Introduction

True North Mortgage, Inc.  and other related entities (True North Mortgage, Inc. alone or, depending on the context, True North Mortgage, Inc., and its affiliates, subsidiaries and related entities, are hereinafter collectively referred to as “TNM”, “us”, “our” or “our”) treat the protection of personal information as a priority.

The Policy also applies to THINK Financial, Morcado Trust, Morcado Mortgage, Park Real Estate Associates, Inc., Park W. Real Estate Associates Inc., among other related entities.

This Privacy Policy (the “Policy”) describes how TNM collects, uses, discloses and retains personal information about you, regardless of the nature of your relationship with TNM (unless you are an employee). For example, you are subjected to the Policy if you applied to one of our services, if you are one of our customers, if you are the representative of one of our customers, borrowers, mortgage holders or partners, if you are one of our consultants, investors or insurers, if you visit our website <truenorthmortgage.ca>, <morcado.ca>, <thinkfinancial.ca> and <parkrealestate.ca> (collectively, the “Sites”), or if you apply for a job with TNM. This Policy also describes the rights you may have under privacy laws in Canada.

Our Sites are not intended for children under the age of 14 and are not designed to attract the attention of children under the age of 14. We may collect information of children via parental and legal guardian’s consent, as described in the section “What Personal Information Does TNM Collect?” below. If you are a parent or guardian and believe we have collected personal information about your child in error, please contact us immediately using the contact information at the end of this Policy, so that we can make reasonable efforts to promptly remove all personal information relating to the child from our systems.

Definition of “Personal Information”

In this Policy, the term “personal information” refers to any information (in any format) that relates to an individual and that directly or indirectly identifies the individual. Examples of personal information include your first and last name, address, phone number, email and date of birth. Personal information will not include any business contact information such as your name, title, professional phone number, postal or email address.

What Personal Information Does TNM Collect?

We may collect the following personal information about you:

• Identifiers and contact information, such as your first and last name, address, phone number, social insurance number (for credit report and tax purposes), and email. We may collect this information if you contact us on our Sites, meet with our agents, or by other means, including when you apply for a job or for our services and products. Depending on the type of products or services you are applying to, we may also collect certain information on estate planning such as beneficial ownership, power of attorney or trusted contact information as well as information on your dependent children, such as the name, age, passport number or birth certificate. The later information will be collected through parental consent and legal guardian only.
• Financial information, such as bank information, credit information, income, assets, insurance (including without limitation and, as applicable, life insurance and home insurance), liabilities, source of funds, references, tax documentation as well as financial and employment records for the purpose of delivering our product and services, when you apply to our products and services via the Sites.
• Medical Information, such as health insurance number for identification purposes as well as pre-existing medical conditions, among others, for life insurance policies or disability policies. The information we collect will depend on the type of services and products to which you are applying via the Sites.
• Gender and demographic information, such as the date of birth and gender. We collect this information if you are applying for one of our services and products via the Sites.
• Employment-related information, including information about your work experience and education. We collect this information if you are applying for a position at TNM. We may also collect information from reference checks that you provide as part of your application or from recruitment agencies.
• Information you provide to us through our social media accounts. TNM is present on social media platforms, such as Facebook, Instagram, and LinkedIn. When you interact with our social media accounts, for example, if you “like” our page or make comments, we may collect certain information about you, such as your name and profile picture. The information we collect depends on what these social media platforms share with us based on the privacy settings you have selected. We suggest you consult the privacy policies of these social media platforms to learn more.
• Geolocation and Technical information when you visit our Sites. When you visit our Sites, we may collect technical information electronically (through the use of cookies or the use of digital ID verification tools, for example) about your browser or device and your use of the Sites. This information may include information about your visit to or use of our Sites, including the IP address of your device or computer, user location, and the browser you used to access our Sites. This will allow us to, among others, present and offer you the rates or other offerings in your location or region. To learn how to limit the type of information we collect, use or disclose about you when you visit and/or use our Sites, please see “What Are Your Privacy Rights?” section below.

For example, we use Google Analytics, which allows us to obtain information about your online activities, including which pages you viewed, the source of your visit and the time spent on our Sites. You can disable the use of Google Analytics by visiting the Google Analytics opt-out page.

• Video surveillance and call recording. As a security measure for visitors and occupants of our premises and to maintain the security of our buildings, we can use video surveillance at various locations in our premises. If you call our customer service, we may also record calls for quality and training purposes.
• Credit and background checks. If you apply for a job or for our products and services, we may perform a credit and background check with your consent.
• Other information about your interactions with us. We may collect information about any other interactions you may have with us (including any transactions, communications or requests you may have).

How Do We Use Personal Information?

We may use your personal information for the following purposes, or otherwise with your consent or as permitted or required by law:

• To process and evaluate your application to our products and services, including processing your application, and executing credit checks (with your consent).
• To ensure and improve our operations and the performance of our Sites, for example, by analyzing your use of them, generating reports and ensuring their proper functioning.
• To manage our business activities, for example, to improve our business strategies or to detect fraud (or other illegal activities) and ensure the security of our IT systems.
• To communicate with you, for example, to respond to information requests, chat messages (including via chatbots), or other inquiries or to send you marketing communications and inform you about our products or send you personalized offers (e.g., newsletters, etc.). At any time, you may withdraw your consent from receiving such marketing communications and personalized offers via the procedure detailed in the section “What are your privacy choices?”
• For security purposes, for example, to identify you, and investigate incidents in the products and services, as well as to prevent loss.
• To process your job application, including reviewing your application and assessing your suitability for the job you are applying for or for other positions that match your profile, obtaining and verifying information or references about you from third parties (with your consent) and to inform you of job offers that may be of interest to you.
• To anonymize your personal information for research and investigation purpose. We may anonymize or de-identify your personal information.
• For other purposes permitted or required by law. We will not use personal information for any other purpose without your consent, unless we are legally permitted or required to do so by law, for example, to comply with a legal obligation or to protect the rights, including property rights, and interests of TNM.
• To make automated decisions about you: We may use your information to make automated decisions about you. We may do so to respond to your application to our products and services, or for marketing purposes. As required, we will inform you of any such use during the process or when the decision is communicated to you. We will refer you to the team responsible for the decision rendered if you have any questions. Please note that a decision will be considered as being automated when no individual has intervened in a significant manner in the decision-making process.

How Do We Share Personal Information?

Your personal information may be disclosed in the following contexts in order to achieve the purposes set out in this section:

• With our employees. Certain of our employees may have access to your personal information in the context of their functions and on a need-to-know basis only.
• Affiliates and Partners. We may share your personal information with TNM affiliates for the purposes described in this Policy. For example, our human resources department could share your application with our affiliates.
• Service providers. We hire companies and individuals to perform certain tasks on our behalf and/or to provide us with services. These service providers may fall into different categories such as accounting, financial, tax, marketing (including digital, behavioural advertisements, commercial electronic messages and social media platforms), legal consulting, website hosting, customer service, and IT or software solutions. These service providers have access to the personal information necessary to fulfill their duties, but may not use this information for any other purpose.
• Protecting the interests of TNM and third parties. We may disclose personal information when we believe it is appropriate for the purposes of complying with the law, enforcing our agreements, or protecting the rights, title deeds or safety of TNM, its clients or other parties.
• Commercial transactions. We may disclose and transfer personal information in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any part of our business, assets or shares (including in connection with bankruptcy or similar proceedings), but only to the extent that your personal information is necessary for such transactions, in which case we will comply with applicable legal requirements.
• Other situations. We may share your personal information in other situations, in which case we will inform you of such practices and obtain your prior consent (or as required or permitted by law).

What Types of Cookies Are Used by TNM?

Cookies are small pieces of data (text file) that are saved on your computer or mobile when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. Cookies may be temporary (or “session”) cookies, which are only in use while you visit our Sites and are deleted when you close your browser, or permanent cookies, which stay on your device’s permanent storage after you leave our Sites until you delete them manually or your browser deletes them after a period of time. Cookies that are set by us are called first-party cookies. We also use third-party cookies, which are cookies from a domain different than the domain of the Sites you are visiting.

Our Sites primarily use the following four types of cookies:

• Necessary cookies: These cookies are necessary for our Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but that may cause some parts of the Sites to not work.
• Functional cookies: These cookies are used to recognize and remember your preferences, sharing content of the Sites on social media platforms, collecting feedback and other third-party features. For example, functionality cookies may use information, such as your language preferences, to make sure that you arrive at a version of our Sites that will provide you with a continuous experience.
• Analytics cookies: These cookies are used to understand how visitors interact with our Sites. For example, analytics cookies will provide information on metrics such as the number of visitors, bounce rate, traffic source among others. We use various tools for these purposes. For instance, we use Google Analytics to learn more about the visitors on our Sites and their activities on our Sites. To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to information regarding your visit (such as the pages you visit and length of your visit), information about your device (such as your IP address), how you got to the Sites, and other information about you. Google Analytics has developed an opt-out tool that will prevent Google Analytics from tracking you across all websites, which is available here: https://tools.google.com/dlpage/gaoptout/.
• Performance cookies: These cookies are used to understand and analyze key performance indexes of our Sites to help deliver a better user experience. For example, performance cookies tell us which pages are popular, monitor traffic to our Sites and compile anonymous analytic information. Performance cookies can also be used to identify and remedy operational problems with the Sites.
• Advertisement Cookies: These cookies collect information about your browsing habits and are generally placed on our Sites by our advertising partners, which include social media platforms. They may be used by those companies to build a profile of your interests, show you relevant advertisements on other websites and analyze the efficiency of the advertisement campaign.
• Uncategorized cookies: The Sites may include cookies that are uncategorized. Those cookies are being analyzed and have not been classified as yet.

When using our Sites, you may be directed to other websites for such activities as surveys, for job applications, and to view content hosted on those websites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our Sites.

What Are Your Privacy Choices?

By providing us with personal information when using our Sites, you consent to the collection, use and disclosure of your personal information in accordance with this Policy. In some cases, your consent may be “implied”, meaning that your consent is presumed based on your action or inaction at the time of collection, use or sharing of your personal information. We usually obtain your consent when we want to use personal information for a new purpose or for a purpose other than those indicated at the time of collection in this Policy, in accordance with applicable privacy laws.

You can choose how we treat your personal information:

• Changing your browser settings. We use technologies such as cookies to improve your experience on our Sites. Thanks to technologies such as cookies, our Sites can recognize you when you use or return to them and can facilitate your experience (for example, memorizing the language of our Sites, displaying videos). You can remove or disable some of these technologies at any time via your browser and the cookie banner. However, if you do, you may not be able to use some of the features of our Sites.

Please refer to your browser's instructions, help screen or cookie banner for information on how to block, delete and manage cookies on your computer or mobile device.

You can deactivate Google Analytics by downloading and installing the Google Analytics Deactivation Browser Add-on for your browser.

• Withdraw your consent. You may withdraw your consent to the collection, use and disclosure of your personal information in accordance with this Policy at any time by sending us a request in accordance with the information provided in the “Complaints and Questions” section below, subject to legal or contractual restrictions. Withdrawal of your consent may affect the provision of the services you receive or would like to receive, as the continued use and disclosure of your personal information may be necessary to make the service available to you. In some circumstances, legal requirements may prevent you from withdrawing your consent.
• Marketing communications. You may withdraw your consent to receiving marketing communications or other personalized offers at any time by either logging into your account and changing the preference settings or via the unsubscribe mechanism included in such communications and offers. You can also contact us at the contact information listed in the “Complaints and Questions” below to make such request.

What Are Your Privacy Rights?

The rights described above may be exercised in accordance with the requirements and restrictions provided by law:

• Your right of access: you have the right to ask us if we use or retain your personal information. You may also request copies of this personal information.
• Your right to rectification: you have the right to ask us to rectify personal information that you consider inaccurate or equivocal, and to complete information that you consider incomplete. You may also have the right to request rectification of your personal information if the collection, disclosure or retention of such information is not permitted by law.

To exercise your rights, you may make a request to that effect in your account or by contacting our TNM Privacy Officer at the email address indicated in the “Complaints and Questions” section below.

Governance Rules and Other Privacy Measures

TNM implements reasonable administrative, contractual, technical and physical safeguards to protect personal information in its custody or control from loss or unauthorized access, use, modification and disclosure.

TNM has adopted policies and practices that ensure the protection of your personal information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees throughout the information lifecycle and that limit their access to information on a need-to-know basis;
• If the information is collected or stored electronically, the establishment of technical safeguards such as firewalls, passwords, anti-virus softwares, multi-factor authentication tools and other similar measures;
• Appointment of a Privacy Officer to ensure compliance with applicable privacy laws;
• Training of employees on privacy and information security;
• A process for handling privacy complaints and inquiries, including regarding any confidentiality incidents involving personal information; and
• Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate safeguards and security standards.

Retention of Your Personal Information

TNM has processes and retention periods to ensure that we retain your personal information only for as long as is reasonably necessary for the purposes set out in this Policy or to comply with our legal obligations.

TNM is committed to making reasonable efforts to maintain users’ personal information that is accurate, complete and up-to-date to the extent necessary to achieve the purposes for which it was collected and is to be used. TNM may, from time to time, ask you to confirm the accuracy of your personal information for this purpose.

Transfer of Your Personal Information to Countries Other Than Canada

Some of our external third-party service providers are based outside of your province or territory of residence, including without limitation Canada and the United States, and their processing of your personal information will therefore result in the transfer of information outside of Canada. Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, your personal information may be subject to the laws of a foreign jurisdiction, including any law that permits or requires the disclosure of information to law enforcement or national security authorities upon request.

Complaints and Questions

TNM has appointed a Privacy Officer. If you believe that your privacy question or request has been handled in violation of this Policy, or if you would like to receive more information about this Policy, you can submit a written request to the Privacy Officer at privacy@truenorthmortgage.ca.

Updates

We may review and update this Policy as necessary to stay current with laws and regulations, new technologies and standards. Please refer to the “Effective Date” at the top of this page to find out when this Policy was last revised. If the changes we make are material, we will highlight them when required by applicable law, including by posting a notice on your account or via email before the change comes into effect. We encourage you to check this page regularly for the latest information on our privacy practices.

By continuing to use our services or to log into your account after the modified version of this Policy has been published, you agree to the changes made to this Policy.