PRIVACY POLICY

1. Scope This privacy policy (hereinafter the “Policy”) applies to the following entities:
   • ÉDYFIC INC.;
   • GESTION DEVIMCO IMMOBILIER INC.;
   • DEVIMCO IMMOBILIER INC.; &
   • Their affiliated entities. (hereinafter referred to as “Devimco” or “we“)
   The Policy applies to Personal Information (as defined below) concerning users of the website https ://devimco.com/, websites created specifically for Devimco projects (hereinafter collectively the “Website“) as well as to Personal Information collected via our social network accounts, including the following:
   • Facebook: https://www.facebook.com/groupedevimco
   • Instagram: https://www.instagram.com/groupedevimco/
   • LinkedIn: https://www.linkedin.com/company/devimco
   (hereinafter collectively the “Social Network Accounts“) The Policy also applies to Personal Information concerning our customers, co-contractors, potential buyers, employees, job applicants, as well as that concerning the directors of our financial partners. The Policy sets out how we manage and protect Personal Information within the limits imposed on us by the Act respecting the protection of personal information in the private sector (the “Act“). In this regard, the following sections provide you with information on:
   • The general principles that guide our actions and the scope of your consent;
   • The categories of Personal Information we collect, the means by which we collect it, and the purposes for which we use it;
   • The security and governance measures we take to protect it;
   • How we disclose and store it;
   • Your rights and how you can exercise them.
2. General principles Devimco is committed to respecting the following principles, both in its internal policies and in its day-to-day operations and business:
   • Your consent to the collection, use or disclosure of your Personal Information must be manifest, free and informed. It must be given for the specific purposes and objectives identified in this Policy, in accordance with the terms and conditions specified in section 3.
   • The purposes for which Devimco collects your Personal Information (as set out in section 4 of this Policy) are identified at or before the time of collection.
   • Unless we have obtained your express or implied consent and/or unless the Act or any other legislative provision requires or authorizes us to do otherwise, your Personal Information will only be collected, used and disclosed for the purposes specified in section 4 or for purposes consistent therewith.
   • Access to your Personal Information by Devimco employees is strictly limited to those employees for whom such Personal Information is necessary for the performance of their duties and the fulfillment of their tasks.
   • Devimco recognizes that the communication of your Personal Information to third parties requires your consent except in the cases described in section 6 of this Policy or when otherwise authorized or required by the Act or any other legislative provision.
   • Devimco retains your Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected in accordance with section 7 of this Policy.
   • Devimco strives to obtain accurate, complete and up-to-date Personal Information, but you have, as the case may be, the obligation or the right to rectify it according to the terms specified in section 8 of this Policy.
   • Devimco uses reasonable means to ensure that you can exercise the rights granted to you by law, as set out in section 8 of this Policy.
3. Acceptance and consent BY USING THE WEBSITE OR BY COMMUNICATING YOUR PERSONAL INFORMATION TO OUR REPRESENTATIVES VIA OUR SOCIAL NETWORK ACCOUNTS, YOU CONSENT TO ITS COLLECTION, USE, DISCLOSURE AND RETENTION IN ACCORDANCE WITH THIS POLICY. PLEASE READ IT CAREFULLY. IF YOU DO NOT CONSENT, PLEASE DISCONTINUE USE OF THE WEBSITE OR SERVICES.  Depending on the nature and sensitivity of your Personal Information, your consent may be express (such consent may be given verbally, in writing or electronically, for example, by checking a box confirming your consent or by signing a form requesting your consent) or implied (when you voluntarily provide Personal Information, for example, by completing a form).  Except where otherwise provided by the Act, you may withdraw your consent at any time upon reasonable notice to Devimco. Please note that if you choose to withdraw your consent to the collection, use or disclosure of your Personal Information, certain features of our Website and/or certain services may no longer be accessible or available to you.  This Policy does not apply to third-party websites, pages or applications that may be accessed through our Website. If you follow such links, these third-party sites or services will likely have their own privacy policies that you should review before submitting your personal information.  Furthermore, when you communicate your Personal Information via Social Network Accounts, the privacy policies of these platforms may apply. We cannot guarantee that these platforms will respect the exercise of your rights. Please read their privacy policies carefully :
   • https://www.facebook.com/privacy/policy (Instagram & Facebook).
   • https://fr.linkedin.com/legal/privacy-policy (LinkedIn).
4. Personal information collected, methods and purposes of collection “Personal information” means any information relating to a natural person that allows, directly or indirectly, that person to be identified.  Each of Devimco’s internal entities and departments collects only the Personal Information about you that is necessary to establish, manage and maintain its relationship with you. For each of these entities and departments, we describe below the categories of Personal Information we collect, the means by which we do so and the legitimate purposes we pursue in doing so.  If we collect other Personal Information on an ad hoc basis as needed, we will ask for your consent in accordance with Section 3 and the general principles described in Section 2, which are applicable.
   • Real estate management (residential rental)Devimco’s residential rental division collects the following Personal Information about tenants:
     • identification information: first and last name, date of birth, gender and identification documents (for example health insurance card or driver’s license with numbers suppressed);
     • contact information: postal address, telephone number, e-mail address;
     • professional information: employer, job title, length of service, salary, proof of income (for example pay statement for net monthly salary);
     • financial information: cheque specimen and credit score;
     • rental history information: information related to previous lease (duration, expiry, current rent, etc.), reference information (name and telephone number of previous landlords, representative of the current employer, etc.);
     • other information (depending on building): license plate (for automated parking access systems and emergencies).
     This Personal Information may notably be collected during telephone conversations or e-mail exchanges with our representatives or when you fill out lease or credit investigation forms. It may also be collected via platforms such as Upperbee and Condo Manager. In addition, some of this information may be provided to us by third parties such as credit investigation firms, collection agents, banks and outside firms helping foreign residents settle in Quebec. This Personal Information is required for the following purposes:
     • rent residential units;
     • establish and maintain our relationship with you and offer you ongoing service;
     • obtain statistics on your satisfaction;
     • validate your ability to pay;
     • verify your rental history;
     • send you notices and information;
     • provide you with services through third parties;
     • manage our rental inventory; and
     • meet legal requirements.
     In some cases, this Personal Information may be used in legal proceedings (notably before the Tribunal administratif du logement), including civil proceedings relating to the recovery of unpaid rent.
   • Commercial leasing Devimco’s commercial leasing department collects the following Personal Information from tenants and/or their representative(s), when the tenant is a legal entity:
     • identification information: first and last name, date of birth;
     • contact information: postal address, telephone number, e-mail address;
     • professional information: address of current job, name of employer, duties performed;
     • financial information: cheque specimen, credit information, personal financial statement.
     This Personal Information is collected by e-mail or via a disclosure form and is required for the following purposes:
     • rent you commercial space;
     • validate your ability to pay;
     • guarantee payments with a personal guarantee.
     In some cases, this Personal Information may be used in legal proceedings, including civil proceedings for the recovery of unpaid rent.
   • Sales (Condos Clients) Devimco’s department and/or affiliated entities dedicated to the sale of units in co-ownership (condos) collects the following Personal Information from potential buyers:
     • identification information: first and last name, address, telephone number, e-mail, gender, identification (health insurance card and/or driver’s licence), nationality, marital status information;
     • financial information: mortgage approval, banking information;
     This Personal Information may be collected during e-mail exchanges with our representatives, when you sign a preliminary contract (and/or an amendment or appendix thereto) or, if applicable, when you fill out any other form required for the sale of a condo unit. This information may also be provided to us by third parties, such as real estate brokers, banks and notaries. This Personal Information is required for the following purposes:
     • sell you a unit, parking space and/or storage space in a co-ownership;
     • send you mandatory notices, and generally provide you with information relevant to the sale;
     • verify your identity and compliance with certain conditions imposed by law. For example, we can verify whether you qualify as an investor or a foreign resident;
     • manage sales-related accounting and customization work.
   • Human resources Devimco’s Human Resources Department collects the following categories of Personal Information about employees:
     • identification information: first and last name, date of birth, vehicle information (for automated parking access and emergencies), photo, ID (notably for initial employee identification and in the event of an accident/stop of work), SIN;
     • contact information: postal address, telephone number, e-mail, emergency contact telephone number;
     • medical information: vaccination information related to COVID, information related to work-related accidents and illnesses that occurred during the employment relationship with Devimco;
     • employment history information: information generally provided in a résumé, such as jobs held during career and seniority, as well as salaries and the names and telephone numbers of references (at the time of hiring);
     • financial information: specimen cheque (for payroll);
     This Personal Information may be collected via technological platforms dedicated to human resources and payroll management or via external recruitment firms for information generally provided in a curriculum vitae. With regard to job applicants, we collect the Personal Information generally provided in a résumé, such as a list of jobs held during a career, as well as identification and contact information such as first and last names, telephone numbers and e-mail address. Subsequently, the other Personal Information listed above is collected as it becomes necessary to advance the hiring process.
5. Security of your Personal Information The security of your Personal Information is a priority for us. We have put in place physical and technological measures that are reasonable in light of the sensitivity of the Personal Information, its use, amount, distribution and medium.
6. Disclosure of your Personal Information:
   • To whom ? We may disclose your Personal Information to third parties in specific circumstances permitted by the Act or other legislation. The following table summarizes these circumstances and the measures we take to protect their confidentiality.

     Recipient	Purpose	Measures
     To the following subcontractors, suppliers, co-contractors and agents: Credit investigation firms; Telecommunication service providers; Financial auditors; Condominium Management compagnies; Notaries; Other agents and service providers.	We sign contracts with subcontractors, suppliers, co-contractors and agents in order to provide you with a service and/or improve existing services.	Our contracts require subcontractors, suppliers, co-contractors and agents to: Use only the Personal Information required to provide the service; Refrain from disclosing or communicating Personal Information without our consent; Implement rigorous security measures; Allow us to audit these measures; Notify us of any breach of confidentiality; Destroy Personal Information at the end of a contract.
     To another party as part of a business transaction. Such transaction is defined as the disposal or lease of all or part of our business or its assets, a change in our legal structure by merger or otherwise, the obtaining of a loan or any other form of financing, or a security interest taken to guarantee one of our obligations (hereinafter the “Business Transaction“)	Conclude a Business Transaction.	Our contracts require the other party to: Use only the Personal Information necessary to complete the Business Transaction; Implement rigorous security measures; Refrain from disclosing or communicating Personal Information without our consent; Notify us of any breach of confidentiality; Destroy Personal Information if the Business Transaction is not completed, or if it is no longer required to complete the Business Transaction.
     To the legitimate competent authorities.	In order to comply with a court order or decision, including a valid search warrant, or a competent authority.	The laws governing these authorities require them to put measures in place to respect and preserve the confidentiality of your Personal Information.

   • Where? As part of our operations, we do not share your Personal Information with third parties outside Quebec.  If, exceptionally, we are required to disclose your Personal Information outside Quebec, we will conduct a Privacy Impact Assessment that takes into account:
     • the sensitivity of the Personal Information;
     • the purposes for which it will be used;
     • the safeguards to which it will be subject; and
     • the legal regime applicable in the country where the Personal Information will be communicated.
     We will only proceed with this communication if this assessment demonstrates that the Personal Information will benefit from adequate protection in accordance with generally accepted principles of protection of Personal Information. In addition, such disclosure will be subject to a written contract that takes into account all the conclusions of the assessment.
7. Conservation We retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected, except where legal requirements or contractual interests recognized by law require us to retain it for a longer period. We also reserve the right to establish Personal Information destruction policies from time to time. Upon written request to the e-mail address provided at the end of this Policy, we may also inform you of the length of time we will retain your Personal Information.  If you request the destruction of your Personal Information for which the purposes for which it was collected have been fulfilled, we will use reasonable efforts to fulfill your request as quickly as possible.
8. Your rights  With respect to your Personal Information, you have the following rights:
   • The right to be informed of its use, disclosure, retention and destruction (this Policy is intended to do just that);
   • The right to access your Personal Information and to obtain, where appropriate, further details on how we use, disclose, store and destroy it;
   • In some cases, the right to object to, restrict or withdraw your consent upon reasonable notice sent to the e-mail address provided at the end of this Policy;
   • The right to have your Personal Information corrected if it is inaccurate or misleading, and to have it completed if it is incomplete; and
   • The right to have your Personal Information deleted if it is out-of-date or if the purposes for which it was collected have been fulfilled, subject to our legal obligations;
   You may exercise these rights by sending an e-mail to the e-mail address provided at the end of this Policy. We will respond to your request within 30 days of receipt. Subject to the restrictions set out in the Act, if we refuse to provide or correct your information, we will inform you of the reasons for the refusal, of your recourse and of the applicable sections of the Act. If we refuse to rectify or delete your Personal Information, we will allow you to add comments to your file in writing with respect to the Personal Information for which rectification or deletion has been refused. We will also retain Personal Information that has been the subject of a request for access or removal for as long as necessary to allow you to exhaust your remedies under the Act. You can also file a complaint with the Commission d’accès à l’information du Québec by using the form available on its website. However, we invite you to contact our Privacy Officer first.
9. Cookies  We use technologies to identify, locate or profile you by using the following cookies:
   • Necessary Cookies : These cookies are necessary for the operation of our WebSite and cannot be disabled. These cookies do not collect any Personal Information.
   • Functionality cookies : Functionality cookies are used throughout the browsing process to facilitate the use of our Website. For example, a functional cookie may be used to remember your username to make it easier for you to log in, or to remember your preferences or selected options;
   • Analytical cookies: These cookies are used to collect statistics on the use of our Website and user preferences. These cookies may be used to collect data on user interactions with our Website, such as clicks and mouse movements. The information gathered may be used to analyze user behavior and improve the browsing experience on our Website.
   • Advertising cookies: These cookies may be added by the Website or by other sites displaying advertising or announcements. These cookies collect information and establish your visitor profile. Cookies may also be used to track advertising effectiveness and better target ads based on previous browsing behavior. In particular, cookies will be used by the following social media: LinkedIn, Facebook, TikTok, as well as partners such as Microsoft, Bing, Google, Google Analytics and OpenX.
   For further information about the cookies we use on our Website, please refer to our cookies banner. Cookies with identification, location and profiling functions are disabled by default. You can configure your browser at any time to block cookies. You can also opt out of our use of cookies and similar technologies. However, this action may deprive you of certain functions offered on the Website.
10. Privacy Officer  Devimco’s Privacy Officer is Mr. Mathieu Jobin. If you have any questions or requests regarding this Policy, please send an e-mail to the following address: confidentialité@devimco.com
11. Modification Devimco reserves the right to change the content of this Policy at any time. Any changes will be posted on our Website and brought to your attention when you log in. We recommend that you review this section of our Website periodically.