Privacy Policy
current version: 2023.09.22
This Privacy Policy (hereafter the "Policy") sets out Collège de l'immobilier du Québec's practices regarding the collection, use, disclosure, and retention of your personal information. To make the Policy easier to read, we identify ourselves as CIQ or simply "we".
Our Policy applies regardless of how we collect your personal information, for example, in person, by telephone, by e-mail, or via our website.
In some situations, we may be able to provide you with additional information about the processing of your personal information when collecting it, for example, by using a separate form.
By accepting our Policy or by providing us with personal information after having had the opportunity to review the Policy or any supplemental notice, you agree that your personal information may be processed in accordance with our Policy and any supplemental form.
1. How Can You Contact Our Privacy Officer?
You can contact our Privacy Officer:
by e-mail: responsable.rp@collegeimmobilier.com
for the attention of : Privacy offer
by mail : 600 chemin du Golf, Montréal, Québec, H3E 1A8
for the attention of : Privacy offer
2. What Is the Personal Information We Collect and for What Purposes?
2.1 Student and Candidate Management: We process, use, disclose, and retain the personal information of CIQ students for operational purposes in order to be able to offer various services to students, following CIQ admissions and registrations, and to maintain student records. The CIQ will also process the personal information of candidates applying to study at the CIQ. The personal information collected and used for the above purposes includes, but is not limited to, last name, first name, address, e-mail address, telephone number, date of birth, citizenship, birth certificate information and copy, permanent code, social insurance number, gender, father's and mother's names, and financial information such as credit card information.
2.2 Management of Teachers, Trainers, Human Resources, and Candidates: We process, use, disclose, and retain the personal information of teachers and educators, employees, and members of QIC committees to, among other things, maintain employee files, evaluate and analyze pre-hire candidates, and for payroll processing. The personal information collected includes, but is not limited to: last name, first name, personal address, previous addresses, date of birth, telephone number, resume, social insurance number, sex, marital status, emergency contact, employment history, criminal history, financial information related to bank accounts, cheque specimen, signature, certificates and diplomas, psychometric tests, and pre-employment tests.
2.3 General Governance of the CIQ: We process, use, disclose, and retain the personal information of the directors of the QIC, including, but not limited to, the directors’ identification documents collected at the beginning of their mandate, in order to be able to keep the QIC’s information up to date in the public corporate registries.
2.4 General Management of Finance: We process, use, disclose, and retain the personal information of CIQ students, teachers, educators, employees, directors, committee members, service providers, contractors, and other business partners to, among other things, manage payroll, billing, and identity validation in certain situations. Personal information collected for these purposes includes, but is not limited to, last name, first name, telephone number, date of birth, gender, banking information, personal address, business address, licence number, and other information in the OACIQ file or information relating to the business associated with the broker.
2.5 Communications and Marketing Operations: We process, use, disclose, and retain the personal information of our website users, students, teachers, and trainers for purposes including, but not limited to, producing occasional communications for promotional purposes and analyzing Web site traffic. The personal information collected includes, but is not limited to: e-mail address, last name, first name, gender, geographic location, public Meta account data, browsing data, IP address, and browser type.
Please refer to our Policy on the Use of Cookies attached hereto as Appendix A for more information on how your personal information is handled through our website.
3. How Do We Collect Your Personal Information?
3.1 We collect your personal information directly from you for the purposes of:
3.1.1 student management when you voluntarily provide your personal information via online registration and admission, when you contact us by phone, in writing via mail or email, via one of our forms or via the instant messaging platform available on our website.
3.1.2 managing of CIQ teachers and instructors when you voluntarily provide your personal information when you communicate with us by email, telephone, or in writing via mail or one of our forms.
3.1.3 managing relations with CIQ suppliers when you voluntarily provide your personal information when you enter into a written or verbal contractual agreement with the CIQ.
3.1.4 human resources management when you voluntarily provide your personal information through your communications with us, by email, by phone or in person, when you apply for a job with us, when you fill out pre-employment and post-employment forms, and when you submit your payroll information;
3.1.5.general governance when you provide your personal information through your communications with us, by email, by phone, or in person, when you apply for a position on the board and / or a committee, when you submit your information for payroll purposes, and when you provide us with your identification at the beginning of your mandate.
3.1.6 financial management when you voluntarily provide your personal information through your communications with us, by email, by phone, or in person, when you complete our forms, when you register or use our services, and when you submit your information for payroll or billing purposes;
3.1.7 communications and marketing transactions when you voluntarily provide your personal information through your communications with us, by email, website, online chat, by phone, or in person, when you sign up for the online portal or our distribution lists, when you use our services, and when you visit our website (in this regard, you can consult our Policy on the Use of Cookies attached as Appendix A hereto).
We wish to draw your attention to the fact that the information you provide directly to us in one of the ways mentioned in section 3.1 or obtained from a third party as indicated in section 3.2 may be exchanged between the various internal stakeholders within the CIQ when necessary for the proper functioning of the CIQ’s operations. Section 4 describes in more detail who will have access to your personal information within the CIQ.
3.2 We collect your personal information from third parties or service providers for:
3.2.1. CIQ student management: through student, transactional, and training platforms such as Omnivox.
3.2.2 management of CIQ teachers and instructors: with real estate agencies, professional orders, OACIQ, and with third-party affiliates mentioned in section 4.2
3.2.3 human resources management: with digital platforms such as Linkedin, Indeed, JobBoom, and JobIllico, with former employers, and with affiliated third parties mentioned in section 4.2;
3.2.4 general communications and marketing operations: Google Analytics, Meta, and Bing.
3.3 Minor Under 14 Years of Age
We do not voluntarily collect the personal information of individuals under the age of 14.
If you are a minor under the age of 14, you may not provide us with personal information without the express consent of a parent or guardian.
If you are a parent or guardian and are aware that your children have provided us with personal information, please contact us.
If we discover that we have collected personal information from a person under the age of 14 without the consent of the person having parental authority or guardian, we will take the necessary steps to remove that information from our systems.
4. Who Will Have Access to Your Personal Information Within the CIQ and to Whom Will We Share Your Personal Information?
4.1 In-House
Within the CIQ, employees who necessarily need access to your personal information in the performance of their duties will have access to your personal information only when necessary to fulfill the purposes for which you have agreed.
4.2 Affiliated Entities
We may disclose to and receive from the Association professionnelle des courtiers immobiliers du Québec (“APCIQ”) and Centris Corporation Inc. (“Centris”), which are affiliates of the CIQ, certain personal information in connection with the outsourcing of organizational services, including for instance the services of the APCIQ’s human resources, APCIQ’s finance and Centris’ information technology services.
4.3 Third Parties and Service Providers
We may transfer your personal information to third parties and service providers in connection with our operations. Here are the categories of third parties and service providers to whom your personal information may be transmitted:
|
Third Parties |
Categories of Personal Information |
Purposes |
|
Government institutions or other public entities such as the Ministry of Higher Education, Student Financial Assistance, the Organisme d’autoréglementation du courtage immobilier du Québec. |
Information about students, teachers, and employees. |
Comply with government requests and comply with our regulatory obligations. |
|
Student, transactional, training, or support platforms for our operations such as Omnivox, Moneris, Dynamics 365, Sharepoint, or OneDrive. |
Information about students, teachers, employees, and candidates. |
Provide our services, manage transactions and operations. |
5. What Fully Automated Decisions Are Made Using Your Personal Information?
We are not currently making fully automated decisions about you. Should this change, we will inform you and you will be able to make representations to that effect in order to have those decisions reviewed.
6. What Identification, Profiling, or Localizing Technologies Do We Use?
We use technologies to identify, locate, or profile you through the use of cookies.
These technologies enable the following functionalities in particular: consent management, cookie control, personalization, preference management, regulatory compliance, data storage, analysis reports on cookie use, regulatory compliance, and website performance. You can activate these technologies by accepting the cookies identified as being used for identification, profiling, or localization on our website's cookie banner.
For more information, please refer to our Policy on the Use of Cookies at Appendix A.
7. How Long Do We Keep Your Personal Information?
We will keep your personal information until the purposes for which it was collected have been fulfilled. However, we may be able to retain your personal information for a longer period of time when required to comply with our legal and regulatory obligations relating to the retention or storage of information or files.
For more information on how long we retain personal information, please contact our Privacy Officer.
You understand that your consent is therefore valid for this period, unless you exercise your right to withdraw your consent, with the consequences that such a request entails, as described below.
8. Where Do We Keep the Personal Information and Is It Transferred Outside Quebec?
Your personal information is currently held virtually on the servers of the College or our affiliates and is hosted in the United States for Dynamics 365 and in Canada for Sharepoint and OneDrive. Some of your personal information is also hosted on webcasting, email and survey solutions, and on student, transactional, training, and other platforms which we use such as the Omnivox platform. When using these platforms, your personal information may be transferred and stored outside Québec by its suppliers.
Some of your personal information is also archived and kept physically on paper at the CIQ’s head office. All physically-held personal information is protected by secure and restricted access to its physical location in accordance with section 4.1 hereof.
When we consider that the disclosure of your personal information outside Québec will be necessary to support our operations, we will assess whether or not your personal information is adequately protected in the event of disclosure. We will only disclose your personal information if we are satisfied that it is adequately protected. Disclosure will also be governed by an appropriate contractual arrangement.
9. Protection Measures and Inherent Risks
We deploy appropriate security measures to protect your personal information. In particular, we have put in place appropriate physical, technical and administrative safeguards to ensure the protection of personal information.
Despite these measures, given the risks inherent in using computer systems, we cannot, however, ensure or guarantee the security and confidentiality of the personal information you send or provide to us, and you do so at your own risk.
If you have reason to believe that personal information has been compromised, please contact our Privacy Officer.
10. What Are Your Rights with Respect to Your Personal Information?
The law provides you with various rights regarding your personal information. In particular, you have the following rights:
10.1 Access to Your Personal Information : You can ask us if we have personal information about you and, if so, you can request access to that personal information. You may have access to some of your personal information through platforms such as Omnivox.
10.2 Rectification : You can ask us to correct any incomplete or inaccurate personal information we have about you. In some cases, you may be able to correct some of your personal information through platforms such as Omnivox.
10.3 Withdrawal of Consent : You may withdraw your consent to the disclosure or use of the personal information we have about you.
However, you understand that in such a case, you may no longer be able to benefit from our services. Depending on the scope of your request, the removal of your information may no longer allow us to keep you as a student or teacher, for example. If your request by its nature implies an inability to pursue the contract with us, certain penalties or contractual consequences may apply.
10.4 Stop Broadcasting or De-Indexation : You can ask us to stop distributing your personal information or to de-index any hyperlink attached to your name that allows access to this information by technological means, if the distribution of this information contravenes the law or a court order.
You can also require that the hyperlink to this information be re-indexed, if the dissemination of this information causes you serious harm related to your right to respect for your reputation or your privacy when certain legal conditions are met.
11. How Can You Exercise Your Rights?
To exercise any of your rights, please contact our Privacy Officer.
12. How Do I File a Complaint About Our Handling of Your Personal Information?
The CIQ takes requests, complaints, and comments on how we handle your personal information very seriously. We encourage you to contact our Privacy Officer to make any complaints or comments about our privacy practices.
Your complaint will be reviewed by our Privacy Officer, who will determine whether the handling of your personal information is consistent with our privacy program and any applicable legislation.
Our goal is to do our best to resolve your complaint. We aim to respond to every complaint politely, promptly, and ideally within a maximum of 30 days.
You can also file a complaint with the Commission d’accès à l’information du Québec using the form available on their website. However, we ask that you please contact our Privacy Officer first.
13. External Sites or Services
This Policy does not apply to third party websites, pages, or applications that may be accessed through our products and services and we are not responsible for such third-party services. If you follow such links, these third-party sites or services will likely have their own privacy policies that you will need to review before submitting your personal information.
14. How Do We Update this Policy?
We may change our Policy from time to time at our sole discretion.
Before coming into force, the proposed amendments will be published on the CIQ website, along with a notice of change. The proposed amendments will become effective on the date specified in the relevant notice of change.
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Summary of our Internal Policy on the Governance of Personal Information
The CIQ is committed to protecting your personal information throughout its life cycle in accordance with its privacy program and the requirements set out in applicable legislation.
In addition to our Privacy Policy, the CIQ has adopted a Privacy Governance Policy that sets out the principles governing the protection of personal information in its operations.
The objectives of our Governance are to:
ensure that your personal information is handled appropriately, securely, correctly, and transparently;
establish guidelines for the CIQ’s handling of personal information throughout its life cycle; and
define the roles and responsibilities of the Privacy Officer and our staff.
1. Roles and Responsibilities
Since respect for your personal information is everyone’s responsibility within the CIQ, our Privacy Officer is supported by a multidisciplinary team that includes members from each of our business units as well as external advisors.
Every member of our staff has a role to play so that we can act in accordance with our privacy program. In fact, each of our employees is asked to:
address any questions or comments to the Privacy Officer about how we handle or should handle your personal information;
participate in training and awareness activities on our commitment to privacy;
2. Guiding Principles of Corporate Governance
The CIQ recognizes the importance of protecting the confidentiality and security of the personal information it processes in the course of its activities and to raise awareness among its staff and partners about this issue.
The CIQ has developed guidelines on good practices and prohibited practices regarding how we can handle your personal information, such as:
We determine the purposes and objectives sought before collecting your personal information. Your personal information is then used only in accordance with these purposes and objectives.
If we identify new purposes, we will seek express consent to allow us to process your personal information in accordance with those new purposes, unless otherwise permitted by law;
- We seek to collect only the bare minimum in order to achieve the identified goals.
- We seek your consent when collecting your personal information, and for sensitive personal information, we seek your express consent;
- We post our Privacy Policy clearly and prominently when we collect your personal information through technology;
- We ensure that our technology products or services with privacy settings offer the highest level of privacy by default, without any intervention needed on your part;
- We do not use identification, location, or profiling technology without disclosing this practice and informing you how to activate such features;
- We ensure that your personal information is complete and up-to-date when we use it;
- We conduct privacy impact assessments when required by law, and when we consider that the handling of your personal information poses privacy risks;
- To the extent possible, we restrict access to your personal information only to those of our personnel and service providers who require access to your personal information in the course of their operations;
- When we make fully automated decisions using your personal information, we make sure we communicate the use of such technology to you and we have a process in place whereby you can submit your observations;
- We do not disclose your personal information to third parties without your consent, except as permitted by law.
3. Privacy Incident
The CIQ has a process in place to respond to and address confidentiality incidents.
Under this process, the CIQ must take reasonable measures to reduce the risk of serious harm and review its practices to prevent new confidentiality incidents of the same nature.
The CIQ documents all Privacy Incidents in its Privacy Incident Registry and will adapt its privacy program as required, following a Privacy Incident.
APPENDIX A
Policy on the Use of Cookies and Identification, Profiling and Location Technologies
Current version: 2023.09.22
This Policy regarding the use of cookie tools and cookies ("Cookie Policy") describes how and why Collège de l'immobilier du Québec ("we", "us", "our") uses cookies, Web beacons and other identification, profiling, and location technologies on our website, and in our electronic promotional communications.
Our Cookie Policy complements our Privacy Policy and should be read in conjunction with it.
1. What You Need to Know About Cookies and Web Beacons
1.1 What Are Cookies and Web Beacons?
Sign-in cookies are small text files that are downloaded to your device when you visit a website, use a mobile app, or download an email. Cookies allow a website to recognize a device and store information (such as your preferences, your use of the website) and read that information each time you access the website.
There are two types of cookies: (i) primary; and (ii) third-party. Essentially, the two types are technically identical and perform the same functions; the main difference is how they are created and then used.
Primary cookies. Primary cookies are created by the website you are visiting. A website can only access the cookies it has placed on your device, so, for example, cookies placed when you visit a search engine cannot be accessed by our websites.
Third-party cookies. Third-party cookies are created by a site other than the one you are visiting and are mainly used for profiling purposes and behavioral advertising. They also allow website owners to provide certain services. This type of cookie may be placed via what is known as a web beacon (more on this below). Since a website can only access the login cookies it has placed, we cannot access the third-party login cookies placed on any of our websites.
A web beacon, often referred to as a pixel invisible, is a transparent image, usually 1 pixel x 1 pixel, that is placed on a website or in an email to assess how a user interacts with specific content. Web beacons operate by sending information with the request to the third party’s web server when the request for the web beacons is made.
1.2 What Can You Do to Control the Cookies Placed on Your Computer?
We have deployed a cookie management solution to give you control over the cookies that remain on your device. With this tool, you have granular control over the categories of cookies you choose to accept.
In addition, and generally speaking, most browsers allow you to configure how cookies are accepted by your browser. Keep in mind that changing your cookie settings may prevent some websites from functioning properly. Please consult your browser developer's documentation to find out how to configure your cookie settings.
You can also use your browser's private or incognito mode. When using a website in private mode, all cookies are automatically deleted when all private mode tabs are closed. See your browser's help section for details of how private mode works.
Some recent browsers have built-in functionality to block or control the profiling content. We invite you to consult your browser's help section to see if such a feature is available.
Some browsers may have extensions created by third parties that can be used to manage and delete cookies. If you decide to use extensions, please pay particular attention to the extensions you install and the permissions they require.
You can also disable our use of cookies and similar technologies that allow us to profile and display advertising on third-party sites.
2. How Do We Use Cookies on Our Website?
2.1 Why Do We Use Cookies on Our Websites?
We use cookies and web beacons to:
- Analyze traffic on our website in general;
- Adjust website settings to suit your device;
- Display advertisements via services provided by third parties;
- Help us understand how people use our services and interact with our promotional material, so that we can improve them;
- Analyze your interaction with other pages and websites;
- Help us personalize our approach, responses and services by remembering your preferences; and
- Offer a live chat service to visitors to our website.
In addition, we use third-party connection cookies and web beacons such as Live Chat, Doubleclick, and Microsoft to analyze your web interactions to provide you with more targeted advertising and content.
These connection cookies and web markers allow us to post promotional material on non-CIQ websites.
We use web beacons in our promotional e-mails to collect statistics on the opening of e-mails and the interaction with the content of e-mails in order to analyze the performance of our promotional campaigns. We use your interaction with our promotional e-mails as an indicator of your interest in our products and services. We could adjust the way we contact you based on your interaction with our promotional emails.
2.2 What Types of Cookies Are Used on Our Websites?
On our websites, we use primary cookies and third-party cookies, some of which are critical to the proper operation of our website, while others are used for analytical and marketing purposes.
Cookies and web beacons will be stored on your device only if you have consented to their placement.
Necessary cookies. Necessary cookies are crucial to the website's basic functions and it will not function as intended without them. These cookies do not store any personally identifiable data.
Functional cookies. Functional cookies enable certain functionalities such as sharing website content on social media platforms, collecting comments, and other third-party functionalities.
Analytical cookies. Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on the number of visitors, the bounce rate, the source of traffic, etc.
Performance cookies. Performance cookies are used to understand and analyze the website’s key performance indicators, providing a better user experience for visitors.
Cookies for targeted advertising. Advertising cookies are used to provide visitors with personalized advertisements based on previously visited pages and to analyze the effectiveness of the advertising campaign.
Other cookies. Unclassified cookies are those that are currently being analyzed and have not yet been categorized.
3. Cookie Tools to Measure Interaction with Our Website and Promotional Material
3.1 What You Need to Know About Analytics
Cookie tools are used to collect, analyze, and measure web traffic and user visits to our websites in order to understand and optimize their use. Cookie tools work by collecting information about a visitor's interactions with one or more web pages. This information includes, for example, the visitor's IP address.
3.2 What Cookie Tools Do We Use on Our Websites?
3.2.1. Google Analytics
We use the Google Analytics tool offered by Google Inc. to collect information about how visitors use our websites. We use the reports compiled by Google Analytics to help us improve our websites.
Information is collected in an anonymous format and may include:
the country and city from which you access our websites;
demographic information based on information Google already has about you from your interactions with other websites;
the number of visitors to our websites and the pages visited.
Further information on the information made available to us by Google Analytics can be found on this page.
When we send your IP address to Google for use with Google Analytics, we anonymize it by truncating the last 3 digits. The Google Analytics Terms of Use prohibit us from sending personal information to Google through Google Analytics. Information about your interaction with our websites will be transferred to and stored by Google.
In addition, we also use the following services offered by Google Analytics:
Google Analytics Demographics and Interest Reporting;
Google Display Network Impression Reporting; and
Remarketing with Google Analytics.
For more information on how Google treats the personal information it may hold about you as a result of the Google Analytics services it provides to us, please see Google's Privacy Policy for this purpose available here.
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