Privacy Policy

This website is governed by the laws of Canada. If you are located outside Canada and have questions about how the laws of your country apply to the collection, use or disclosure of your personal information, please contact the privacy commissioner or data supervisory authority of the country in which you are located.

Horizon31's privacy policy is based on Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”), which incorporates the ten principles set out in the National Standard of Canada entitled Model Code for the Protection of Personal Information. For more details on this law, please consult the official website of the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en/.

At Horizon31 (“Horizon31”), we respect the privacy of our clients and are committed to ensuring the accuracy, confidentiality, security and protection of your personal information. We have adopted the following privacy policy to ensure that Horizon31 upholds its commitment to respecting your privacy and protecting your personal information.

Horizon31 supports and advises its clients in acquiring international real estate. Our services include, among other things, selecting and presenting projects, supporting clients throughout the buying process, connecting them with developers and partners, as well as rental management services and other real estate-related advisory services. Horizon31 does not act as a real estate broker.

In providing these services, Horizon31 may collect certain personal information about its clients, employees and partners with their consent. Horizon31 may also collect, use or share information without first obtaining consent where such collection, use or sharing is permitted or required by law.

Within the meaning of the Act respecting the protection of personal information in the private sector, “personal information” means “any information which relates to a natural person and allows that person to be identified.” It may include, among other things, the person's name, home address, email address, date of birth, credit history or any other financial information, credit card information, and other information about their family.

Business contact information is also personal information, but no consent is required to collect, use or disclose this information for the purpose of communicating, or facilitating communication, with someone for professional purposes.

All of our employees and contractors who have access to personal information must adhere to the privacy policy in accordance with applicable law and to Horizon31's related practices. To this end, Horizon31 has appointed Dominic St-Pierre as privacy officer, responsible for ensuring compliance with the policy and for answering your questions regarding confidentiality.

Our services are intended for an adult clientele. Horizon31 does not knowingly collect personal information about minors. If we learn that a minor has provided us with personal information without the required consent, we will take the necessary steps to delete it.

This privacy policy is intended to ensure Horizon31's compliance with the requirements of the laws and regulations applicable in Quebec and reflects respect for the rights of all our clients and other individuals with respect to the collection, holding, use, disclosure and protection of personal information.

In this sense, this policy governs the collection, use, retention and destruction of personal information in order to establish and maintain a relationship of trust between Horizon31 and its clients and other individuals, and to comply with applicable laws.

As part of providing its services and with your consent, Horizon31 and its partners use cookies or similar technologies. These methods make it possible to collect and process personal data, including but not limited to your visits to our website, the collection of IP addresses and cookie identifiers. You will be asked to confirm your consent and, under applicable laws, you may withdraw or limit your consent at any time.

As part of our activities and the provision of our services, we collect a number of personal details about you, such as:

• identity information, such as a first or last name;
• contact details, such as a name, address, email address and phone number;
• biographical information you submit, such as a job title, an employer's name, photos and video or audio content;
• information you provide to us as part of our service delivery, including sensitive personal information;
• billing and financial information, such as a billing address, bank account information or payment data;
• general information, information about education and professional background, details concerning professional affiliations and other information relevant to the services you wish to receive from us;
• identification data and other background-verification data, such as a copy of a driver's licence, passport or utility bill;
• any other personal information provided. Please note that if you provide us with personal information about third parties, you must ensure that you have duly notified them and obtained their consent to such disclosure. This responsibility does not fall to Horizon31.

We use your personal information solely to provide our services and to meet our obligations regarding the mandate you wish to entrust to us. We will retain personal information only for as long as necessary for the purposes set out in this policy and to comply with our related legal, ethical and regulatory obligations. Note that, upon receiving a withdrawal of your consent, we comply with the requirements of the Act in such situations.

In delivering our services, we may use personal information in any of the ways set out below, with your consent or, where applicable, without obtaining your consent when the Act requires or authorizes us to do so:

• to provide our services and conduct our business, to administer and perform our services, including to fulfil our obligations under any agreement entered into between you and us;
• to ensure compliance with our legal and regulatory obligations;
• to ensure the proper conduct of our business and comply with our ethical and professional obligations, including billing, financial management and the management of our files;
• for any other purpose authorized by law or to which you consent;
• for statistical or quality-control purposes.

To collect the requests you submit to us, manage the client relationship and communicate with you, we use the GoHighLevel platform (“GHL”). The information you provide through our forms (name, contact details, details about your project) is collected, hosted and processed there. As GHL is operated from the United States, this information may be hosted or processed outside Quebec and Canada. We limit the information transmitted to GHL to what is reasonably necessary and require that the confidentiality of that information be preserved. We do not use any other third party to collect or manage your personal information.

In addition, we may be required to disclose personal information under certain laws, or if we believe in good faith that such disclosure is necessary to comply with applicable laws or to carry out a mandate entrusted to us, or in order to cooperate with governmental authorities.

From the moment they are collected until they are destroyed, your personal information is currently hosted in Canada, but may be hosted on secure servers that could be located abroad if the nature of the service delivery justifies it. However, please be assured that our practices concerning your personal information remain at all times governed by this policy and, where applicable, contractual commitments are put in place to preserve the confidentiality of that information.

Although we cannot guarantee absolute protection of all your personal information with certainty, we take all necessary measures so that the personal information we collect is protected and stored in accordance with generally accepted industry standards, both during transmission and once we have received it. We maintain appropriate physical, technical and administrative safeguards to protect personal information against theft, loss, accidental or unlawful destruction or disclosure, unauthorized access, misuse or any other unlawful form of processing.

Please note that you may contact us at any time to obtain more information about how your information is protected, or to disclose to us an incident related to the protection of your personal information, in accordance with the “Questions and concerns” section of this policy.

In accordance with applicable privacy laws, you have a number of rights regarding your personal information. These rights include, but are not limited to:

• The right to accuracy of information: so that it is complete, up to date and accurate at the time it is used.
• The right of access to information: the right to be informed about the information processed or used and the right to request access to the personal information held, subject to applicable law.
• The right to have information corrected: the right to request the correction of any incomplete, misleading or inaccurate personal information we hold.
• The right to withdraw consent to the disclosure or use of the personal information collected: at any time, you may withdraw your consent to the disclosure, transmission or use of the information collected.

To exercise any of these rights, please contact us in accordance with the “Questions and concerns” section of this policy.

Under applicable laws, Horizon31 undertakes to report without delay any situation giving reason to believe that “a confidentiality incident involving personal information it holds” has occurred and that presents a risk of serious harm. In such a case, the appointed privacy officer (Dominic St-Pierre) will notify the Commission d'accès à l'information.

Every confidentiality incident is recorded in the “Register of confidentiality incidents” established in accordance with the Act.

This policy is updated to remain compliant with the requirements of the law. Horizon31 therefore invites you to consult the most recent version. After each update, we will assume that you have read the current version of our privacy policy and that we may collect, use and disclose your personal information in accordance with the updated policy, unless you notify us otherwise in writing.

Under the Act respecting the protection of personal information in the private sector, any interested person may, in good faith and without fear of reprisal, file a complaint with the Commission on any matter relating to the protection of personal information as well as on Horizon31's practices in this regard.

In addition to its obligations under the laws applicable in the province of Quebec, Horizon31 wishes to maintain the highest standards by applying the ten privacy principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5). In this sense, the following ten principles govern our actions with respect to the collection, use and disclosure of personal information:

First principle – Accountability

Horizon31 is responsible for all personal information it holds or retains, including personal information transferred to third parties for processing.

Second principle – Identifying purposes for collection

Horizon31 will inform you of the purposes for which it collects personal information, before or at the time of collection.

Third principle – Consent

In accordance with Canadian law, Horizon31 will obtain your consent before or at the time of collecting, using or disclosing your personal information. This consent may be express or implied. You may withdraw your consent at any time on reasonable notice (subject to legal or contractual restrictions). However, Horizon31 may collect, use or disclose personal information without your knowledge or consent in exceptional circumstances when authorized or required by law.

Fourth principle – Limiting collection

The information collected by Horizon31 will be limited to the data necessary for the purposes indicated to you or required to provide the requested services. This information will be collected by fair and lawful means.

Fifth principle – Limiting use, disclosure and retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, unless you consent. It will generally be retained only for as long as necessary to serve the purposes for which it was collected, unless an applicable law requires or permits it to be retained longer.

Sixth principle – Accuracy

Horizon31 will ensure that personal information remains as accurate, complete and up to date as necessary to fulfil the identified purposes. You may modify or complete the information if you discover that it is inaccurate or incomplete.

Seventh principle – Safeguards

Personal information is protected by safeguards appropriate to its level of sensitivity.

Eighth principle – Openness

Horizon31 will make available to its clients, employees and partners the information about the policies and procedures it uses to manage personal information. You can access this information through our websites or by other means upon request.

Ninth principle – Individual access

Upon written request, you will receive information about the existence, use and disclosure of your personal information, and you will be able to consult that information, unless prohibited by law. Horizon31 will respond to such requests as efficiently as possible. If it is prohibited from granting access, it will explain why, except to the extent prohibited by law.

Tenth principle – Challenging compliance

Individuals have the right to raise concerns about an organization's compliance with these principles. Horizon31 has established policies and practices to receive complaints and questions, investigate them and respond. You may contact Horizon31 to raise concerns or to request access to your personal information.

i. Type of information collected

Horizon31 collects various information about you and your devices and uses this information to provide you with the requested products and services and to meet the requirements of applicable law. Some of this information identifies you directly (such as an email address), while other information is associated with you through your account, profile or device.

We do not collect personal information about you when you visit the website (other than your IP address, as described below in the “Website usage information and cookies” section), unless you provide it. All information you provide to us is kept securely and remains strictly confidential. This policy does not apply to aggregated data about people whose precise identity cannot be determined.

ii. Use of your information

At Horizon31, we use personal information for the following purposes:

• To verify your identity;
• To respond to your requests and present you with real estate projects matching your criteria;
• To communicate with you in order to provide our products and services, including updates and other offers that may interest you;
• To include them in the documentation relating to your particular real estate transaction;
• To monitor our service level and follow up with you to ensure your satisfaction;
• To personalize your experience with Horizon31, including by presenting you with relevant results and content;
• To detect, investigate and prevent fraudulent transactions and other illegal activities, and to protect the rights and property of Horizon31, its clients and third parties.

We will use your personal information only for the purposes indicated to you and to which you have expressly or implicitly consented, unless an applicable law requires or permits another use without your consent. If we wish to use your information for any other purpose, we will notify you and request your consent beforehand.

iii. Website usage information, location and cookies

Horizon31 may collect information about your use of this website. Usage information is collected using cookies and may include the pages you visited, your IP address, the items you click on, the time you spend viewing different sections and other usage statistics. This information is used primarily for research and analysis. This aggregated data may be shared with third parties, but will never be accompanied by information that identifies you.

Cookies are small text files containing a unique identification number that allows our computers to recognize your web browser and collect data each time you visit our websites. You can configure your browser to notify you when cookies are received, and you can reject them entirely. However, if you do not accept cookies, you may limit the functionality available when you visit our site.

iv. Authorized disclosure of your information

Horizon31 is required to keep your personal information confidential, except in the following circumstances: when we have your permission; when required by law (for example for tax reporting or under a court order); and when permitted by law (for example in cases of debt collection, medical emergency or suspected illegal activity).

Persons with whom we may share your information: our employees (access is limited to those who have a legitimate reason to use it); our service provider GoHighLevel (GHL), which hosts and processes the information collected through our forms; and, in connection with the sale, merger or transfer of our business, a third party and its professional advisors (the information then to be kept confidential and used only to evaluate and complete the transaction).

v. Security measures to protect information

Horizon31 has organizational, technical and physical controls in place to ensure the security of the information in its possession. Records containing personal information are classified according to the sensitivity of the data. Physical access to premises where personal information is collected, processed or stored is restricted to authorized employees and contractors. As an additional safeguard, we securely destroy your personal information once it has served its intended purposes, unless the law requires or permits it to be retained longer.

vi. Third-party websites

To better serve you, Horizon31 presents on its website links to third-party and social media websites. Horizon31 assumes no responsibility and makes no warranty regarding the content or privacy policy of other linked websites.

vii. Access to your information and corrections

You have the right to consult the personal information we keep in your file and to correct it if it is inaccurate or incomplete. If you wish to consult your file, please send a written request to the privacy officer, at the address indicated in the “Questions and concerns” section. Please note that we will ask you to provide information to verify your identity before granting access. The right of access is not absolute; we may deny you access in certain circumstances provided for by law.

viii. Withdrawal of consent

If you wish to withdraw your consent to the collection, use or disclosure of your personal information, please contact the privacy officer at the contact details found at the end of this document. If you withdraw your consent, we may be unable to provide you with our services that require the use and disclosure of that information.

For any question or concern regarding your personal information or our privacy policy, please contact the privacy officer:

• Dominic St-Pierre, Chief Privacy Officer (Quebec) — dominic@royallepage.ca
• Royal LePage — privacyofficer@royallepage.ca