Web Privacy Policy

Web Privacy Policy

Purpose

This privacy policy of Cogir Real Estate Limited Partnership and all affiliated entities and subsidiaries under its control and part of its group (“Cogir Real Estate“) (the “Privacy Policy” or the “Policy“) contains important information. Its purpose is to inform you about our governance rules, principles, and practices regarding the protection of Personal Information (as defined below), as well as your rights and obligations concerning them.

Scope and Application

Cogir Real Estate and its affiliated companies, including Société de Gestion Cogir s.e.n.c. and Cogir Canadian RH Management LP (collectively “Cogir,” “we,” “our,” and “us“), are concerned about the protection of Personal Information and the privacy of each client or any person who visits our website www.cogir.net and its subdomains (the “Site(s)” or the “Website(s)“), subscribes to our websites, requests information, or communicates with us through our web portals (collectively “you,” “your,” and “yours“).

“Personal Information” is information about a natural person that alone or in combination with other information could be used to identify a person. Personal Information includes, without limitation: the name, residential address, email address, phone number, date of birth (or age), health information of a person wishing to become or who is a tenant of one of our private retirement residences; the name, residential address, email address, phone number of a person wishing to become or who is a tenant of a residential multi-tenant building; booking details, and information requested at one of Cogir’s restaurants, payment processing information, and credit card numbers. It may also include, without limitation, unique digital identifiers such as a computer’s IP address or unique mobile device identifiers, as well as personal preferences, purchase habits and history, credit data, geolocation data, contact information or demographic information, survey data, information on products and services purchased, consumed, or offered, and data on website traffic and visits to the extent that these data are associated with a person’s Personal Information.

Personal Information does not include personal information that has been anonymized by the removal of identifying details so that the data cannot be associated with a specific person.

This Policy applies to Cogir’s activities concerning Personal Information collected, stored, used, or communicated by Cogir or by its representatives, agents, subcontractors, suppliers, and network members (collectively “Partners“) through which goods and services are provided on behalf of Cogir or who occasionally participate in programs, promotions, or other joint arrangements, as well as any other authorized third party who may collect, store, use, or communicate Personal Information about clients to help us better serve them. This Policy applies to the management of Personal Information regardless of its form, whether verbal, written, electronic, or other.

The application of this Privacy Policy is governed by the requirements of the Act respecting the protection of personal information in the private sector (Québec) and the Freedom of Information and Protection of Privacy Act (Ontario) and their associated regulations, as well as other applicable provincial legislative provisions and regulations.

Our Approach and Your Consent

We adopt a consent-based approach to collecting, storing, using, and disclosing Personal Information. When you provide your Personal Information to Cogir, you consent to the collection, holding, use, and disclosure of your Personal Information in accordance with this Policy and as permitted or required by law. Consent may be obtained in person, by phone, by email, by signature, or by other legal means. In certain circumstances, consent is implied within the context of the relationship or individual conduct, meaning your permission is presumed based on your action or inaction at the time of collection, use, or sharing of your Personal Information. Your consent can also be given through an authorized representative, such as a lawyer, special agent, or other designated person. For Sensitive Personal Information (e.g., health information), consent must be explicitly given. In certain circumstances, your Personal Information may be collected, stored, used, or disclosed without your consent in emergencies, where the law permits (e.g., to detect or prevent fraud or illegal activity), or when necessary to comply with a court order or similar obligation. Unless consent is not legally required, we determine the purposes for collecting your Personal Information before or at the time of collection. We must ensure that you consent to Cogir collecting, using, and disclosing your Personal Information in accordance with this Policy as it may be updated or modified from time to time. For the purposes hereof, the term “use” includes processing, handling, and managing Personal Information by Cogir.

A client may withdraw their consent at any time, subject to legal or contractual restrictions, upon providing reasonable notice to Cogir. Please refer to the “Your Rights and Options” section.

Purposes and Objectives of Collecting Personal Information

Cogir collects, stores, uses, and discloses Personal Information to manage and carry out its activities, ensure the provision of required goods and services, administer its programs, and for the following purposes or objectives:

Manage and maintain your records and accounts created for our various products, services, and programs, including:

Managing your real estate assets and investments;

Managing and executing your real estate development and construction projects;

Managing private retirement residences: processing housing applications and creating a file for each resident; maintaining the housing register (including its administration), activities, and expenses attributed to residents; managing healthcare services received by each resident, including interactions with healthcare providers; contacting the authorized representative, substitute decision-maker, or family of a resident; and keeping health records required by law;

Managing residential multi-tenant buildings: processing housing applications and creating a file for each tenant; maintaining the housing register (including its administration), activities, and expenses attributed to tenants;

Managing restaurants: processing reservations at Cogir Restaurants;

Offer and provide the products and services required by you or likely to interest you;

Process information related to your purchases and service requests and handle payments;

Manage and administer our programs;

Manage risks, security, regulatory compliance, and corporate governance;

Communicate with you and respond to your questions, requests, comments, or complaints;

Verify the identity of clients, when required, for transactions, and to reduce fraud or errors in processing transactions;

Determine your eligibility for our products and services and verify compliance with applicable conditions;

Invite you to events, organize promotional activities, and contests;

Conduct studies, surveys, analysis, targeting, segmentation, and statistics to establish pricing, and understand and analyze clients’ interests, needs, and preferences;

Ensure the quality of products and services, conduct internal audits, or carry out continuous improvement activities;

Receive and process job applications in accordance with the terms of the “Employment Section”;

Develop, design, improve, market, and recommend products and services to meet the needs and interests of current and potential clients;

Recognize you on our Websites, social media platforms, mobile applications, and identify your preferences; analyze their use, improve, and personalize their content;

For analysis and marketing targeting purposes, including sending and displaying personalized advertising, as detailed in the “Digital Marketing” section;

Ensure the safety and protection of people and property in our establishments;

Detect fraud attempts and prevent and protect against fraud;

For investigation and law enforcement purposes;

Comply with applicable laws and regulatory requirements;

Communicate with you about any changes to our programs, their operation, and our policies, including this Policy.

We do not collect Personal Information for purposes or objectives other than those indicated in this Policy unless we obtain your additional consent, or the law requires or permits it.

Means and Methods of Collecting Personal Information

Cogir limits the collection of personal information to what is reasonably necessary to achieve the purposes for which it was collected. Cogir may collect, use, and disclose different types of personal information grouped as follows:

“Browsing activity” on the website, such as pages and offers viewed, opt-out preferences, returned emails, clicks, social media content, and IP addresses;

“Contact data,” such as billing address, email address, and phone numbers;

“Financial data,” including bank account and payment card details;

“Identity data,” such as your name, marital status, date of birth, gender, sexual orientation, racial or ethnic origin, and religious beliefs;

“Marketing and communication data,” including your preferences for receiving marketing communications from us and our related third parties, as well as your communication preferences;

“Health personal information,” including all information related to health and healthcare, such as medical history, healthcare programs and services, healthcare providers, special agents, health insurance card number, and other personal identification numbers;

“Preference data,” including information on your accommodation, food, and service preferences to enable us to provide care in a manner that best suits your needs;

“Recruitment data,” including information contained in resumes and job applications for recruitment purposes, such as previous work experience, education, training, languages spoken, etc.;

“Security data,” including identity and contact records (including entry and exit times from Cogir premises), videos, and surveillance footage collected on or near Cogir properties;

“Operational data,” including details of payments you make and receive and other details of the services we have provided to you.

We collect Personal Information from clients in various ways, in verbal, written, or electronic forms via our Websites, mobile application, by phone, mail, email, SMS, chat, through our authorized Partners, or otherwise, including but not limited to when clients:

Make a payment, service request, or information request;

Participate in our programs, events, activities, or promotional offers;

Subscribe to or agree to receive our [newsletters], promotional emails, and other communications about our products, services, promotions, or events;

Visit our Websites or social media platforms [and use our mobile applications] or interact with emails and online advertisements. More details are provided in the “Digital Marketing” section;

Contact, interact with, or communicate with one of our representatives to make a service request, comment, question, or complaint. [In this regard, as some of our services are provided by phone, calls may be recorded to ensure the quality of our services and to protect both parties in case of disagreement];

Participate in one of our surveys or any other customer study;

Submit a job application;

Visit one of our establishments equipped with video surveillance to ensure the safety of people, property, and infrastructure.

Disclosure of Personal Information

Access to Personal Information is limited to specific groups of Cogir employees and Partners authorized by Cogir who need this Personal Information as part of their duties.

We do not disclose Personal Information for purposes or objectives other than those for which it was collected, as stated herein, unless you give us your consent or the law permits it. Therefore, as stated above, we may disclose Personal Information to:

Any entity in our group or our affiliated companies;

Our Partners whose products and services have been retained according to our instructions to perform certain functions on our behalf. We limit the disclosure of your Personal Information to these third parties only to what is necessary for the functions for which they are retained or for the delivery of products and services for which these third parties are engaged. We take contractual and other reasonable measures to offer a level of protection comparable to our own while processing the information by these third parties. Some of these third parties may be located outside of the provinces of Quebec and Ontario or in other countries, and consequently, your Personal Information may be processed, accessed, or stored outside of Quebec and Ontario. These third parties may disclose information in response to valid requests from governments, regulatory bodies, courts, and law enforcement authorities in these jurisdictions following applicable legislation in these jurisdictions or countries.

We may also disclose or transfer your Personal Information to the extent reasonably necessary in the context of financing, sale, merger, reorganization, or consolidation of all or part of a business. In such a case, the beneficiary parties must contractually commit to ensuring the confidentiality of the Personal Information and using it only for the purposes of the transaction or the intended transaction. If a business transaction is completed, the assignees or successors of the business or its assets may use and disclose your Personal Information only for the purposes and objectives stated in this Policy unless they obtain your consent for other uses.

We are also authorized to disclose your Personal Information to third parties as required or permitted by law, including in the following situations:

To government agencies and law enforcement agencies under a warrant, order, or legal provision;

In connection with any ongoing or potential legal proceedings involving us or you;

In establishing, exercising, or defending our rights, or a collection procedure (including providing information to third parties for fraud prevention, money laundering, and credit risk reduction purposes) as permitted by law.

We reserve the right to report illegal or dishonest activities carried out by website users or clients, which may require disclosing Personal Information about that person to fraud management and law enforcement authorities.

From time to time, Cogir may also disclose aggregated, depersonalized, or anonymized data to third parties that do not contain Personal Information or other information about identifiable individuals.

We do not transmit your Personal Information to a third-party promotional partner unless you have consented to its disclosure to them for a specific purpose. We do not sell our client lists.

Retention of Personal Information

We retain Personal Information only for the period necessary in accordance with legal requirements, or useful for the determined purposes. Protection of Personal Information is ensured by implementing physical, organizational, and security measures adapted to the nature of the Personal Information concerned.

We establish retention criteria based on the type of Personal Information collected. We set control measures for retention schedules and practices concerning the retention and destruction of Personal Information and records when they are no longer necessary for the determined purposes of their collection and administration or are no longer required by law. Please note that in some cases, we may retain some of your Personal Information for a reasonable period for legal, administrative, governance, or compliance purposes, and some records containing Personal Information may be depersonalized and thus retained.

As indicated in the “Your Rights and Options” section, you can request the deletion of your Personal Information. Thus, once the objectives and purposes are achieved, and the Personal Information becomes unnecessary, or if the concerned person requests its deletion, we destroy or ensure its anonymization, unless the law permits otherwise.

Security

We take reasonable measures meeting industry standards to protect Personal Information and use security measures corresponding to the particular sensitivity of that information. Additionally, we have implemented and maintain technological, physical, and contractual security measures designed to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, using protections adapted to the sensitivity of the Personal Information.

All individuals authorized by Cogir who have access to Personal Information must respect its confidentiality.

We understand the importance of protecting Personal Information and use Internet security protocols to protect information collected through the Internet. However, you must keep in mind that the Internet is not a secure means of communication. Therefore, we make no representations and offer no guarantees regarding the absolute security of Personal Information provided to us through the Internet. Considering the above, you acknowledge that you provide your Personal Information with full knowledge of these risks.

Links or Redirection to Third-Party Sites or Applications

Our Websites and applications may contain links or redirection to other websites of Partners, advertisers, and other third-party companies. By clicking on these links or navigating the sections identified below, you leave Cogir’s Websites. We do not control the operation of these websites or how your Personal Information and data are collected, stored, used, or communicated. Redirection to third-party websites or listing links to third-party websites on Cogir’s Websites does not engage our responsibility. We are not responsible for the privacy practices or the content of other websites other than our own Websites. You must consult the privacy policies specific to these third-party websites and mobile applications before choosing to provide them with your Personal Information. Therefore, when products and services are offered by an entity other than Cogir, it is your responsibility to review that entity’s privacy policy before choosing to provide them with your Personal Information. Although goods or services are offered by an entity other than Cogir, some information you provide may also be transmitted to Cogir for the purpose of validating your eligibility for these goods or services, promotions, and in some cases for the purpose of retaining and processing information. Please note that certain specific rules apply to the collection, storage, use, and communication of your Personal Information in the context of certain services offered by our Partners. You have an obligation to inquire with these Partners about how they handle your Personal Information.

As of the latest version of this Policy, the following websites are managed by Cogir:

Sites Managed by Cogir

Important Note: When you visit the sections or topics mentioned below, you leave Cogir’s Websites for third-party websites. Therefore, please consult the terms of use and privacy policies applicable to these websites.

Sites Managed by Third Parties

Sections or Topics		Sites and Providers
Cogir Foundation	https://realestate.cogir.net/cogir-foundation/
Activities Newsletter	https://realestate.cogir.net/news/

Data Collected During the Use of Mobile Applications

Some of our mobile applications offer membership, geolocation, and notification services. Geolocation services provide content and services based on location, promotional offers, and other personalized content. Notifications may include reminders or details about promotions or local events. If you consent to location services, Cogir may collect information about your location. You can disable location services or notifications on most mobile devices, but some features of our applications may no longer function.

Information Provided Through Social Media

Cogir uses social media (Facebook, Instagram, LinkedIn, YouTube, Twitter, TikTok) as an extension of its internet presence. Corporate social media accounts are public. Users who choose to interact through social media should read the terms of use and privacy policies of these platforms to be informed about how these platforms use Personal Information. Given that any content posted on one of our social media platforms can be seen by the public, please note it is best to exercise caution when providing or communicating certain Personal Information.

Cogir may offer you access to content through social media platforms or participate in exchange forums, in which case, depending on your account settings, you may allow us to access certain Personal Information associated with your social media account. Cogir may also collect the date and time you visited the page for sharing purposes. Cogir may use this information to validate your identity and personalize your experience. We may also use services provided by social media platforms to display targeted ads to users of these platforms. More details are provided in the “Interest-Based Advertising and Audience Creation“ section.

Employment Section

The Personal Information you provide during the recruitment process will be used and retained to evaluate your qualifications for the position and validate them. Access to this Personal Information will be limited to Cogir staff and its authorized representatives who need access to it. This Personal Information may also be used to see if your profile fits any other position offered within the company. Cogir ensures that Personal Information collected remains confidential and is used only in the context of a selection process and, if applicable, hiring. If you submit a job application to Cogir through a recruitment website, you will need to create an account on a third-party provider’s platform to facilitate the processing of your job application and give your consent to the collection of your Personal Information. You will be bound by the third-party platform’s privacy policy and terms of use, as well as Cogir’s Privacy Policy when processing your Personal Information for recruitment purposes. Following a hire, employee data is retained and used for managing the employee file throughout its lifecycle. You can consult or modify your Personal Information at any time by contacting Cogir’s human resources department.

Digital Marketing

Email Communications and Targeted Advertising

Cogir is committed to responsibly managing email addresses and using them in accordance with the law. Based on the express consent you have given us or implied consent based on an existing business relationship, Cogir may send you promotional messages by email unless otherwise indicated by you.

To better understand and improve the effectiveness of our email marketing efforts, when we send you an email for marketing purposes, Cogir collects information to measure the open rate and to know if you clicked on links contained therein and, if applicable, which pages you visited on our website.

Cogir may also use your email address for digital advertising targeting and audience creation on the web and social media, details of which use are provided in the “Interest-Based Advertising and Audience Creation” section.

You can remove your name from our mailing list at any time by following the unsubscribe link displayed at the bottom of all Cogir emails. Cogir will then remove your name from our electronic mailing lists as soon as possible upon receipt of your written request.

Cookies and Tracking Technologies

When you visit our Websites and social media platforms or use one of our mobile applications, we may use certain automated tools such as: “Cookies” (as defined in the definition section), “Tracking Codes and Pixels” (as defined in the definition section), browser analysis tools, server logs, and web beacons to provide you with a more personalized browsing experience, better understand your needs, track trends, personalize our marketing initiatives, and provide you with the most relevant content. We may also use third-party services to collect and analyze information about areas visited on the Websites (such as the most viewed pages, time spent, search terms, and other engagement data) to evaluate and improve user experience and website convenience.

In general, you can visit our Website without disclosing your identity or submitting Personal Information. However, through the automated means mentioned above and other technologies, we collect IP addresses (Internet Protocol) of all visitors to our Website and other related information such as page requests, browser type, operating system, and average time spent on our Website. We collect similar information about the use of our mobile applications. We use this information to understand user activity on our Website, provide tailored content, and monitor and improve our Website and mobile applications.

You can configure your web browser to notify you when you receive a Cookie or choose not to accept certain Cookies (these options are usually found in your browser’s privacy settings). You do not have to enable Cookies to visit our Website; however, if you choose not to accept them, you may not be able to take advantage of all the features of the Site. Your withdrawal only applies to a specific web browser you used; therefore, you must repeat the operation for each web browser and device you use. Please refer to your browser’s instructions for more information about Cookies.

Interest-Based Advertising and Audience Creation

General

Our goal is to ensure that our advertisements reflect our clients’ needs. We work with certain service providers to promote our products and services that reflect your interests and needs and also use browsing data collected through Cookies or Tracking Codes to facilitate your overall experience on our Website. To do this, we may transmit this browsing data to third parties such as advertising networks and other advertising companies that use their own tracking technologies (including Cookies and Pixels) on our Website and applications, but also on third-party websites and applications in order to provide you with personalized advertisements on our behalf on those websites. The main service providers used by Cogir for targeted advertising are Google, Facebook, Instagram, LinkedIn, YouTube, and TikTok. These companies may collect information about your activities on your various devices on our Website and applications as well as on third-party websites and applications (such as web pages you visit and your interactions with our ads and other communications such as emails) to then use this information to predict your preferences, develop personalized content, and deliver relevant advertisements to you on third-party websites and applications. This is called “interest-based advertising.” This information may also be used to evaluate our online advertising campaigns.

Audience Creation

We also use custom audience services from social media platforms such as Facebook and Instagram, as well as advertising audience services such as Google, which send targeted advertisements to users of these platforms or on third-party websites based on custom audiences created through a profile-matching process. You can limit this targeting by modifying your advertising preferences on each of these social or advertising platforms.

Please note that even if you choose not to receive personalized advertising from a third party, tracking technologies may still collect data for other purposes, including data analysis, and you may still see ads from us. However, these advertisements will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.

Web Analytics

Web analytics involves collecting, analyzing, and reporting data on website traffic and visits. We use analytics tools to analyze visitor browsing behaviors on websites and understand attribution and traffic source impact.

When your computer or another device requests access to a page on one of our Websites, the information collected for web analytics includes, but is not limited to:

The originating IP address (the storage and retention format does not allow visitor identification);

The date and time of the visit;

The type of browser and operating system used;

The page(s) visited and the document(s) downloaded.

The data collected for web analytics may be aggregated and used by Cogir for statistical analysis and targeting, verification, evaluation, research, planning, and reporting purposes. This information is only made available to web managers and other employees who need it in the course of their duties.

Accuracy of Information

Cogir takes reasonable steps to ensure that the Personal Information collected is accurate and complete. We update our records regarding members and clients based on information they provide to us or that is provided to us by our Partners when applicable. Therefore, to ensure that our records are as complete, accurate, and up-to-date as possible, you must inform Cogir of any relevant changes to your Personal Information, such as a change of name, address, or contact details.

Your Rights and Options

We offer you various options that allow you to exercise your rights and meet certain preferences regarding the use of your Personal Information that we have collected about you.

Access, Verification, Correction, and Deletion of Personal Information in Our Possession

To the extent that we retain Personal Information about you, unless prohibited by law, you have the right to: (i) verify your Personal Information; (ii) request that your Personal Information be corrected or updated; and (iii) withdraw your consent to our use of your Personal Information and have your Personal Information deleted from our records. If you wish to know or verify the Personal Information that Cogir holds about you, correct it, or have it permanently and completely deleted from our records, please contact us at the contact details mentioned in the “Privacy Officer – Contact Us” section below.

Please note that to prevent fraudulent or unauthorized access requests, we may ask you to identify yourself and provide proof of identity.

When we receive such a request, we commit to responding promptly. If we are unable to provide access to all your Personal Information, the reasons will be communicated to you. You may also request the deletion of your Personal Information subject to legal and contractual restrictions; however, please note that the deletion of certain information may affect our ability to provide certain services. If you request the deletion of your Personal Information, we reserve the right to retain certain information for a reasonable period to meet our legal obligations.

Options and Right of Withdrawal You can generally withdraw your consent to the use or disclosure of your Personal Information at any time, subject to legal or contractual restrictions, by contacting Cogir at the contact details indicated in the “Privacy Officer – Contact Us” section below. However, without such consent, we may not be able to offer you certain services.

Privacy Officer – Contact Us

Cogir’s Privacy Officer is responsible for creating, supervising, and implementing a privacy management program and policies and procedures to protect personal information, answering any privacy-related questions, and informing you about our privacy practices.

If you have any questions about this Policy or how Cogir collects, stores, uses, and discloses your Personal Information or if you wish to exercise a right regarding your Personal Information, obtain access to it, or request its correction or deletion, you should write to the Privacy Officer by email at [email protected] or at the following postal address:

To the attention of:

Privacy Officer Legal Affairs Department

385 Viger Avenue West Suite 400

Montreal (Quebec) H2Z 0C2

Cogir will respond to all requests received promptly.

Policy Changes and Updates

We make changes and updates to this Policy from time to time to comply with applicable laws and to accurately reflect our privacy practices. Therefore, Cogir may revise this Policy at any time based on the evolution of its activities, laws, availability of new technologies, or the introduction of new products, services, programs, or features without notice.

Any changes to the Policy are posted on our Websites. When we make changes to this Policy, we revise the date of the last update appearing at the end of the document. Please check it regularly to see if changes have been made.

Continuing to use our services, including our Websites, means you accept the revised terms of the Policy and give your consent accordingly.

Updates

This Privacy Policy is the most recent version and was updated in September 2023.

Definitions

Cookies: A cookie is a small text file stored on your device that identifies your browser, device, or IP address (and not you as an individual) on our computers each time you visit our Website.

Tracking Codes and Pixels: A pixel is a small transparent graphic image that allows us to record simple user actions related to our website and email communications we receive to help us determine the usage and effectiveness of our Website and communications. These “images” are automatically downloaded into your browser or device when you visit a website or social media platforms or open an HTML email from us, allowing us to know if a certain page has been visited or if an email has been read. These tracking codes help us optimize and customize our Websites for you and future visitors and personalize our marketing initiatives.