1. Data controller

This privacy policy is published by Sspace(hereinafter “we,” “our,” or “the company”), which operates the website accessible at the address associated with the Sspace brand.

Sspace is subject to the An Act to modernize legislative provisions respecting the protection of personal information (S.Q. 2021, c. 25), commonly known as “Bill 25.” This law governs how we collect, use, disclose, and retain your personal information.

Our website is hosted in Quebec by Horizon-Cumulus (Joliette, Quebec), which means that data related to the primary hosting of your visit remains within Quebec. However, certain third-party services integrated into the site involve transfers outside of Quebec, as described in sections 4 and 5 of this policy.

2. Personal information collected

Depending on how you interact with our site, we may collect the following categories of personal information:

• Identification and contact information — name, email address, phone number, mailing address, when you fill out a contact form or a real estate information request form.
• Transactional information — data related to your requests, transactions, or business interactions conducted through the site (e.g., quote forms, visit requests, information about your real estate interests).
• Navigation and technical information — IP address, browser type and version, pages visited, session duration, browsing behavior, approximate location (city or region), device identifiers. This information is collected automatically during your visit, including through the analytics and advertising services described in Section 4.
• Advertising and social identifiers — identifiers linked to your Meta (Facebook/Instagram) account or your Google advertising profile, collected only if you have consented to Marketing category cookies.
• Consent preferences — your cookie preferences, stored by the Moelleux platform to respect your preferences during your future visits.

We do not collect sensitive personal information, such as health data, biometric data, or Social Security numbers, in the ordinary course of operating this site.

3. Purposes of processing

Your personal information is used solely for the purposes described below. For each purpose, we indicate the legal basis on which we rely, in accordance with Act 25.

• Responding to your requests for real estate information — Processing your contact information and interests to provide you with the requested information (viewings, properties, availability). Legal basis: performance of a contract or pre-contractual steps at your request.
• Audience measurement and site improvement — Analysis of visitor behavior via Google Analytics 4 to understand which pages are most frequently visited and improve the browsing experience. Legal basis: consent (analytics cookie).
• Targeted advertising and remarketing — Conversion tracking and delivery of personalized ads on Meta (Facebook/Instagram) and Google platforms, targeting people who have visited our site. Legal basis: consent (marketing cookie).
• Optimal website display — Loading fonts via Google Fonts to ensure consistent visual rendering across all devices. Legal basis: legitimate interest (technical operation of the site) — no profiling is performed for this purpose.
• Cookie consent management — Storing your consent preferences via the Moelleux platform, operated by Horizon-Cumulus (Joliette, Quebec), to respect your choices during future visits. Legal basis: legal obligation (Bill 25) and legitimate interest.
• Site security and integrity — Use of IP addresses and technical data to detect unauthorized access and protect the infrastructure. Legal basis: legitimate interest.

We do not use your personal information for purposes incompatible with those set out above without obtaining your prior consent.

4. Third parties and subcontractors

The following table lists all third-party services integrated into our website, their purpose, their category, and whether information may be transferred outside of Quebec.

Cookies in the Analytics and Marketing categories are only enabled after we have obtained your explicit consent via our cookie management banner. You can change your preferences at any time.

5. Transfers outside Québec

In accordance with section 17 of Act 25, we hereby inform you that certain personal information collected during your visit is transferred and processed outside of Quebec, specifically in the United States, by the following providers:

• Google Analytics 4 (Google LLC, United States) — your browsing data and device identifiers may be processed on U.S. servers. Google adheres to recognized transfer mechanisms (standard contractual clauses) and offers data minimization options, including IP address anonymization.
• Meta Pixel (Facebook) (Meta Platforms, Inc., United States) — your advertising identifiers, browsing data, and, where applicable, transaction data may be transmitted to Meta for the purposes of targeted advertising and remarketing.
• Google Ads / Conversion (Google LLC, United States) — your advertising IDs and conversion data are transmitted to Google for the optimization of advertising campaigns.
• Google Fonts (Google LLC, United States) — your IP address is transmitted to Google’s servers when fonts are loaded.

Before any transfer to these suppliers based in the United States, we ensure that an adequate level of protection is in place, in particular by entering into contractual agreements for the protection of personal information that comply with the requirements of Bill 25. A Privacy Impact Assessment (PIA) is conducted when the nature of the transfer requires it, to verify that the information is adequately protected in the destination jurisdiction.

Our primary hosting infrastructure (website and consent management via Moelleux) is located in Quebec. The data transfers described above apply exclusively to third-party analytics, advertising, and functional services integrated into the site.

6. Shelf life

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or to comply with our legal obligations. The following table outlines our retention practices by data type.

Once these time limits have expired, your information will be securely destroyed or irreversibly anonymized in accordance with our internal procedures for the destruction of personal information.

7. Rights of persons concerned

Bill 25 grants you several rights regarding the personal information we hold about you. Here is an overview of those rights and how to exercise them.

• Your right of access - You may ask to see the personal information we hold about you, as well as information about how it is used and disclosed.
• Right of rectification - If information concerning you is inaccurate, incomplete or ambiguous, you may request that it be corrected.
• Right to erasure (right to be forgotten) — In the situations provided for by Act 25, you may request the deletion of your personal information, particularly when the purpose for which it was collected has been fulfilled or when you withdraw your consent.
• Right to portability - You may request to receive, in a commonly used technological format, the personal information you have provided to us, in order to transmit it to another data controller.
• Right to withdraw consent — You may withdraw your consent at any time for processing based on consent (including analytics and marketing cookies), without this affecting the lawfulness of processing carried out prior to your withdrawal. To manage your cookie preferences, use the consent banner available on our site.

To exercise any of these rights, please send your written request to our Privacy Officer, whose contact information is provided in Section 8. We are committed to processing your request within 30 days within 30 days of receipt, in accordance with Act 25.

If you believe that your rights have not been respected or that your personal information has been processed in a manner that does not comply with the law, you have the right to file a complaint with the Commission for Access to Information (CAI) :

• Website : www.cai.gouv.qc.ca

8. Privacy Officer

In accordance with Section 8.1 of Act 25, Sspace has appointed a Privacy Officer (PO). This person is your point of contact for any questions, requests, or concerns regarding the protection of your personal information.

• Name : Frédérique Dono Roberge
• Title : --
• E-mail : info@monsspace.com
• Phone : 418 806-4287

We undertake to respond to any request within a maximum of 30 days within 30 days of receipt, as provided for by Act 25. If your request is complex or voluminous, we will notify you within that same timeframe of any necessary extension and the reason for it.

9. Effective date and versioning

This Privacy Policy is effective as of June, 11 2026and constitutes the version 2.

We reserve the right to modify this policy at any time to reflect changes in our practices, the services we use, or applicable legal requirements. In the event of a material change, we will notify you via a prominent notice on our website before the changes take effect. The update date at the top of this section indicates the current version.

We encourage you to review this policy periodically to stay informed about how we protect your personal information.