PRIVACY POLICY
[INSERT LEGAL BUSINESS NAME]
Last Updated: [Insert Date]
1. Introduction
This Privacy Policy describes how [Insert Legal Business Name] (“we”, “us”, “our”) collects, uses, discloses, and safeguards personal information through our website, digital portals, artificial intelligence tools, electronic communications, and related services (collectively, the “Services”).
We are committed to protecting your privacy in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and any applicable provincial privacy laws.
By using our Services, you consent to the collection, use, and disclosure of personal information as described in this Privacy Policy.
2. Who We Are
Legal Name: [Insert Legal Business Name]
Trade Name (if applicable): [Insert Trade Name]
License Number(s): [Insert Mortgage License Number(s)]
Regulatory Authority: [e.g., FSRA Ontario, BCFSA, AMF Québec, etc.]
Business Address: [Insert Address]
Email: [Insert Privacy Contact Email]
Telephone: [Insert Phone Number]
You are encouraged to verify our licensing status through the applicable provincial regulator.
3. Information We Collect
We may collect personal information including:
A. Identification Information
- Full name
- Date of birth
- Government-issued identification
- Social Insurance Number (where legally required)
- Contact details (email, phone, address)
B. Financial Information
- Income and employment information
- Credit history
- Bank account information
- Asset and liability information
- Mortgage and property details
C. Property & Transaction Information
- Property addresses
- Purchase agreements
- Appraisals
- Mortgage statements
- Legal documentation
D. Digital & Technical Information
- IP address
- Device/browser information
- Usage data
- Communication metadata
- Call recordings (where applicable)
E. AI Chat & AI Phone Interactions
When interacting with our AI chat assistant, AI phone assistant, or automated intake systems, information you provide may be:
- Collected
- Stored
- Transcribed
- Reviewed
- Used to respond to your inquiry
You are responsible for the accuracy of information you provide through these tools.
4. How We Use Your Information
We use personal information to:
- Assess mortgage eligibility
- Provide mortgage brokerage or lending services
- Communicate regarding applications or transactions
- Verify identity
- Comply with regulatory obligations
- Detect fraud and prevent unlawful activity
- Improve our Services
- Maintain records required by law
We may also use anonymized or aggregated data for operational and analytical purposes.
5. AI Tools and Automated Systems
We may use artificial intelligence (“AI”) systems to assist with:
- Initial client intake
- General information responses
- Appointment scheduling
- Document collection
- Administrative support
Important Notice:
AI systems are programmed, supervised, and controlled by our business. We are solely responsible for the configuration, knowledge base content, compliance, and outputs generated by these systems.
AI-generated responses are informational only and do not constitute binding mortgage advice unless reviewed and confirmed by a licensed representative.
6. Email Communications and Third-Party Processing
Electronic communications submitted through our website (including contact forms and document uploads) may be processed or transmitted using secure third-party technology providers.
This may include:
- Email routing systems
- Document portals
- Cloud storage
- Customer relationship management systems
- AI processing tools
These providers act as service processors under contractual confidentiality and data protection obligations.
We remain responsible for personal information under our control.
7. Disclosure of Personal Information
We may disclose personal information to:
- Lenders and financial institutions
- Credit reporting agencies
- Mortgage insurers (e.g., CMHC, Sagen, Canada Guaranty)
- Appraisers
- Lawyers and notaries
- Regulatory bodies
- Fraud prevention agencies
- Technology service providers supporting our operations
We do not sell personal information.
8. Cross-Border Data Transfers
Some service providers may store or process data outside of Canada.
Where this occurs:
- Information remains subject to applicable Canadian privacy laws.
- Data may be subject to foreign legal requirements.
- We use reasonable contractual safeguards to protect your information.
9. Data Retention
We retain personal information:
- As long as necessary to fulfill the purposes identified
- As required under mortgage brokerage and regulatory record-keeping laws
- For legal, compliance, audit, or dispute resolution purposes
Retention periods may extend beyond the completion of a mortgage transaction.
10. Security Safeguards
We implement reasonable administrative, technical, and physical safeguards including:
- Encrypted communications
- Secure document portals
- Access controls
- Authentication procedures
- Secure cloud storage
However, no electronic transmission or storage method is completely secure. By using our Services, you acknowledge inherent internet security risks.
11. Your Rights
You may:
- Request access to your personal information
- Request correction of inaccurate information
- Withdraw consent (subject to legal and contractual restrictions)
- Request details about how your data is used
Requests must be submitted in writing to the Privacy Officer listed below.
12. Cookies and Tracking Technologies
Our website may use:
- Cookies
- Analytics tools
- Session tracking
- Performance monitoring tools
You may disable cookies in your browser settings; however, this may affect website functionality.
13. Limitation of Liability
We provide digital tools, including automated intake systems, communication platforms, and AI assistants, to enhance client service.
We are responsible for our compliance with applicable privacy laws.
However:
- Users are responsible for the accuracy of information submitted.
- AI tools may generate preliminary or automated responses.
- Mortgage approval decisions are made by lenders, not by automated systems.
- We are not liable for decisions made by third-party lenders or financial institutions.
Nothing in this policy limits statutory rights under applicable law.
14. Changes to This Policy
We may update this Privacy Policy from time to time.
The updated version will be posted on this website with a revised “Last Updated” date.
Continued use of the Services constitutes acceptance of the updated policy.
15. Privacy Officer Contact Information
Privacy Officer: [Insert Name or Title]
Company: [Insert Legal Business Name]
Address: [Insert Address]
Email: [Insert Privacy Email]
Phone: [Insert Phone]
IMPORTANT NOTICE TO WEBSITE OWNER (REMOVE BEFORE PUBLISHING)
This template must be customized with:
- Legal business name
- Provincial license number(s)
- Regulator
- Business address
- Contact details
- Any province-specific disclosures required
Failure to properly customize this document may result in non-compliance with applicable mortgage brokerage regulations.