Privacy Policy
PRIVACY POLICY
Last updated: MARCH 31, 2026
Preliminary Note
The Réseau Première Ligne (“RPL”) is a group of family medicine groups (FMGs) aimed at fostering collaboration, knowledge sharing, and innovation to support healthcare professionals and provide patient-centred care.
RPL is an unincorporated association established at the initiative of Groupe Medway Inc., which contributes to its startup activities and development.
In this context, Groupe Medway Inc.’s personal information protection policies apply to RPL’s activities, with the necessary adaptations to reflect its structure, operations, and applicable legal requirements.
This privacy policy (the “Policy”) is intended to inform users (“you”) of how Groupe Medway Inc. and its related and/or affiliated companies (hereinafter collectively referred to as “Medway” or “we” or “our”) collect, use, store, disclose, and destroy personal information you provide in the course of our activities, including real estate operations and, where applicable, RPL activities, or that is collected when browsing our websites (the “Site”).
When you provide personal information while browsing our site or in the course of our activities, you consent, where required, to the collection, use, disclosure, and processing of your personal information in accordance with this Policy.
1. SCOPE OF THE POLICY
This policy applies to you. It describes how we collect, use, store, and disclose your personal information when you provide it to us on our site or in the course of our real estate operations. This Policy also applies, with necessary adaptations, to RPL activities when conducted through the site.
Our site may include hyperlinks to third-party websites or online resources. These websites and resources are governed by their own privacy policies, and Medway assumes no responsibility in this regard.
This Policy should be read in conjunction with the Cookie Policy, available here.
2. COLLECTION OF PERSONAL INFORMATION
We collect your personal information, particularly when you:
- Sign a lease with us;
- Schedule an appointment to visit a leasing office or for commercial space rental;
- Complete a form requesting contact from a leasing agent;
- Browse our site.
What personal information do we collect and why?
| What information? | Why? |
|---|---|
| At lease signing | |
| First name, last name, contact details (address, email, phone), date of birth, void cheque, signature, ID, SIN (if required for credit purposes). | To identify you, communicate with you, confirm your identity, process rent payments, and perform credit verification. |
| Appointments or contact forms | |
| First name, last name, contact details (email, phone), customer service call recordings. | To personalize communications, confirm appointments, ensure service quality, and a newsletter subscription (with consent). |
| Website browsing | |
| Usage data (pages, duration), IP address, browser type, operating system, cookies. | To analyze traffic, improve content, ensure security, and facilitate navigation. |
Réseau Première Ligne (RPL)
For RPL activities, only the information that is voluntarily provided is collected (newsletter signup, contests, contact forms). This typically includes name and contact details.
Consent: Consent is obtained explicitly (registration) or implicitly (when you voluntarily contact us for a specific request).
Minors: Our site is not intended for children under 14 years old. If we learn that such data was collected without parental consent, it will be deleted without delay.
3. DISCLOSURE AND SHARING
Medway does not disclose your personal information to third parties without your consent, except:
- When required by law (court order, etc.);
- To protect Medway’s rights or property;
- In the event of a business transaction (merger, acquisition);
- To third-party service providers (contracted vendors).
Transfers outside Quebec: Before any transfer outside the province, we conduct a privacy impact assessment (PIA) to ensure adequate protection.
4. RETENTION AND DESTRUCTION
- Clients and tenants: Duration of the relationship + 7 years (tax purposes).
- Marketing leads: 3 years after the last interaction.
- Cookies: 13 months.
- Correspondence: 2 years after the last communication.
Upon expiry, data is securely destroyed or anonymized.
5. INDIVIDUAL RIGHTS
You have the right to access, correct, withdraw consent, and request data portability. To exercise your rights, contact our Privacy Officer (see Section 8). Requests are processed within 30 days.
6. SECURITY AND INCIDENTS
6.1 Security measures
| Type | Measures in place |
|---|---|
| Technical | Encryption, firewalls, multi-factor authentication, regular backups. |
| Organizational | Access is limited on a need-to-know basis, staff training, and password policies. |
| Physical | Secure premises, server access control, and secure disposal of media. |
6.2 Incident management
In the event of an incident posing a risk of serious harm, we will notify the Commission d’accès à l’information and affected individuals. Procedures are regularly reviewed to address emerging threats.
7. POLICY CHANGES
Medway reserves the right to modify this policy. In the event of significant changes, a notice will be prominently displayed on our site. Continued use of the Site constitutes acceptance of the updated Policy.
8. CONTACT US
Me Jean-François Hébert, Lawyer
Privacy Officer
Email: responsableprp@med-way.ca
Mailing address: 230-820 route des Rivières, Lévis (Quebec) G7A 2V1