Privacy Policy

Société Immobilière BG is committed to protecting the personal information in its custody. Personal information is confidential except where disclosure is authorized or required by law. Any person who has access to personal information held by Société Immobilière BG must take the necessary measures to ensure its protection and confidentiality. This Policy and its related procedures establish the measures designed to reduce the risk of privacy incidents, manage such incidents when they occur, and prevent similar incidents from happening in the future.

Collection of Personal Information in Connection with Our Business Relationship and Services

In the course of providing services to its clients or for marketing purposes, Société Immobilière BG collects certain information that may include personal information. This information may be obtained through voluntary disclosure by the individuals concerned during communications with us, or through technological applications such as forms, emails, applications or other means. This information is used to sell products, provide services, or offer such products and services.

By providing this information to Société Immobilière BG, or by using the technological tools available on our website, social media platforms, applications or services offered by Société Immobilière BG, you consent to the collection and use of this information.

Société Immobilière BG makes every reasonable effort, and only when required for its activities, to share or transfer this information only to reliable partners for whom it has verified that satisfactory security and confidentiality measures are in place. Whenever possible, all information is stored on servers located in Quebec or, at minimum, in Canada.

Every individual has the right to obtain details about the information held about them and to request corrections when necessary.

Retention and Destruction of Information

Upon request, individuals may obtain information regarding how their personal information is stored, who has access to it, how it is used, and the retention period after which the information will be destroyed.

Privacy Incident and Procedure

The following procedure sets out the steps to be taken when Société Immobilière BG has reasonable grounds to believe that a privacy incident has occurred, or when such an incident is confirmed, involving personal information it holds, in accordance with the Act respecting the protection of personal information in the private sector, chapter P-39.1, and the Regulation respecting confidentiality incidents.

Definitions

The definitions to be considered for the application of this procedure, which may be supplemented by any other regulation, policy, directive or procedure referring to them, are as follows:

Privacy Incident: Unauthorized access to, use or disclosure of personal information not authorized by law, as well as the loss of personal information or any other breach of its protection.

Examples include:

A hacker gaining unauthorized access to a computer system;
A person using personal information from a database they have access to in the course of their duties for the purpose of identity theft;
Sensitive information being accidentally disclosed to the wrong person;
A person losing or having documents containing personal information stolen;
A person gaining unauthorized access to a database containing personal information in order to alter it.

Personal Information: Any information concerning a natural person that allows that person to be identified. A person’s name, taken alone, is not considered personal information. However, when that name is associated or combined with another piece of information relating to the same person, it becomes personal information.

Examples of personal information include:

A person’s name and date of birth;
Social insurance number;
Credit card number;
Health insurance number;
Medical or financial information;
A person’s name and personal phone number;
A person’s name and home address.

Sensitive Personal Information: Personal information is considered sensitive when, by its nature, particularly if it is medical, biometric or otherwise intimate, or because of the context in which it is used or disclosed, it gives rise to a high level of reasonable expectation of privacy.

This may include, for example, medical, biometric, genetic or financial information, as well as information relating to ethnic origin, political opinions, sexual orientation, religious beliefs or other intimate personal matters.

Protection of Personal Information

Société Immobilière BG implements appropriate and reasonable security measures to protect personal information against loss or theft, as well as against unauthorized access, disclosure, copying, use or modification not authorized by law. Access to personal information is restricted to employees and authorized personnel who require such access to perform their duties.

Employees of Société Immobilière BG, or persons working on its behalf, must notably:

Make reasonable efforts to minimize the risk of unintentional disclosure of personal information;
Take special precautions to ensure that personal information is not monitored, overheard, accessed or lost when working in locations other than Société Immobilière BG’s offices;
Take reasonable measures to protect personal information when moving it from one location to another.

Reporting a Privacy Incident

Any person to whom Société Immobilière BG discloses personal information, including colleagues, suppliers, partners, experts and subcontractors, must report any privacy incident when they have reasonable grounds to believe that such an incident involving personal information held by Société Immobilière BG has occurred. This report must be made without delay to the person responsible for the protection of personal information.

Any employee of Société Immobilière BG who has reasonable grounds to believe that a privacy incident involving personal information held by Société Immobilière BG has occurred must also notify their immediate supervisor.

Any serious incident involving a significant number of individuals, or involving sensitive information that could cause significant harm, must be reported to the Commission d’accès à l’information as soon as Société Immobilière BG becomes aware of it.

Person Responsible for Personal Information: Roles and Responsibilities

The person responsible for the protection of personal information at Société Immobilière BG can be reached using the following contact information:

Helen Beaulac
Email: info@sibg.ca
Phone: 450-359-7776

Their role includes:

Contributing to the implementation of the privacy incident management process;
Keeping the privacy incident register up to date, documenting incidents and ensuring the required follow-up on their handling;
Keeping the complaints register up to date, documenting complaints and ensuring the required follow-up on their handling;
Contributing to privacy incident risk analyses in order to identify threats and vulnerabilities and implement appropriate solutions.

In the event of a privacy incident, the person responsible for the protection of personal information takes charge of managing the incident and works with any other relevant person depending on the nature of the incident.

In this capacity, they:

Assess the risk of harm and determine its level of severity. This assessment takes into account, in particular, the sensitivity of the information concerned, the anticipated consequences of its use and the likelihood that it will be used for harmful purposes;
Promptly notify the person whose personal information is affected by the incident when there is a risk of serious harm, unless doing so could hinder an investigation conducted by a person or organization legally responsible for preventing, detecting or prosecuting crimes or offences.

This notice must include the following information:

A description of the personal information affected by the incident or, if this information is not known, the reason why such a description cannot be provided;
A brief description of the circumstances of the incident;
The date or period during which the incident occurred or, if unknown, an approximate period;
A brief description of the measures the organization has taken or intends to take following the incident in order to reduce the risk of harm;
The measures the organization recommends that the affected person take in order to reduce the risk of harm or mitigate such harm;
Contact information allowing the affected person to obtain further information about the incident.

Notify, where applicable, any person or organization that may help reduce the risk, while disclosing only the personal information necessary for that purpose;
Promptly notify the Commission d’accès à l’information in writing of the privacy incident when it presents a risk of serious harm.

The notice to the Commission d’accès à l’information must include the following information:

The name of the business, Société Immobilière BG, and the Quebec Enterprise Number assigned to it under the Act respecting the legal publicity of enterprises;
The name and contact information of the person to contact within Société Immobilière BG regarding the incident;
A description of the personal information affected by the incident or, if this information is not known, the reason why such a description cannot be provided;
A brief description of the circumstances of the incident and, if known, its cause;
The date or period during which the incident occurred or, if unknown, an approximate period;
The date or period during which Société Immobilière BG became aware of the incident;
The number of individuals affected by the incident and, among them, the number of individuals residing in Quebec, or an approximate number if these numbers are not known;
A description of the factors that led Société Immobilière BG to conclude that there is a risk of serious harm to the affected individuals, such as the sensitivity of the personal information involved, possible malicious uses of the information, anticipated consequences of its use and the likelihood that it will be used for harmful purposes;
The measures Société Immobilière BG has taken or intends to take to notify the persons whose personal information is affected by the incident, as well as the date on which the persons were notified or the expected notification timeframe;
The measures Société Immobilière BG has taken or intends to take following the incident, including measures intended to reduce the risk of harm, mitigate such harm and prevent similar incidents from occurring in the future, as well as the timeframe for implementing those measures;
Where applicable, a statement indicating that a person or organization outside Quebec with responsibilities similar to those of the Commission d’accès à l’information regarding the oversight of personal information protection has been notified of the incident.

Promptly notify Société Immobilière BG’s insurers, where applicable;
Record the privacy incident in the register provided for this purpose;
Provide a copy of this register to the Commission d’accès à l’information upon request.

Privacy Incident Register

Société Immobilière BG is required to maintain a register of privacy incidents.

Retention Period for Information Contained in the Register

The information contained in the register must be kept up to date and retained for the longer of the following two periods: a minimum period of five years after the date on which Société Immobilière BG became aware of the incident, or the period required by any government authority or applicable law or regulation.

Complaints Register and Handling of Complaints

Société Immobilière BG is required to maintain a complaints register and record the handling of complaints.

Retention Period for Information Contained in the Register

Effective Date

This Policy and its procedures come into effect on September 22, 2023.

Contact Us

If you have any questions about our privacy policy, wish to exercise your rights described above, file a complaint or update your personal information, please contact the person responsible for the protection of personal information as follows:

By email: info@sibg.ca

By mail: Société Immobilière BG, Attn: Person Responsible for the Protection of Personal Information, 420 boul. St-Luc, Saint-Jean-sur-Richelieu, QC J2W 2A3.

We will make every reasonable effort to process your request promptly.

Last updated: June 4, 2026