YOUR PRIVACY IS PROTECTED
WHAT IS PERSONAL INFORMATION?
“Personal Information” is information about an identifiable individual. It includes an individual’s name, residential address and telephone number, e-mail address, age and gender, personal financial records, identification numbers including their social insurance number, personal health information, and personal references. Certain publicly available information, such as business contact information or a public directory listing of individuals’ names, addresses, and telephone numbers, or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered to be Personal Information.
WHAT INFORMATION DOES MCAN COLLECT?
The types of Personal Information that we may collect include:
- your contact information, such as your address, telephone number, e-mail or other electronic address, social media account name, and fax number;
- information that we can use to identify you and/or that we require to meet tax, anti-money laundering and other “know your client” legal and regulatory obligations, such as your Social Insurance Number (SIN), date of birth, occupation, and certain other information set out on government-issued identification that you may provide to us;
- your credit and financial information such as employment history, income sources, assets, liabilities, credit history, and payment preferences;
- information regarding your business relationship with us, including information related to agreements that you have entered into with us, your preferences, advisors and decision-makers, and any feed-back or other similar information that you have provided to us;
- certain transactional information such as your payment history, and information about which products or services you use and how you use them, or how you otherwise do business with us;
- information such as your language and other communication preferences, your location, certain demographic information about you, information about your interests, and other information that helps us to understand more about you including how you like to do business and what types of products, services or offers you may like;
- information to understand your current and future needs in relation to the products and services provided by us, which we collect through means such as client surveys and other forms of market research and analysis; and
- certain other information that we may request when you apply for a product or service with us to help determine your eligibility for the product or service, such as information requested pursuant to our mortgage commitment letters or credit applications.
We collect Personal Information when it is provided to us. MCAN may collect Personal Information directly from the person to whom the Personal Information relates, such as when you apply for a product or service with us. MCAN also collects Personal Information from third parties, such as brokers, or individuals that are opening an account to be operated on behalf of a third party, in accordance with money laundering legislation, provided that such third parties have obtained consent from the individual to whom the information relates to provide this Personal Information to us. In most circumstances where the Personal Information that we collect is collected from a third party, we will obtain your permission before we seek out this information unless we are authorized by law to collect this information without your consent. If we do not obtain your permission, we take reasonable steps to ensure that such third parties have your consent to share your Personal Information with us. If you refuse to provide us with certain Personal Information, we will not refuse to provide you with a product or service unless we are unable to provide it without this information.
COLLECTION OF NON-PERSONAL INFORMATION
We collect certain non-Personal Information which is recorded by the standard operation of our internet servers on an anonymous basis, such as your IP address, the operating system you are using, the sections of the Site you visit, and the Site pages read and images viewed. This non-identifiable information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes, (ii) to improve the Site, (iii) to conduct internal reviews of the number of visitors to the Site (iv) to help us better understand visitors’ use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary. We do not use your IP address to identify you.
When you view the Site, we collect and store some information on your computer. This information will be stored in a “Cookie,” which is a file created on your computer’s hard drive, and will help us in many ways. For example, Cookies allow us to tailor the Site to better match your interests and preferences. With most Internet browsers, you can erase Cookies from your computer hard drive, block the creation of Cookies, or receive a warning before a Cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Our Site may use Web beacon, gif, or other technologies. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with Cookies. If you don’t want your Cookie information to be associated with your visits to these pages, you can set your browser to turn off Cookies. If you turn off Cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable Cookie information and are disregarded.
How do we Use Personal Information?
We may use Personal Information for the following purposes:
- to verify your identity, and to protect you and us from error, fraud or other misrepresentations;
- to support and maintain the accuracy and integrity of the credit reporting system, which includes clients’ past credit and repayment history, as well as other financial transactions;
- with respect to your SIN, for income tax reporting purposes in certain situations, or to verify information provided by credit bureaus;
- to determine your initial and ongoing eligibility for financial products, and provide you with information about such products;
- to investigate specific transactions or patterns of transactions for the purpose of detecting unauthorized or illegal activities;
- to verify your instructions;
- to investigate your complaints;
- to implement risk management programs;
- to provide specific services associated with an account; and
- to understand your current and future needs.
We will only collect and use as much of your Personal Information as we require to fulfill the purposes for which the Personal Information is being collected, unless we are required or permitted by law to collect and use additional information. We will notify you of the purpose or purposes for which we are collecting the information at or before the time that we collect the Personal Information so that you may choose whether to provide us with Personal Information for those purposes. We may provide this notice either orally or in writing. If we intend to use the Personal Information that we have collected for a new purpose that we have not previously disclosed to you, we will communicate the new purpose prior to using the information for the new purpose and obtain your consent to use the information for the new purpose, unless we are required or permitted by law to use the information for this new purpose without consent. Other than as required or permitted by law, your Personal Information will not be used for any other purpose without consent. You may also withdraw your consent to our collection, use or disclosure of your personal information, subject to legal or contractual restrictions, upon providing us with reasonable notice. We will inform you of any implications at the time of your request.
Sharing Personal Information
We will not share your Personal Information with anyone, other than as described in this Policy, or unless we are permitted or required to do so pursuant to applicable laws. If we wish to disclose your Personal Information for a purpose that has not previously been consented to, we will ask for your consent before disclosing your Personal Information for that purpose, unless we are permitted or required by law to disclose this information without consent. MCANdoes not sell or rent listsof our clients or any other Personal Information to others fortheiruse. From time to time, we may share your Personal Information with third party suppliers who provide services on our behalf, or with business partners, as required for the provision of products and services to you. For example, our third party suppliers and business partners may use your personal information to print statements, collect accounts, operate payment services, provide client services, perform account due diligence or general account administration, and process transactions on our behalf. We select third party suppliers and business partners carefully and ensure through contractual means that they protect Personal Information in a manner that is consistent with our privacy policies and practices and security standards, and comply with applicable privacy laws. These third party suppliers and business partners will only be provided with as much Personal Information as they require to fulfill the purposes for which Personal Information is being shared. In some cases, these third party suppliers and/or business partners may be located outside of Canada, and therefore Personal Information that has been collected by us may be transferred, processed and stored outside of Canada. Under the laws of foreign jurisdictions, in certain circumstances foreign courts, government authorities, regulators, or law enforcement agencies may be entitled to access this Personal Information without notice.
SAFEGUARDING YOUR PERSONAL INFORMATION
We use appropriate safeguards to secure and protect Personal Information that is in our custody and/or control to protect against unauthorized use, alteration, duplication, destruction, disclosure, loss or theft of, or unauthorized access to your Personal Information. We use physical, technical, and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question, such as secure locks on filing cabinets and doors, and restricted access to our information processing and storage areas. Also, we limit access to Personal Information to authorized employees, business partners, and third party suppliers who have a legitimate business purpose for accessing it, through contractual means, through the use of pass keys and computer passwords and, where necessary, the encryption of electronically transmitted information. We only retain Personal Information for as long as it is needed to meet the purposes for which it was collected, unless we are required pursuant to applicable laws to retain this information for a different period of time. We have procedures in place to ensure that Personal Information is securely disposed of.
CORRECTING YOUR PERSONAL INFORMATION
We want to make sure that the information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information unless it is necessary for us to do so to fulfill the purposes for which we collected the information, or unless we are otherwise required to update this information. Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
ACCESS TO PERSONAL INFORMATION
If you have any questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse you access to such information. You may write to or email our Privacy Officer at the address below to request access to Personal Information that we have about you. We will respond to requests within the time periods set out in Privacy Laws.
QUESTIONS OR CONCERNS
MCAN is accountable for all Personal Information that is in our custody or control, and we have designated a Privacy Officer that is ultimately responsible for the handling of this information, and for ensuring that we are complying with this Policy. The contact information for the Privacy Officer is set out below. Ifyou have privacy questions, concerns or complaints, or if you would like more information about our privacy policies and practices please contact the Privacy Officer using the following contact information:
Privacy Officer, MCAN Mortgage Corporation
200 King Street West
Toronto, ON, M5H3T4
You may also contact XCEED’s main line by calling 1-888-811-6660, and ask to speak to a customer service representative.
If you have any questions about your privacy rights, or any complaints, you may also contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Tower B, 3rd Floor
Ottawa, ON, K1A 1H3
Date: May 30, 2014