Privacy officer contact information
Mandougou Boicel, Agency Director, is responsible for the protection of personal information at Silver Spoon Realty.
Business address: 4915, rue West Broadway, Montréal, Québec H4V 1R5
Email for requests: silverspoonrealty@gmail.com
Business telephone: 514 214-8024
Website: www.silverspoonrealty.com
Purpose and scope
Silver Spoon Realty protects the personal information it holds in connection with its residential and commercial real estate brokerage, leasing, administrative and compliance activities. This policy explains the agency’s practices and the rights of the individuals concerned. It applies, in particular, to clients, parties to a transaction, rental applicants, guarantors, prospective clients, suppliers and website visitors.
Information collected
- Identity, contact details and information needed to verify identity.
- Occupation, employer, references and information concerning legal capacity.
- Financial information, proof of income, credit information and statements when necessary and authorized.
- Information about a property, its financing, its occupancy and the parties involved.
- Brokerage contracts, promises, leases, notices, declarations, supporting documents and signatures.
- Communications, notes, emails, text messages, billing information and remuneration information.
- Technical data generated by the website or digital tools when they are used.
Collection methods
Information is collected directly from the individual concerned through forms, email, telephone, text messages, meetings, electronic document management systems, signature platforms or the website. It may also come from a party to a transaction, a professional, a verification service provider or a public register when permitted by law or valid consent.
Purposes of use
- Provide the requested services and perform a brokerage contract.
- Verify identity, capacity and information needed for a transaction or rental application.
- Prepare, negotiate, conclude and administer brokerage or leasing documents.
- Communicate with the necessary parties and professionals.
- Maintain files, books and registers and comply with legal, regulatory, tax and reporting obligations.
- Prevent fraud, protect systems and manage complaints or incidents.
- Conduct prospecting only when valid consent or another legal authorization permits it.
Consent
The agency obtains consent that is clear, free, informed, specific and limited to the stated purposes. Express consent is obtained when required by law, particularly for sensitive information. Evidence of consent, its date, scope and method are retained. Consent may be withdrawn, subject to legal obligations and information necessary to provide the service; withdrawal may prevent certain steps from continuing.
Disclosure to third parties
To the extent necessary and authorized, information may be disclosed to the parties, collaborating brokers and agencies, the owners concerned, notaries, lawyers, inspectors, appraisers, financial institutions, verification service providers, real estate listing services, technology providers, insurers, the OACIQ, FARCIQ, FINTRAC, tax authorities or other bodies authorized to require it. Silver Spoon Realty does not sell or rent lists of personal information.
Suppliers receiving information while carrying out a mandate are subject to the required written commitments, including commitments concerning limited use, confidentiality, security, incident reporting and destruction.
Processing outside Québec
Before disclosing personal information outside Québec or allowing it to be processed there, the agency conducts the required privacy impact assessment. It considers the sensitivity of the information, the purposes, security measures and applicable legal framework, and governs the disclosure through a written agreement. Disclosure occurs only if the protection is considered adequate.
Security
Access is limited to authorized needs. Depending on the sensitivity and medium, the agency uses measures such as unique passwords, multifactor authentication where available, device locking, restricted access, updates, backups, recipient verification and careful transmission of sensitive documents. No system can eliminate all risk; the agency reviews its measures when a risk or change is identified.
Retention and destruction
Files and registers subject to OACIQ rules are retained for at least six years after their final closure. Other information is retained only for the period necessary for its purpose or a legal obligation. At the end of that period, and in the absence of an applicable hold, paper documents are shredded and files are securely deleted or anonymized where permitted by law.
Confidentiality incidents
Any loss or unauthorized access, use or disclosure is assessed and recorded. The agency takes immediate steps to limit harm. When an incident presents a risk of serious injury, it promptly notifies the Commission d’accès à l’information and the individuals concerned, in accordance with the law.
Website and cookies
The website’s current code does not add advertising, audience-measurement or profiling trackers. The hosting and access service may use technical data and cookies necessary to provide and secure the service.
Inquiry forms prepare a draft in your email application. The agency receives the information only when you send the email. The investment calculator performs its calculations in your browser; the website’s code does not send the figures entered to the agency. Property-search criteria can appear in the inquiry page’s URL when you request matching properties; avoid entering sensitive information in these fields or sharing that URL if it contains information you wish to keep private.
Links to Centris, mapping services and other external websites take you to services governed by their own privacy policies. If optional identification, location or profiling features are added, they will be disabled by default and activated according to the visitor’s choice, with a simple way to accept, refuse or change that choice.
Rights and complaints
Subject to exceptions provided by law, an individual may request access to their information, its correction or the withdrawal of their consent. They may also submit a complaint to the privacy officer. The agency reasonably verifies the requester’s identity, acknowledges receipt and responds in writing within the applicable time limits. An individual who is dissatisfied may contact Québec’s Commission d’accès à l’information.
Changes
The policy is reviewed when a significant change affects the agency’s practices, systems, suppliers or obligations. Previous versions are retained when necessary to document compliance.
Adoption
This policy takes effect upon approval. It does not retroactively describe practices in earlier periods.