FamilyLending.ca
PRIVACY POLICY
At FamilyLending.ca we are committed to protecting the privacy
and confidentiality of the personal information of our clients
(individually, the “Client” and collectively, the “Clients”.) As
financial service providers, we have a professional obligation
to maintain in confidential information we receive within our
role as a financial services provider. The purpose of this
Privacy Policy is to advise clients as to why we ask for
personal information, how we use it, what safeguards we employ,
and how to contact us with privacy-related matters.
What Is Personal Information?
In this Privacy Policy, “Personal Information” means information
that is gathered in connection with an application,
pre-approval, request for information for a mortgage(s) or
loan(s) and insurance and other related products through
FamilyLending.ca or its affiliates and is provided to, or
collected by FamilyLending.ca and its staff or by
FamilyLending.ca’s agents, associates, and affiliates on
FamilyLending.ca’s behalf (collectively, “FamilyLending.ca’.).
Why FamilyLending.ca Collects Personal Information
At FamilyLending.ca we collect and use Personal Information for
the following purposes:
Provide mortgage brokering services and other related services
to the Client and offer products and services best suited to
their needs, including arranging and/or renewing
loan(s)/mortgage(s), informing the client of group creditor
insurance and other products offered or related services as
approved by FamilyLending.ca or its affiliates that may be of
interest to the Client;
Checking Client credit worthiness through credit bureau inquiry
and personal information agents who have information on a
Client’s financial position;
Advising Clients of the financial options, as well as, ongoing
developments of the mortgage market and industry;
Auditing the services provided to our Clients;
Compliance with all municipal, provincial, federal and other
applicable laws; and
Such other specific purposes which are communicated to the
Client by a member of FamilyLending.ca before collection of such
Personal Information.
Except when otherwise permitted by law, we will only use a
Client’s Personal Information for the purposes identified to the
Client. When Personal Information is to be used for a purpose
not identified, we will take all reasonable steps to ensure that
new purpose is identified prior to use.
How Do We Collect Personal Information?
The Client is our main source of information. With the Client’s
consent, we may also obtain information directly from a third
party to help us determine eligibility for various financial
products and other related services. For credit matters, for
example, it is essential that we know the clients’ financial
worth as well as the clients’ credit record. We will also
contact other lenders, financial institutions, credit bureaus
and employers. Consent is therefore important because without
it, we will not be able to carry out the appropriate inquiries
and it might be difficult for us to offer the credit product
requested. In most cases, consent is given on the forms used for
specific products or, from time to time, on a separate form. The
declaration of consent is clear and unambiguous.
Consent
A clients’ provision of Personal Information to FamilyLending.ca
means that they agree and consent that FamilyLending.ca can
collect, use and disclose such Personal Information in
compliance with this Privacy Policy. FamilyLending.ca will not
collect, use or disclose a Client’s Personal Information without
the Client’s requisite consent, except in certain extraordinary
circumstances. Such extraordinary circumstances shall include
without limitation, when legal, medical or security reasons make
it impossible or impractical to obtain consent or where it is
otherwise in the best interests of the Client.
The most common method we use to obtain a Client’s consent is by
way of the Client’s consent as confirmed by the application.
Where practical, we may also obtain a Client’s consent through
oral communications or other written documentation.
Our Clients may withdraw their consent by written notice to us
at any time, subject to any legal or contractual restrictions
and reasonable notice. A Client’s refusal to provide, or
subsequent withdrawal of, his or her consent may affect
FamilyLending.ca ability to provide the Client with mortgage
services or other related services. A member of FamilyLending.ca
will inform the Client of the implications of such withdrawal.
To withdraw consent, a Client should contact the Chief Privacy
Officer in writing at:
Attn: Chief Privacy Officer
FamilyLending.ca
60 Keil Drive South
Chatham, Ontario
N7L 1C1
Toll Free: 1-866-941-6678
Use and Disclosure of Personal Information
We will use a Client's Personal Information to provide financial
advice and other related services to the Client, to administer our
database, to include Clients in direct marketing Activities and for
the other uses described above under the heading "Why
FamilyLending.ca Collects Personal Information". Under certain
circumstances, FamilyLending.ca will disclose a Client's personal
information to third parties. Specifically, Personal Information may
be used, shared and disclosed to, from, or with, the members of
FamilyLending.ca, witnesses in a litigation proceeding, experts
retained on a Client's behalf, private investigators, agents
retained on behalf of a Client, credit reporting agencies, credit
bureaus, as well as such other third parties as are necessary to
facilitate the matter for which the Client has retained our office
and provided consent.
Under certain circumstances FamilyLending.ca may disclose Personal
Information where:
required or authorized by law to do so, for example if a court
issues a subpoena;
a Client has consented to the disclosure;
when mortgage services by FamilyLending.ca are provided to a Client
requiring us to give Personal Information about a Client to a third
party (for example, to a lender in a real estate mortgage
transaction) the Client's consent will be implied, unless the Client
tells us otherwise;
where it is necessary to pull a credit bureau for purposes of
processing a mortgage transaction;
if FamilyLending.ca engages a third party to provide administrative
or support services to us (such as computer back-up services,
payroll, shredding or archival file storage) and the third party is
bound by our Privacy Policy;
protection of FamilyLending.ca best interest;
protection of the public interest such as the denouncement of
criminal Activity such as fraud or money laundering. In all such
cases, authorities are contacted and personal information may be
disclosed;
if we retain a law firm(s) to Act on our behalf for any reason; and
if the information is already publicly known.
Limiting collection and retention of Personal Information
FamilyLending.ca limits the collection of a Client's Personal
Information to that which is necessary for the purposes identified
in this Privacy Policy as same may be amended from time to time, or
for any additional purpose identified to the Client before the
collection of the Personal Information. As well, Personal
Information is not used or disclosed for purposes other than those
for which it was originally collected, except with the consent of
the Client or as otherwise permitted by law.
FamilyLending.ca will retain Personal Information only for so long
as it is needed to fulfill the purposes for which it was obtained
and to meet our professional requirements as set out in our
governing regulatory bodies and/or any other legal requirement,
statutory or otherwise, from time to time.
Accuracy
FamilyLending.ca strives to ensure that a Client's Personal
Information is as accurate, complete, and up-to-date as is necessary
for the purposes for which it is used.
Safeguards
FamilyLending.ca endeavors to maintain adequate safeguards to
protect against loss, theft, unauthorized access, disclosure,
copying, use or modification of Client's Personal Information in the
care to FamilyLending.ca.
FamilyLending.ca uses various methods to safeguard personal
information, including physical security, computer and electronic
security, destruction of information no longer needed, and
contractual protections with third party data processors.
Protection
Client lists are never passed on to third parties other than
affiliated members of FamilyLending.ca. When they are hired, our
employees and agents must undertake to respect the confidential
nature of client information. Only employees and associates who need
to view the file as part of their work have access to this
information.
Accountability, Openness and Client Access
FamilyLending.ca is responsible for the Personal Information under
its control and has appointed a Chief Privacy Officer to oversee our
efforts to comply in all material respects with applicable privacy
legislation and the terms of this Privacy Policy. The Chief Privacy
Officer and those designated by the Chief Privacy Officer address
and investigate questions or concerns regarding a Client's Personal
Information.
FamilyLending.ca will provide a Client access to their Personal
Information. The Client may correct or amend any inaccuracies in the
Client's Personal Information. FamilyLending.ca has the right to
refuse a request for access to Personal Information if:
The information is protected by legal privilege;
Granting access would reveal confidential commercial information;
The information was collected for purposes related to the detection
and prevention of fraud;
The information was generated in the course of a formal dispute
resolution process;
The information would likely reveal personal information about
another individual;
The request is in vexation or frivolous;
To protect our firm's rights and property;
Changes to Privacy Policy
FamilyLending.ca will from time to time review and revisit privacy
practices and this Privacy Policy.
FamilyLending.ca Web Site
Our Web site may contain links to other sites, which are not
governed by this Privacy Policy. On our Web site, like most other
commercial Web sites, we may monitor traffic patterns; site usage
and related site information in order to optimize our web service.
We may provide aggregated information to third parties, but these
statistics do not include any identifiable personal information.
Marketing
FamilyLending.ca may tell you about products and services through
direct mail, telephone, email, or other means. If you do not wish us
to do so, please advise FamilyLending.ca in writing of your wishes.
Communicating With FamilyLending.ca
We recognize that convenience and quick access to advice must be
balanced with security needs. We use many different means to
communicate with clients, some of which are more convenient such as
e-mail. Our emails are sent with industry standard encryption. Such
encryption however does not guarantee privacy and security as
encrypted messages can nonetheless be subject to interception and
translation. If clients do not wish us to communicate by e-mail,
they may speak with the Agent/Broker handling the matter about
alternative arrangements.
Chief Privacy Officer
FamilyLending.ca
60 Keil Drive South
Chatham, Ontario
N7L 1C1
Toll Free: 1-866-941-6678
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