PRIVACY POLICY

Last updated: October 3, 2024

Cameron Stephens Mortgage Capital Ltd. and its affiliates and related entities (“CSMC“, “we“, “us“, or “our“) are committed to respecting and protecting the privacy of the personal information we obtain from you when accessing and obtaining our products and services, accessing or using our website, found at https://cameronstephens.com/, including our investor portal found at https://csconnect.ca/login (collectively, our “Website“), or interacting with any of our social media accounts including on Facebook, Instagram, LinkedIn and X (collectively, the “Services“).

We have created this privacy policy (this “Policy“) to inform you about how we collect, use and share your personal information, and about our privacy practices in general. This Policy also describes your rights and the decisions you can make about your information. Our employees and contracted employees are required to comply with this Policy.

For the purposes of this Policy, “personal information” means information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact or locate a single person.

ACCEPTANCE OF THIS PRIVACY POLICY

By submitting your personal information to us or by otherwise using our Services, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Policy.

We reserve the right to amend this Policy at any time by posting a revised version on our Website. We recommend that you check our Website periodically to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the top of this Policy. Depending on the circumstances, we may also decide to send you a notice electronically that this Policy was changed. If you continue to access or use our Services after this Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.

This Policy should be read together with our Website Terms of Use which can be accessed at: TERMS & CONDITIONS

APPLICATION OF PRIVACY POLICY

This Policy applies to all personal information we collect, use and disclose in the course of our business, in accordance with applicable laws and regulations. This Policy applies where we collect personal information, however accessed and / or used, whether via personal computers, mobile devices or otherwise provided to us directly by you or another authorized party.

INFORMATION WE COLLECT AND HOW WE COLLECT IT

We collect your information by lawful means and, where appropriate, directly from you. Wherever possible, we limit the amount of information we collect, use or disclose to that necessary and appropriate to more efficiently operate our business.

We may collect the following information from you by phone, email, in person, by application, through our Website and by other means in the following contexts:

Directly From You:

When you provide us with your personal information for any purpose, such as accessing our Services, uploading or submitting information or applications through our Website or by email, making a complaint, or contacting us to obtain our Services, including over the phone, by fax and/or email, you may voluntarily provide us with certain personal information. For example, to facilitate a loan request and to comply with our legal obligations, we may require that you provide us with various supporting documents in connection with a loan request and information listed in our standard forms such as our know your client (KYC) form and personal net worth statement. These forms request information such as your first and last name, date of birth, address, phone number, e-mail address, social insurance number, your marital status, spouse’s name (if applicable), whether you have any dependents, employment information, and financial information. We may also ask for a copy of your passport, drivers’ license or other form of government issued identification.

Surveys: Occasionally, we may ask you to complete an optional survey where you may be asked to submit certain personal information for identification purposes and to better understand your feedback.

Automated Collection: When you use our Website, we use cookies and other automatic data collection technologies to collect certain information to improve your use of the Website and as further described under the heading “Use of Cookies”, below.

Electronic Communications: If you sign up for e-mail, text, “SMS” or other electronic communications, including to receive a copy of our newsletter, we will collect and use the information that you provide to us in accordance with this Policy.

Support Services: If you e-mail, fax, write to us or otherwise contact us, we collect your name and contact information in order to respond to your request.

OBTAINING CONSENT

We obtain your consent before we collect, use or disclose your information. Normally, we ask for your consent in writing, however, in some circumstances we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us, such as by agreeing to applicable terms of use and/or by accessing our Services.

Subject to our legal and contractual requirements, reasonable notice, and any applicable laws, you may refuse, alter or withdraw your consent to certain of the identified purposes at any time by contacting our Privacy Officer (see end of this Policy for contact information). The period of reasonable notice will vary depending on the nature of the information and its purpose.

If you provide us or our service providers with personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such information for the purposes set forth in this Policy.

There may be circumstances where you have provided information for an identified purpose, and we later need to use that information for a different purpose. In such circumstances we will seek your consent to use the information for the new purpose.

HOW WE USE YOUR INFORMATION

Will will only use your personal information for purposes that a reasonable person would consider appropriate in the circumstances. We may use the personal information we collect about you to:

  • Assist us with providing you with our Services, and a positive and secure experience on our Website;
  • Verify your identity and process loan applications;
  • Assess a company’s ability to obtain a requested loan;
  • Evaluate your ability to meet your financial obligations in connection with a loan;
  • Understand your financial service requirements and determine the suitability of Services for you;
  • If an application you are associated with is successful, to administer the loan and provide ongoing services;
  • Communicate with you for purposes you have separately indicated when you signed up to our Website, newsletter or contacted us;
  • Provide you with details about new Services and other important information;
  • For the management and administration of our business, and to address problems with, and to improve, our Website design and Services;
  • For administrative purposes such as creating and maintaining business records and risk management;
  • Identify and protect against fraud, the integrity of the credit-granting system and other criminal activities;
  • Comply with legal or regulatory requirements (including know your client (KYC) and anti-money laundering (AML) requirements);
  • Carry out our obligations and enforce our rights arising from any contracts we may have with you or to comply with our legal, regulatory requirements and professional obligations;
  • Fulfill the purposes for which you provided the information or that were described when it was collected; and
  • For any other purpose with your consent.

We may use personal information for other purposes with your consent or as permitted or required by law.

SHARING YOUR INFORMATION

We share the information we collect about you with certain individuals that you connect and communicate with at CSMC (such as employees working at CSMC who provide you with our Services).

We only disclose your information as described in this Policy, with your consent, or as otherwise permitted or required by law, solely in connection with the purposes for which the personal information was collected. Under certain circumstances, we will disclose your information, including:

  • With our service providers, such as those we rely on to host our Website, in order to enable those service providers to carry out work on our behalf;
  • With our financial, insurance, legal, accounting or other advisors that provide professional services to us;
  • With credit bureaus, credit reporting agencies, financial institutions, private lenders, and service providers (including their respective agents and representatives), in order to determine and verify, on an on-going basis, the continuing eligibility for your associated loan and ability to meet financial obligations;
  • When necessary to comply with court orders, regulatory rules, or to satisfy our insurance requirements; and
  • In connection with a business transaction involving CSMC.

To the extent we enter into arrangements with service providers to store, handle or otherwise deal with personal information on our behalf, such as for data processing, document storage software support and office services, we require such parties (by contractual or other means) to provide comparable privacy protection while the information is processed or handled by them and to only use your information to perform the services we have specified and with the same standards set out in this Policy.

If we disclose your personal information in connection with a business transaction for the sale of CSMC or any of its substantial assets, we may disclose personal information, including Employee Personal Information (described below), only as necessary in connection with the transaction, and provided that the party to which we disclose the personal information is bound by an agreement to only use or disclose the personal information for the purposes for which it was collected, used or disclosed by CSMC.  CSMC will notify you that the transaction has occurred and what personal information has been disclosed.

If we have made corrections to your personal information, we will send the corrected personal information to each organization to which we disclosed the personal information during the year before the correction was made.

Our service providers may perform activities outside of Canada. Accordingly, your personal information may be subject to the laws of a foreign jurisdiction, including the United States, and such jurisdiction may have legal requirements that require us or our service providers to disclose information to courts, law enforcement, or other governmental authorities.

Please note that there are circumstances where the use and/or disclosure of information may be justified or permitted or where we may or must disclose information without your consent, in accordance with applicable law. For example, we may disclose your information to a government institution that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity. Where obliged or permitted to disclose information without consent, we will try not to disclose more information than is required for such purpose.

Under no circumstances do we sell your information to other companies for their own use.

RETENTION, STORAGE AND SECURITY OF YOUR INFORMATION

We retain your information to the extent necessary for the purposes for which it was collected as described in this Policy, to comply with applicable laws, and for reasonable backup, audit, or similar purposes.  Information about our policies practices and processes for complying with applicable privacy laws is available upon request.

Your information is stored in secured locations and on servers controlled by us, located either at our facilities or at the facilities of our service providers. We use safeguards applicable to our industry to protect the security of information in our possession, including physical, organizational and technological measures. Measures include: (i) security of our premises; (ii) limiting access to files that contain personal information; (iii) technological safeguards; and (iv) internal password and security policies. Sensitive personal information will be accorded a higher level of protection commensurate with its level of sensitivity.

We will destroy records containing personal information, or remove the means by which that personal information can be associated with you, as soon as it is reasonable to assume that the personal information is no longer necessary for the purpose for which it was collected, and retention is no longer necessary for legal or business purposes.

While we take appropriate measures to protect your information, no method of transmitting or storing information is completely secure. There is always a risk that it may be lost, intercepted or misused. We make no warranty with respect to the integrity of any electronic communications between us and you or with respect to the security of any such communications.

YOUR RIGHTS AND CHOICES

Ensuring your personal information is accurate and current is important to us, and we respect the rights you have with respect to your personal information. At any time you may contact us to:

  • request access to your personal information and to obtain a copy of it;
  • request information about the ways in which we are using your personal information, and the names of the individuals and organizations to whom your personal information has been disclosed;
  • unsubscribe from our email communications or promotional materials;
  • request a correction of your personal information in the event we hold incomplete or inaccurate information about you; or
  • withdraw your consent for our use and disclosure of your personal information.

If we are likely to disclose your personal information to another organization, or use your personal information to make a decision that affects you, we will use reasonable efforts to ensure that that personal information is accurate and complete.

While you are generally permitted to withdraw your consent on reasonable notice to us, legal or contractual restrictions may require us to use or retain your personal information for a certain period of time. We will advise you if this is the case. As such, we may continue to use your information as may be required to provide you with our Services, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent to use and disclose this information, we may no longer be able to provide you with our Services.

When you make a request, we may require you to provide sufficient personal information to allow us to identify you. If you are unable to provide proof of your identity, we reserve the right to refuse to send you any personal information. If you contact us about your personal information, we will respond to your request within a reasonable time.

In order to cover costs, we may charge you a minimal fee for accessing your personal information (we will let you know in advance if any fees are applicable to your request and will have you confirm before we proceed), unless it is information that has been collected for the purpose of establishing, managing or terminating our employment relationship with you, in which case no fee will apply.

You can always unsubscribe from receiving promotional e-mails from us by simply clicking the ‘unsubscribe’ link provided at the bottom of every promotional e-mail from us.

BEING DENIED ACCESS TO YOUR PERSONAL INFORMATION

Your rights to access your personal information are not absolute. We may deny access when: (i) denial of access is required or authorized by law; (ii) information relates to existing or anticipated legal proceedings against you; (iii) granting you access would have an unreasonable impact on other people’s privacy; (iv) protecting our rights and property; and (v) your request is frivolous or vexatious. We will inform you of the reasons and the legal basis for any refusal.  Inquiries regarding any refusal may be directed to the privacy officer identified below.

USE OF COOKIES

We use browser tracking cookies (or “cookies”) on our Website. Cookies are small text files that are put on the hard disk of a user’s computer by a website. They are unique to you and can only be read by the website or web server that assigned the cookie.

The types of cookies we may use include the following:

Strictly necessary cookies. These are required for the operation of our Website and Contact Page. They include, for example, cookies that allow you to send email messages to us for information and services. Strictly necessary cookies cannot be disabled.

Flash Cookies. Certain features of our Website may utilize local stored objects, also referred to as Flash cookies, to collect and store information about your location and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.

Analytical cookies. These cookies allow us to recognize and count the number of Website visitors and to see how visitors navigate our Website when they are using it. You may refuse to accept these cookies by activating the appropriate setting on your browser. However, if you do so, you may be unable to access certain parts of our Website. Unless your browser settings are adjusted so that it will refuse cookies, our system will issue cookies when you visit our Website.

We also use browser ‘log files’ which record certain information when you visit a website, including your internet protocol (IP) address.

To improve the user experience on our Website, we use cookies and logs files to: recognize you when you return to our Website; record activity on our Website and remember what items you have viewed or clicked on; study how you navigate our Website to help us improve the design, content and function of our Website; and customize the message, content and delivery of online banner advertisements and e-mails that reflect how you navigate to and through our Website based on your online behaviour. We call this information “Browsing Data”. We may hire third-party service providers to help us collect and analyze this Browsing Data, but your personal information is not disclosed to these third-party service providers.

LINKS TO OTHER SITES

Our Website may contain links to other websites that are not operated by us. We are not responsible for the privacy practices or the content of such other websites, including websites operated by affiliated entities. We provide such links only as a convenience and the inclusion of a link on our Website does not imply endorsement of the linked to website by CSMC. We recommend that users review the privacy policies of third-party websites arrived at from links on our sites before using those websites.

Our Website may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Website.

CHILDREN’S ONLINE PRIVACY PROTECTION

The Website is not intended for use by children under the age of 13. We do not knowingly collect or use any information from any children under the age of 13 through our Website. If we become aware that, based on our Website tracking, we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

EMPLOYEES

This policy applies to personal information that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate the employment relationship between you and CSMC (“Employee Personal Information”). In this case, “employee” includes volunteers.  Employee Personal information does not include your business contact information, or information prepared or collected by you, whether alone or in conjunction with others, as part of your employment-related responsibilities or activities.

Unless expressly permitted by law, CSMC will not collect, use or disclose your Employee Personal Information without your consent unless it is reasonable to do so for the purposes of establishing, managing or terminating your employment relationship with CSMC.  However, before we collect, use or disclose your Employment Personal Information without consent, unless otherwise permitted by applicable law, we will notify you and inform you of the purposes for which the information will be collected, used or disclosed.

QUESTIONS OR CONCERNS ABOUT THIS PRIVACY POLICY

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact our privacy officer at diana@cameronstephens.com, or by delivery in person, by courier or by mail to:

Cameron Stephens Mortgage Capital Ltd.
320 Bay Street
Suite 1700
Toronto, Ontario M5H 4A6

If you need further assistance, please contact us either by writing to us at the above address or by telephone at 416- 591-8787 x 204.

If you contact us about your personal information, we will respond to your request within a reasonable time and at no cost to you.

Information about our processes for dealing with complaints is available upon  request.

If the outcome of your inquiry with CSMC is not satisfactory, please escalate your concerns to the following office:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3

 

As regards transactions wholly within the Province of British Columbia, concerns may be addressed to:

 

Office of the Information and Privacy Commissioner for British Columbia

PO Box 9038 Stn. Prov. Govt.

Victoria, BC V8W 9A4

 

As regards transactions wholly within the Province of Alberta, concerns may be addressed to:

 

Office of the Information and Privacy Commissioner of Alberta
Edmonton Calgary
#410, 9925 – 109 Street NW Suite 2460, 801 6 Avenue SW
Edmonton, AB T5K 2J8 Calgary, AB T2P 3W2

© Cameron Stephens Mortgage Capital Ltd. All rights reserved. Reproduction in whole or in part without permission is prohibited.