Last Updated: June 2019
What personal information do we collect?
Canadian privacy legislation defines "personal information" very broadly. Generally speaking, it will be information which:
- is about an identifiable individual; or
- allows an individual to be identified; and
- in either case, is not information which is already "public" according to exceptions set forth in the applicable legislation.
In this policy, our use of the term "Personal Information" means information which is defined as being personal information under the applicable Canadian privacy legislation, and which is not exempted under such legislation.
Generally speaking, personal Information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or e-mail address. Certain information, such as your name, home address and telephone number, may be exempted under Provincial legislation.
We may collect the following types of personal information from you when you use any of our products or services:
- Mailing/street address
- Email address
- Telephone number(s)
- Other contact details
- Age/date of birth
- Credit card information (via our payment platform or Identification platform)
- Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information
- Details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- Any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- Information you provide to us through customer surveys; and/or
- Any other personal information that may be required in order to facilitate your dealings with us.
- In addition to disclosing your personal information to enable us to provide our products and services to You, by its nature the FundMore.ai portals and apps enable you to send and receive documents, information and related meta data (collectively, “Documents”) that may contain personal and sensitive data including:
- Employment information
- Income records
- Financial records
- Criminal records
- Biometric information that is to be used for certain purposes
- Biometric templates.
Any other information which is necessary for us to gather in connection with an application, pre-approval, or request for information concerning mortgages, loans or other products or services purchased or applied for through The Company or any of our affiliates or sub-mortgage brokers (including Personal Information about family members, beneficiaries, directors, officers, employees, potential guarantors and other relevant parties).
How do we use information gathered about online visitors?
In general, The Company collects, uses and discloses Personal Information about you in order to provide you with mortgage brokerage and related services. This will include some or all of the following purposes:
- Providing mortgage brokerage services to you and offering products and services best suited to your needs, including arranging and/or renewing loan(s)/mortgage(s) and informing you of group creditor insurance and other products offered or approved by us or by lenders or other parties with whom we have business relationships and which may be of interest to you;
- Checking your credit-worthiness through credit bureau inquiries and personal information agents who have information on your financial position;
- Advising you of your financial options, as well as ongoing developments within the mortgage market and industry;
- Auditing the services provided to our clients;
- Complying with all municipal, provincial, federal and other applicable laws;
- Any specific purposes which are communicated to you prior to the collection of such Personal Information; and
- Any other purpose to which you consent.
Except when otherwise permitted by law, we will only use your Personal Information for the purposes identified to you, either in this Policy or directly by The Company or one of its affiliated brokerages. When Personal Information is to be used for a purpose not identified, we will take all reasonable steps to ensure that the new purpose is identified and consented to you prior to such use.
To whom do we disclose your personal information?
From time to time, The Company may disclose your Personal Information to:
- Prospective lenders, financial institutions, insurance companies and other suppliers of products or services The Company is providing or offering to you;
- Sub-mortgage brokers and other staff within The Company and its affiliated brokerages for purposes related to the services we are providing to you;
- Service providers, including organizations or individuals we have retained to perform functions on our behalf, such as office and registry services;
- Organizations or individuals retained by us to evaluate your creditworthiness or to collect debts outstanding on an account;
- A person who, in the reasonable judgment of The Company, is providing or seeking the information as your agent or who is otherwise legally entitled to receive that information;
- Police or other authorities where in The Company ’s opinion such disclosure is required for protection of the public interest, including any case where we suspect criminal activity such as fraud or money laundering;
- Any entity, including government agencies, regulatory bodies and law enforcement agencies, as required, authorised or permitted by law or a court order;
- Any law firm(s) which may be retained to act on our behalf for any reason;
- Our insurers and to regulatory agencies such as provincial financial institutions commissions or others in connection with regulatory or other activities relating to our obligations and/or our mortgage brokerage businesses; or
- Any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
- Any person, entity or platform provider authorised by you or acting on your behalf including, without limitation, your financial institution, legal, financial or other adviser, hospital, medical practitioner, health services provider, accountant, trustee, administrator, employer, guardian, attorney, agent, or other professional services provider;
- Payment systems operators (e.g. when you pay any of our fees by credit card
- Our employees and related bodies corporate;
- Third party suppliers and service providers (including providers for the operation of our websites, apps and/or our business or in connection with providing our products and services to you)
- Our sponsors or promoters of any competition that we conduct via our services; and/or
- Anyone to whom our assets or businesses (or any part of them) are transferred.
As many of our dealings with lenders and other parties are conducted through electronic means of communication, you specifically consent to our transmission of your Personal Information by electronic means, including by email and facsimile transmission, for all purposes identified in this Policy or otherwise consented to by you.
Do we use your personal information for direct marketing
We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the PIPEDA and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (i.e. an unsubscribe link). In the event you opt out of receiving direct marketing communications, we may still communicate with you regarding an existing product or service of ours that you are using in order to provide the service you have requested, update you as to features, pricing or other relevant issues.
Promotional and informational offers
With the permission of an online visitor, information submitted at the time of registration or submission may be used for marketing and promotional purposes by The Company provided notice of this fact is made available online. If a visitor objects to such use for any reason, he/she may prevent that use, either by e-mail request or by modifying the registration information provided. The Company uses reasonable efforts to maintain visitors' information in a secure environment. If you have submitted personal information and want to change it or opt-out, please contact us as described below.
Disclosure of information
The Company, in common with many web site operators, may use standard technology called "cookies" on its Sites. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. You can disable cookies by turning them off in your browser; however, some areas of the Sites may not function properly if you do so.
Protection of children online
The Company considers the protection of children's privacy, especially online, to be of the utmost importance. We do not knowingly collect or solicit personal information from children nor do we allow them to become registered users of, or to request information through, our Sites or help-seeking information lines.
Protection of information
Our Commitment to Security: We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. The Company applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.