Privacy Policy

Privacy and Personal Information Governance Policy of MSI Property Management

Thank you for visiting Le Rinfret’s website (hereinafter referred to as “Le Rinfret”) and for reviewing its Privacy Policy (hereinafter the “Policy”).

By browsing our website or using our systems or services, you acknowledge that you have read and understood this Policy and that you consent to the collection, use, disclosure, retention, and destruction of your data and Personal Information in accordance with this Policy, where applicable.

This Policy also aims to outline the roles and responsibilities of MSI staff members regarding the collection, use, and destruction of your Personal Information.

If you have any questions regarding your Personal Information and these questions remain after reading the Policy, you may contact the Personal Information Protection Officer (hereinafter the “Officer”), Simon Lessard, at the following email address: info@lerinfret.com.

Le Rinfret may, at its discretion, modify this Policy from time to time. If any changes are made, you will be informed, as applicable. Once informed, your continued use of the website after the modified Policy comes into effect constitutes your consent to the updated version.

1. Definitions

In this Policy, Le Rinfret refers to:

i. “Governmental Authority(ies)” means a) any government, ministry, court, tribunal, arbitral body, commission, agency, board, or office at the multinational, federal, provincial, state, regional, municipal, or local level; b) any subdivision, agent, commission, or authority of any of the foregoing entities; c) any quasi-governmental or private body exercising regulatory, administrative, expropriation authority, or any tax authority acting under or on behalf of any of the aforementioned authorities, including any private body mandated to provide public services;

ii. “Personal Information” means any information about an individual that allows, directly or indirectly, their identification;

iii. “Officer” refers to the person appointed by Le Rinfret to oversee the protection of Personal Information and ensure compliance with the Law. The Officer may be contacted by email at: info@msimmobiliers.com;

iv. “Law” refers to the Act Respecting the Protection of Personal Information in the Private Sector, Chapter P-39.1, including any subsequent amendments or modifications to said law.

2. Objectives of the Privacy Policy

Respect for privacy and the protection of Personal Information are essential to us. Through this Policy, we aim to protect such information in accordance with applicable laws.

To ensure such protection, Le Rinfret commits to collecting, using, retaining, and disclosing information that can directly or indirectly identify an individual only when consent has been given, unless otherwise permitted or required by law, in which case your consent will not be necessary.

The purpose of this Policy is to inform users of the reasons for and the methods by which Le Rinfret, or any person acting on its behalf, collects, uses, retains, and discloses their Personal Information. It is written in clear language to ensure informed consent from users.

Whenever possible, Le Rinfret commits to anonymizing and/or aggregating your Personal Information so that it no longer identifies any individual.

3. Effective Date

This Policy is effective as of June 1, 2025.

4. Terms of Consent Collection

We are committed to obtaining consent before collecting an individual’s Personal Information. Consent may be explicit or implicit and may be provided directly by the individual or by their authorized representative.

Wherever possible, we prioritize obtaining explicit consent, whether verbally, electronically, or in writing. However, implicit consent may be reasonably inferred from a person’s actions or inaction. For example, providing a name and address to receive a publication or providing a name and phone number to receive a response to an inquiry is considered implicit consent to the collection of information containing Personal Information. To determine the appropriate type of consent, we consider the sensitivity of the Personal Information involved, the purposes for which it is collected, and the reasonable expectations of someone in a similar situation.

If we intend to use Personal Information for a purpose not outlined in this Policy or for which you have not already consented, we will obtain your consent.

By submitting your Personal Information to Le Rinfret, you consent to the collection, use, disclosure, retention, and destruction of your Personal Information by Le Rinfret in accordance with this Policy.

5. Purposes for Collecting Personal Information

Personal Information is collected in accordance with the purposes and objectives set out in this Policy. Le Rinfret collects your Personal Information for the following purposes:

i. To provide products and services: Our services include, but are not limited to, apartment rentals, residential property management, and various tenant services for residential buildings. We use the necessary Personal Information to deliver our services and fulfill our contractual obligations.

ii. To assess your rental application: We collect your Personal Information when you complete an apartment rental application on our website in order to process and evaluate your application.

iii. To ensure and improve our products and services: Personal Information collected during your interactions with our services may be used to analyze and enhance the performance of our products and services.

iv. To develop new products and services: Collected Personal Information may be used in research and development to offer new products and services to our users, including through marketing messages and advertisements.

v. To offer personalized products and services: The collection and analysis of Personal Information generated by your interactions with our services help us design and deliver relevant products and services to better meet your expectations, particularly by implementing accommodations for clients who need them.

vi. To evaluate product and service performance: Personal Information is collected to obtain feedback on the benefits and drawbacks of our offerings so we can evaluate and address any issues as needed, including through surveys. This allows us to ensure the quality of our products and services and to support risk management.

vii. To protect our users’ privacy: The data collected allows us to verify the identity of and protect the privacy of individuals who contact us by phone, electronically, or otherwise.

viii. To comply with legal obligations: Personal Information may be used to fulfill obligations under applicable laws, regulations, or international treaties.

ix. To send you additional information or promotional material: Personal Information may be used to send you surveys, contests, promotions, special offers, etc. You are free to withdraw your consent at any time.

Le Rinfret places the highest importance on the security of your Personal Information and is committed to processing it in accordance with industry standards, solely for the purposes for which it was collected, as outlined in this Policy or in a specific notice to that effect.

6. Personal Information Collected

Le Rinfret may collect Personal Information in various forms, but only through lawful means and strictly for necessary purposes disclosed to you, as described in this Policy or when permitted or required by law.

The nature and sensitivity of the Personal Information collected may vary depending on the context of your interactions with Le Rinfret. Therefore, we prioritize informing you about the type of Personal Information we use.

7. Right of Access and Rectification Provided by Law

Le Rinfret ensures that all Personal Information in its possession is as accurate, current, and complete as necessary for the purposes for which it is used.

Le Rinfret is committed, upon your request, to confirming the existence of your Personal Information, granting you access, and allowing you to obtain a copy in a structured and commonly used technological format.

You have the right to request the correction of any inaccurate, incomplete, or equivocal Personal Information, or the deletion of any Personal Information whose collection, disclosure, or retention is not authorized by law.

You also have the right to request that the dissemination of your Personal Information be stopped when such dissemination violates the law, a court order, or if the following conditions are met: (i) the dissemination causes you serious harm with respect to your reputation or privacy, (ii) the harm clearly outweighs the public’s interest in knowing the information or any individual’s right to free expression, and (iii) the requested cessation of dissemination does not exceed what is necessary to prevent the continuation of the harm.

In all cases, your request for access or rectification must be made in writing to the Privacy Officer, accompanied by proof of your identity as the person concerned by the Personal Information. The Privacy Officer is committed to responding to your written request within 30 days of receipt.

Access to your Personal Information is free of charge, except when reasonable fees may be charged for transcribing, reproducing, or transmitting the information.

If your request is denied, the Privacy Officer will provide reasons for the refusal and indicate the legal provision on which the refusal is based, the available recourses, and the applicable timeframe. The Privacy Officer is also committed to providing the necessary assistance to help you understand the refusal.

The Privacy Officer undertakes to provide a copy of any corrected or added Personal Information free of charge, or, as the case may be, a certificate of deletion of the Personal Information. The Officer also commits to notifying, without delay, any person who received the information within the six months preceding the individual’s request, including, where applicable, the person from whom they received it.

The Privacy Officer will retain the Personal Information subject to your access or rectification request for the time necessary to allow you to exhaust your legal recourses.

If your request involves data found on third-party web pages or platforms, please contact those third parties directly.

8. Right to Withdraw Your Consent

You have the right to withdraw your consent at any time regarding the disclosure, use, and retention of your Personal Information by Le Rinfret. To do so, please contact the Privacy Officer using the contact information provided in this Policy.

9. Disclosure of Your Personal Information to Third Parties

We do not share your Personal Information with companies, organizations, or individuals outside of Le Rinfret, except with our authorized service providers and business partners who need access to the information for the purposes described in this Policy and within its limits, and in the following cases:

i. With your consent.

ii. Our clients who own residential or rental properties, when you submit a rental application through the website.

iii. For storage on cloud servers, in which case Personal Information may pass through third-party jurisdictions. In such cases, Le Rinfret will take steps to ensure the security of your Personal Information.

iv. For external processing needs: We transmit Personal Information to other companies or trusted individuals that process it on our behalf, according to our instructions, in compliance with this Policy, with a level of data security at least equivalent to ours, and in accordance with all appropriate security and confidentiality measures.

v. For legal reasons: We may disclose Personal Information outside our organization if access to it is necessary to comply with applicable laws and regulations.
Your Personal Information may be disclosed outside of Quebec. If so, Le Rinfret commits to conducting a privacy impact assessment and will only disclose the information if the assessment shows that the disclosed Personal Information will receive adequate protection. In such cases, the disclosure will be governed by a written agreement that reflects the assessment results and any arrangements made to mitigate identified risks.

Le Rinfret commits not to sell or rent your Personal Information to any third party.

10. Automatically Collected Personal Information – Cookies

Le Rinfret collects Personal Information provided by cookies. Cookies are data files commonly stored on your device when using websites and online services. They are used for efficient website operation and may provide information and assist in service personalization.

You may choose to accept or refuse cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to refuse cookies if you prefer. If you wish to disable cookies, this can typically be done in your browser’s preferences menu. You may also use private browsing when accessing the website. However, please note that refusing cookies may affect your experience on the website.

Please note that our website may contain links or references to third-party websites. This Policy no longer applies once you leave our website, and MSI is not responsible for the collection or processing of Personal Information by these third parties or external sources.

11. Retention of Personal Information

Le Rinfret retains collected data for various periods, depending on its nature and usefulness in providing our products and services. During the retention period, Le Rinfret takes physical and technical measures to secure data containing Personal Information.

The main locations where Personal Information is stored include the cities in which Le Rinfret has offices or facilities and in cities where Google Drive has servers that store Personal Information collected and retained by Le Rinfret.

Personal Information may be stored outside the country in which you reside, if a third-party provider or another entity to whom we disclose Personal Information under this Policy is located abroad. In such cases, Personal Information may be subject to the local laws of the countries or territories where it is collected, used, disclosed, or stored, and governmental or law enforcement authorities may have access to it.

Once the retention period has expired, Personal Information is destroyed. Only anonymized or depersonalized statistical data or reports may be retained for extended periods.

12. Security Measures

Le Rinfret implements necessary security measures, including physical, electronic, technological, and organizational safeguards, to protect your Personal Information.

Le Rinfret also maintains various internal protocols related to the protection of Personal Information, including this Policy and access controls based on each employee’s role in the company.

13. Handling Complaints

For any complaints regarding the protection of your Personal Information or its use by Le Rinfret, please contact the Privacy Officer at the email address listed on the first page of this Policy. The Officer will respond to your complaint via email as soon as possible.

14. Roles and Responsibilities of Staff Members

Le Rinfret implements access controls to ensure that only employees authorized by Le Rinfret can access your Personal Information. These authorized employees must access or know your Personal Information in order for Le Rinfret to provide its services.

The Privacy Officer is responsible for ensuring compliance with and implementation of this Policy. The Officer also ensures that all authorized employees of Le Rinfret are aware of the Policy and use Personal Information in accordance with its provisions.

15. Personal Information of Minors

Le Rinfret does not collect Personal Information from minors under the age of 14, except with written consent from a parent or legal guardian.

16. Precedence

In case of any conflict between this Policy and applicable legislation, the provisions of the law shall prevail.

Last update of the Policy: June 1, 2025