PRIVACY POLICY

Last updated: Revised September 8, 2022

Scope

This policy applies to Felipe Sanchez Kaso Management Inc (“We”, “Us” and “Our”), and describes how we collect, use and disclose personal information.

This Privacy Policy covers the personal information we collect, use and disclose from our websites, mortgage applications and inquiries that are sent to us. It also covers personal information that we collect, use and disclose in any other way. Personal Information” means any information about an identifiable individual, subject to more specific definitions or interpretations under applicable law. Personal information generally includes name, address, email address and financial information relating to an individual, but does not generally include contact or business information.

This Privacy Notice does not affect the personal information of employees, temporary or permanent staff, consultants or other persons performing work with us. In addition, this notice does not affect any information that is not “personal information” as defined or interpreted under applicable laws.

Our Commitment

We are committed to protecting Personal Information and to collecting, using and disclosing it only in accordance with applicable privacy laws.

Consent

We collect, use and disclose your personal information with your consent (which may be express or implied) or as required or permitted by law. By providing us with your personal information (through our websites or otherwise), you consent to our collection, use and disclosure of that personal information in accordance with this Policy. Subject to legal requirements and contractual obligations and upon reasonable notice, you may withdraw your consent to our future collection, use and disclosure of your personal information by contacting our Privacy Officer at the address below. If you do not agree with the terms of this policy or withdraw your consent, we may not be able to provide you with certain products, services or information.

Nature of Information Collection

Where appropriate, we obtain personal information directly from you or from our interactions with you, but we may also obtain your personal information from other sources, including mortgage brokers and agents in our network, as well as from consumer reporting agencies, credit bureaus, financial institutions and real estate appraisers. The personal information we obtain may include the following: your name, address, e-mail address, financial information, credit history and other information that is relevant to the products and services we offer you, that is relevant to a mortgage application or that is included in an inquiry sent by you, either directly or through one of the mortgage brokers or agents in our network. We limit the collection of your personal information to that which we need for the purposes we describe below or as required or permitted by law.

Why we collect, use and disclose personal information

We collect, use and disclose your personal information in order to:

– Provide you with products and services;

– Process mortgage applications and inquiries that you send to us through one of our mortgage brokers;

– To facilitate your relationships and transactions with mortgage brokers and users of our products and services;

– To learn about your needs and preferences in order to serve you better, including recommending products and services that are particularly suited to your needs;

– To develop, market, sell or provide our products and services;

– To establish and maintain a business relationship with you, including establishing your identity and performing contractual obligations;

– Obtain information about your credit history, in the event you apply for credit or a mortgage;

– To process payments related to your purchase of our products and services;

– To develop, manage and improve our business and operations;

– Protect us from error, breach of contract, negligence, fraud and illegal activity;

– To enter into business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposition, securitization of financing, in which we or any part of our business participates;

– Prevent, discover and investigate violations of this Privacy Policy or other terms of service or use, and fraud and other matters; and

– To comply with legal or other regulatory requirements.

If we need your personal information for other purposes, we will tell you why and obtain your consent if required by law.

Disclosure of Personal Information

It is our policy not to disclose or sell your personal information without your consent, except as otherwise provided herein or as authorized or required by law.

If you send us a mortgage application or inquiry, either directly or through one of our mortgage brokers, we may disclose your personal information to third parties such as lenders, insurers, credit bureaus. We may also disclose your personal information to our brokers and their respective affiliates for the purpose of processing your loan application or inquiry.

From time to time, we may disclose your personal information to service providers we have hired to perform certain functions on our behalf or to provide services to us, including third party software providers, payment processors and web hosting services. We may perform data analysis on your Personal Information and generate reports, statistics and information using your Personal Information for publication purposes (but only in anonymous, aggregated form).

Any personal information may also be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment or other transfer of all or part of our business or assets. In the event of such a transfer, we will use reasonable efforts to try to ensure that the transferee uses your personal information in a manner consistent with this Privacy Policy.

We may also disclose your personal information to other third parties with your consent or without your consent if disclosure is required or permitted by law.

Storage of Personal Information

Your personal information is stored at our facilities or at the facilities of our direct or indirect service providers. We retain your personal information for as long as necessary to fulfill the purposes for which it was obtained or to comply with legal requirements.

Employment Applications

If you apply for a job with us, we will use the personal information we collect in connection with your application to evaluate your application and decide whether to offer you a position. If you accept a position with us, the personal information will be retained in accordance with our privacy practices relating to the personal information of our employees. If we do not offer you a position or if you do not accept our offer of employment, we will retain your personal information for a reasonable period of time in the event that a suitable position becomes available or in the event that you reapply for employment with us.

Location of storage or processing

We and our service providers may store or process your personal information in Canada and, to the extent permitted by applicable law, in the United States or other territories. Personal information that is stored or processed in foreign jurisdictions may be subject to different laws and legal requirements than those in Canada.

Legal Considerations

We and our service providers may disclose your personal information in response to a search warrant, subpoena or other legally valid warrant or request for information. We may also disclose your personal information to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. Finally, we may disclose your personal information as necessary to establish, exercise or defend legal claims, or as otherwise permitted by law.

Information obtained through your use of our websites and software applications

Like many other companies, we use various technologies to collect information and track your activity when you visit our websites and use our software applications. For example, we may use cookies (small files sent to your browser to store information) or web beacons (invisible images placed on certain pages of our websites) to collect personal information about your use of our websites. We may also obtain analytical data and information relating to your use of our websites and software applications, such as your IP address, the browser, device and operating system you are using, the URL that directed you to our website, your physical location, the pages of the websites and software applications you visit, the duration and nature of your use, and the time of day you access the websites and use the software applications.

The information we collect allows us to track your activities on our various websites and software applications and to improve your user experience and the functionality of our websites and software applications. We may also use this information to market certain products or services to you or to tailor our websites and software applications to your user profile. We may also use this information to create aggregated and anonymous information to determine which features are most popular and useful to our users, and for other statistical purposes.

Safeguards

We protect personal information in our custody and control from loss, misuse, unauthorized access and alteration using reasonable physical, organizational and technological security measures.

To the extent that we have arrangements with our service providers to store or process your personal information on our behalf, it is our policy to require them, by contract or other means, to provide comparable protection when storing or processing your personal information. However, these service providers may have their own privacy policies.

While we believe that these safeguards are reasonable and comparable to the safeguards provided by similar service providers, we cannot guarantee that they will be sufficient to protect the privacy and security of your personal information in all circumstances.

Access, Correction, Inquiries and Complaints

If you wish to access or correct your personal information in our custody or control, or if you have any questions or complaints about our personal information practices under this Policy, please contact

Privacy Officer

1060 Michèle-Bohec Boulevard, Suite 101
Blainville, QC J7C 5E2
[email protected]

Changes

This policy may be revised periodically. Simply contact us at the above address, email address or telephone number to obtain an updated copy of this policy.

Last updated: Revised September 8, 2022