault
• Title: Financial Controller / Privacy Officer
• Contact Information: clegault@groupesovima.com | 450-676-4476 ext. 224
• Address: 100 rue Lansdowne, suite 201, St-Bruno-de-Montarville
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3. Personal Information Collected
We only collect information necessary for the identified purposes. Depending on your relationship with us, this may include:

• Rental applicants: Name, contact details, date of birth, proof of identity, rental history, references, proof of income, and information required for credit checks (with separate consent).
• Tenants: Lease information, emergency contact details, home insurance specifications, payment information (specimen cheques or banking data for automatic withdrawals).
• Visitors/Web users: IP address, cookies via our website.
• Security: Images captured by our surveillance cameras in common areas (if applicable).
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4. Purposes of Collection
We use your information for the following purposes:

• Evaluating rental applications (solvency and references);
• Managing and administering leases and tenant services;
• Ensuring rent collection;
• Carrying out maintenance and repair work;
• Ensuring the security of property and people within the buildings;
• Complying with our legal and regulatory obligations.
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5. Consent
By providing us with your personal information, you consent to its use for the stated purposes. For specific situations (such as credit checks), separate written consent is obtained. You may withdraw your consent at any time (subject to contractual or legal restrictions); however, this may prevent us from providing certain services (e.g., the inability to process a rental application).
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6. Access and Disclosure of Information
Your information is accessible only to employees who require it in the performance of their duties. We may disclose your information to third parties in the following cases:

• Service Providers: Credit reporting agencies, maintenance companies, IT services (cloud storage), collection agencies. These third parties are contractually bound by strict confidentiality obligations.
• Legal Obligations: Government bodies or law enforcement, if required by law.
  Note: We never sell your personal information to third parties.
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7. Retention and Destruction
Personal information is retained for the duration necessary to fulfill the purposes for which it was collected, or as prescribed by law or recommended by government agencies (e.g., keeping a lease after the tenant has moved out).
Once the retention period expires, the information is securely destroyed or anonymized.

8. Security Measures
We have implemented physical, technological, and administrative security measures proportional to the sensitivity of the data:

• Locked offices and filing cabinets;
• Access restricted by passwords and two-factor authentication;
• Updated firewalls and antivirus software;
• Employee training on cybersecurity.
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9. Your Rights
In accordance with Law 25, you have the following rights:

• Access: To consult your personal information.
• Rectification: To request the correction of inaccurate or incomplete information.
• Portability: To receive your information in a structured technological format (if applicable).
• Withdrawal of consent: To modify your privacy preferences.
  To exercise these rights, please contact the Privacy Officer (see section 2).
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10. Privacy Incident
In the event of unauthorized access, loss, or theft of your personal information, we commit to:

1. Notifying the Commission d’accès à l’information du Québec (CAI) if the incident presents a risk of serious injury.
2. Notifying the affected individuals.
3. Maintaining a registry of all privacy incidents.
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11. Policy Updates
We reserve the right to modify this policy to reflect legislative changes or our internal practices. Changes will be published on our website.