Privacy
Policy
At
Verico Designer Mortgages Inc, (herein after referred to as “VERICO Broker”),
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 confidence 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 or other product through VERICO Broker or
VERICO Broker affiliates and is provided to, or collected by, VERICO Broker and
its staff or by VERICO Broker's agents, associates, and affiliates on VERICO
Broker's behalf (collectively, “VERICO Broker”).
Why
VERICO Broker Collects Personal Information
VERICO
Broker collects and uses Personal Information for the following purposes:
•
Provide mortgage brokering 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 approved by VERICO Broker 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 VERICO Broker 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 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 VERICO Broker means that they
agree and consent that VERICO Broker can collect, use and disclose such Personal
Information in compliance with this Privacy Policy. VERICO Broker 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 practicable, 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 VERICO Broker's ability to
provide the Client with mortgage services. A member of VERICO Broker 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
VERICO Designer Mortgages Inc.
5 – 1253 Silvan Forest Drive
Burlington, On L7M 0B7
Tel:
905 336-5997
Use
and Disclosure of Personal Information
We
will use a Client’s Personal Information to provide financial advice and
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 VERICO Broker Collects Personal Information". Under certain
circumstances, VERICO Broker 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 VERICO Broker, 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 its consent.
Under
certain circumstances VERICO Broker 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 VERICO Broker 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 VERICO Broker engages a third party to provide administrative or support
services to us (such as computer back-up services, shredding or archival file
storage) and the third party is bound by our Privacy Policy;
•
protection of VERICO Broker's best interests;
•
protection of public interests 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; or
•
if the information is already publicly known.
Limiting
collection and retention of Personal Information
VERICO
Broker 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.
VERICO
Broker 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 our governing regulatory bodies and/or any other legal
requirement, statutory or otherwise, from time to time.
Accuracy
VERICO
Broker 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
VERICO
Broker endeavors to maintain adequate safeguards to protect against loss, theft,
unauthorized access, disclosure, copying, use or modification of Clients’
Personal Information in the care of VERICO Broker. VERICO Broker 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
VERICO
Broker. 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
VERICO
Broker 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.
VERICO
Broker will provide a Client access to their Personal Information. The Client may
correct or amend any inaccuracies in the Client’s Personal Information.
VERICO
Broker 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 vexation or frivolous;
•
To protect our firm’s rights and property.
Changes
to Privacy Policy
VERICO
Broker will from time to time review and revisit privacy practices and this
Privacy Policy.
VERICO
Broker 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.
Communicating
With VERICO Broker
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 128 bit 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 consultant/broker/agent handling the matter about alternative
arrangements.
Attn:
Chief Privacy Officer
VERICO Designer Mortgages Inc.
5 – 1253 Silvan Forest Drive
Burlington, ON L7M 0B7
Tel:
905 336-5997
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