A commitment to privacy and security

Wiseday, Privacy, and Your Personal Information

Your privacy, and the confidentiality of your personal information, are priorities for Wiseday. As a financial service provider, we recognize that the information you provide is fundamental to our business, sensitive in nature and that is important to you that we treat this information carefully and respectfully. This policy (“Policy”) sets out how we collect, process, disclose and use your personal information, and what your rights are with respect to this information.

This policy applies to Wiseday’s website, and any services we provide you through our site, including mortgage brokerage services and other related services (the “Services”). Furthermore, this policy also applies to your other communications with us (such as phone, text or email).

What is Personal Information?

Personal Information is information that is specific to you and includes your name, address, age and other identifiers such as your SIN, income, assets and liabilities, as well as your financial and employment records, current employment situation and other personal information defined in the Personal Information Protection and Electronic Documents Act. Personal information may also include whether or not credit is extended, the way in which you use our products and services and to whom information is disclosed.

How We Protect Your Privacy

A senior member of Wiseday’s management team, George Vouloumanos, has been appointed as Privacy Officer, and is responsible, for analyzing all personal information handling practices at Wiseday and ensuring that this Policy is up to date and in force at all times. We provide training to our employees regarding the importance of privacy, and endeavour to keep them updated with respect to the importance of your privacy and personal information. We keep our employees informed and updated periodically regarding this Privacy Policy, any updates thereto, and any other related policies or important information. Each employee and representative of Wiseday is responsible for the personal information under his or her control.

Why Do We Collect Your Personal Information

Either before or at the time we collect personal information, we will explain how we intend to use it and limit collection and use to those purposes. We will ask for your further consent before it can be used for any other purpose. We obtain most of the information about you directly from you. Additional information may be obtained via credit reporting agencies and other third party sources.

Personal information is collected to establish a relationship and to serve your financial needs. Wiseday is not a financial institution and does not currently provide loans, including mortgage loans. In the course of our brokerage services, we liaise with financial institutions in the course of providing you the Services. This means that in order to provide the Services, we need to collect personal information which the financial institutions with which we work require in order for the financial institutions to assess your eligibility for their services.

Your personal information is collected, among other times, in the following circumstances:

  • open, monitor, maintain, service and process your account
  • to verify your identity;
  • to verify telephone discussions with you, including your requests and instructions, as well as our responses to you;
  • to determine the suitability of our products and services, including through processing and analysis by third party lenders, rating agencies, and consumer reporting agencies;
  • to evaluate your application for financing, particularly with respect to credit risk and eligibility;
  • prevent, detect, or suppress financial abuse, fraud and criminal activity;
  • to understand your financial needs and determine which financial products or related services may be of use or of interest to you;
  • to evaluate our services and for quality improvement, and for general quality assurance purposes;
  • to offer and provide you with products and services which may help meet your needs;
  • to share with third parties Wiseday may select and make arrangements with as its business associates for mortgage, and/or other financial services;
  • those business associates may directly or through us determine eligibility for products and offer them to you;
  • to respond to your questions and comments;
  • to administer our financial and lending programs and provide ongoing service including dealing with your mortgage agent or broker and meet legal, security, processing and regulatory requirements, including Canadian federal and provincial requirements and requirements under foreign laws;
  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;

In the event that you are seeking to obtain a mortgage or undertake a purchase with another person, we will require the same information from that person.

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it.

Wiseday may use Plaid, Inc. (“Plaid”) to connect your Wiseday mortgage application with your bank account to determine your eligibility for an Instant Pre-Approval (IPA) or a Fast-Tracked Renewal or Refinance. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.

Consent

Your consent is required before we may collect, use or disclose your personal information, except in special circumstances. These special circumstances may include situations in which the use of your information is legally required, required for reasons of health or security, or in other circumstances such as a fraud investigation.

You may provide us with consent in a number of different ways. These include when you provide us, or a licensed agent or mortgage broker, with information for a particular purpose, such as a credit application, mortgage commitment, mortgage or related document. In such cases, you are providing us with consent to collect, access, use and disclose the personal information that you have provided for all reasonable purposes related to the purpose(s) for which you provided the information. We will use this information in accordance with this policy and applicable law.

You may also provide us with express consent for collection, use or disclosure of your personal information at the time we collect it, or further to its collection if we identify a new purpose for use or disclosure.

Your consent can be expressed to us orally (such as over the telephone), in writing (such as on an application) or electronically (such as via the internet). We may also ask for your Social Insurance Number, in order to provide to a credit reporting agency so that they may conduct a credit check in the fastest and most accurate way.

It is important that the personal information we hold about you is accurate, updated and current. Please keep us informed if your personal information changes as we rely on you to keep all of your information current. By law you have the right to request access to and to correct the personal information that we hold about you. You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions: for example, you may not withdraw your consent to disclosure of your information to our service providers (as defined below) during the term of your mortgage. Please note that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive.

To withdraw your consent, you should contact our Privacy Officer at the email address listed below.

Collecting, Using Disclosing and Storing Your Information

As we understand your privacy is a priority, we only collect the information we require in order to provide our services, or for such other reasons as we may indicate. We will not use or disclose your personal information for purposes other than those identified to you at the time or before your consent was given. Except in special circumstances as we set out above, we will seek your further consent before using the information for purposes beyond the scope of your original consent.

There are some necessary types of disclosure of your personal information which occasionally occur as part of Wiseday fulfilling its routine obligations and conducting its business in the ordinary course. This includes, for example, disclosure to third party lenders, rating agencies, and consumer reporting agencies.

With your consent, Wiseday will also provide your personal information to third party business associates for determining your eligibility for their own products so they may offer them to you. Wiseday may also provide your personal information to partners, consultants and suppliers who provide services to Wiseday in the operation of Wiseday’s business (also known collectively as "service providers"). Wiseday may have service providers receive your personal information. Wiseday ensures these service providers are obligated to use it only for the purpose of providing the services to Wiseday and that your information is kept secure.

We will retain your information only for the time it is required for the identified purposes and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Once your personal information is no longer required, it will be destroyed or made anonymous.

Safeguarding Your Information

We will protect your information, whether in electronic or paper based format, with strict safeguards and security measures, to protect it from unauthorized access, disclosure or misuse.

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We review our security procedures regularly to ensure that they are being properly administered and that they remain effective and appropriate.

Providing Access to Your Information

We will give you access to the information we retain about you when you request it and satisfactorily identify yourself. We will tell you what personal information we have, what it is being used for, from whom it was collected and to whom it has been disclosed (except where such disclosure was to a governmental body or service provider for routine purposes or to a governmental body where that body has exercised a legal right to obtain the information).

We will do so within a reasonable time and a nominal fee for processing your request may apply.

We may not provide access to personal information within our possession or control if it:

  • contains references to other individuals
  • doing so may reasonably be expected to threaten the security of another individual;
  • would reveal confidential commercial or proprietary information;
  • is subject to solicitor-client or litigation privilege;
  • is used for detection and prevention of criminal activity and dealings in proceeds of crime; or
  • or cannot be disclosed for any other legal reasons;

If we deny your request for access to your personal information, we will advise you in writing of the reasonfor the refusal.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our site, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our website, and other communication data and the resources that you access and use on the website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Site according to your individual interests.
  • Recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How You Can Protect Your Privacy

Reasonable measures (such as systems access security controls, safeguards to detect and prevent security system failures, restricted access and employee training) have been implemented to help protect personal information from loss, misuse, unauthorized access or disclosure. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of personal information. You also play an important role in protecting your privacy and the confidentiality of your personal information.

For example, you should:

  • create a strong and unique password for your user accounts
  • never share your user accounts or password with anyone (we will never ask you for your password, including in any unsolicited communication such as letters, phone calls or email messages, so please contact us if you receive such a request)
  • log out of your user account once you are finished using it, especially if you share your device(s) with anyone else
  • implement a strong and unique password on your device(s).

Respecting and Responding to your Privacy Concerns

Wiseday has prepared this plain language Privacy Policy to keep you informed. It is made available to the public in paper form at the address set out below, and in electronic form at privacy@wiseday.ca. Updated versions of this Privacy Policy may be posted on Wiseday’s website.

If you have any questions or concerns regarding your privacy or this Privacy Policy, you should direct them to Wiseday’s Privacy Officer at the telephone, e-mail address or mailing address below.

Wiseday Privacy Officer
Address

800-1 – Westmount Square
Westmount, Québec
H3Z2P9 Canada

E-mail address: privacy@wiseday.ca

Please be sure to include your name, address, preferred method of communication, the nature of your complaint, request or query and relevant details, including your past communications with us. If you have a complaint and it is justified, or a question we will take the steps necessary to resolve the issue, including, if necessary, amending our Privacy Policy and procedures.

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