Privacy Policy
This website (WEFundMtgs.com), we only collect, with the exception of cookies, the personal information you provide. That information will only be used for the purpose you provided it for. Cookies are only used to help you navigate our website and are not used to monitor you.
If you visit our Web site(s), we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is kept strictly confidential. This Privacy Policy does not apply to aggregated data from which it is not possible to determine the identity of a specific individual. We reserve the right to use aggregated data in any way that it determines appropriate.
We gather and use Personal Information in order to provide you with the products and services you have requested, namely: information that is required to effectively provide products and services. We may also use your Personal Information to update you about our services and to offer you additional products or services that you may be interested in, so that we may continue to serve your needs.
Keeping your personal information private is important to WE Fund Mortgages Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide. Our privacy policy is designed to let users of our website and new clients have clarity and demonstrate our transparency of our business practices.
In order to understand the difference between personal and business information, we want to define each and what our Privacy Policy covers.
Personal Information is information about an identifiable individual. Personal information includes information relating to an individual’s personal characteristics such as age, gender, ethnic background, income, home address and personal phone number as well as health information (health history, health conditions, health services received by them, family practitioner, etc.) or an individual’s activities and views including but not limited to religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual.
Business Information is different from personal information in that it relates to an individual’s business details such as their business address and business telephone number.
For the sake of clarity, Personal Information is protected by Canada’s Personal Information and Electronics Documents Act (PIPEDA) whereas Business Information is not protected by privacy legislation.
Keeping Your Information Accurate
WE Fund Mortgages Inc. strives to base its decisions on each client’s accurate, complete and relevant personal information. Therefore, we rely on you to disclose all material information and inform us of any changes so that we may update our files.
Use of Your Information
There are several reasons why we collect and use 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/or other third-party sources, should we need additional information about you.
Personal information is collected to establish a relationship and to serve your financial needs. It is used:
- to verify your identity;
- to determine the suitability of our services;
- to evaluate your application for becoming a lender and pair it with a mortgage loan in our portfolio;
- to understand your financial needs, risk tolerance and goals in determining which financial products or related services may be of use to you;
- to administer our financial and lending programs and provide ongoing service including dealing with your mortgage agent or broker; and,
- to comply with legal requirements and regulations.
WE Fund Mortgages Inc. uses a select number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office maintenance, tech support, bookkeepers and accountants, a loan administration database and storage company, credit card companies, website managers, and other lawyers. WE Fund Mortgages Inc. restricts their access to any personal information held as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
Please also note that the cost of some services provided by WE Fund Mortgages Inc. to clients is paid for by third parties (e.g., lawyers transacting a mortgage). We obtain consent from these clients to have these third-party payers disburse funds to WE Fund Mortgages Inc.
There are some necessary types of disclosure of your personal information which occasionally occur as part of WE Fund Mortgages Inc. fulfilling its routine obligations and conducting its business in the ordinary course. This may include, for example, disclosure to third party lenders, rating agencies, consumer reporting agencies, partners, consultants and suppliers to We Fund Mortgages Inc.
WE Fund Mortgages Inc. collects personal information about members of the general public and uses this information to provide notice of special events (e.g., a seminar or conference) or to make them aware of our mortgage administration services or our company in general. We may also collect this information from the general public for email marketing. For example, while we try to collect work contact information where possible, we might collect home addresses and personal email addresses. We try to obtain consent before collecting any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list. We also comply with Canada’s Anti-Spam Legislation (CASL).
On our website, we only collect, with the exception of cookies (electronic markers identifying computers that have previously visited our website), the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a course or seminar, to subscribe to our newsletters and/or email distribution). Cookies are only used to help you navigate our website and are not used to monitor you.
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out pay cheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g., an outbreak of a contagious disease) or to investigate a possible breach of law (e.g., if a theft were to occur in the office).
In general, by requesting WE Fund Mortgages Inc.’s services and/or submitting information to us in connection with using our services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy and in the WE Fund Mortgages Inc. contractual documents. Moreover, by visiting, interacting with and/or using our websites, you agree to benefit from, be bound by, the terms and conditions of this Privacy Policy.
Honesty and integrity are very important to WE Fund Mortgages Inc. As such, we will report serious misconduct, incompetence or incapacity of other mortgage professionals, whether they belong to other organizations or our own. Financial Services Regulatory Authority of Ontario (FSRA) has their own strict privacy obligations. While we will make every possilbe attempt to minimize the amount of personal information shared in such investigations, these reports could include personal information about our clients, or other individuals, to support the investigation.
Various government agencies such as Canada Revenue Agency or the Information and Privacy Commissioner, have the authority to review our records and interview our team as a part of their regulations and rules.
In certain circumstances, personal information may be collected, used or disclosed without consent. These exceptional circumstances may include:
- when information is being collected, used or shared for the detection, prevention of or remediation to, the breach of an agreement, fraud or other illegal activity, and the collection of consent might defeat the purpose of collecting the information;
- to collect a debt; and
- to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law or by any regulatory bodies having jurisdiction.
Consent
Your consent is required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation and in other legal and security situations.
We accept any of the following as your consent for WE Fund Mortgages Inc.’s existing and future collection, use and disclosure of your personal information for the purposes identified in this policy or in any document in which you expressly give your consent:
- your unrestricted provision of information directly to WE Fund Mortgages Inc. or through licensed agents or mortgage brokers;
- your consent as obtained through an application process, or in a mortgage commitment, mortgage or related document;
- your receipt of this Privacy Policy, unless you advise us, either orally or in writing, that you do not agree with the terms stated in this Policy, and that you wish to opt out of all or portions of it.
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). Providing your SIN for credit products is optional. If you provide it, we will use it to keep your information separate from others with a similar name, including in our collection and disclosure of information with credit reporting agencies.
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 (defined as third party lenders, rating agencies, consumer reporting agencies, partners, consultants and suppliers to WE Fund Mortgages Inc.) 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 Information and Privacy Officer at the address or telephone number listed below.
How We Protect Your Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Administrative Safeguards
- We have internal privacy and security policies and procedures.
- Our staff are required to complete competency based trainings on privacy and security. Specifically, our Privacy and Information Office has completed a minimum of 2-days of cybersecurity training and is regularly required to keep updated on cybersecurity best practices.
- Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
- We have signed confidentiality agreements with everyone on staff.
- We conduct an internal annual privacy impact assessment.
- External consultants and agencies with access to personal information must provide us with appropriate privacy assurances.
Technical Safeguards to Protect Electronic Data
- A limited number of dedicated computers/laptops are used for conducting business and both include a combination of strong authentication passcodes and biometric controls for access.
- We have a dedicated Privacy Officer responsible for privacy protection which includes auditing and monitoring company activity.
- Strong passwords and data encryption are mandatory for any incoming or outgoing correspondence.
- We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
- Electronic information is transmitted either through a direct line or is anonymized or encrypted.
- The workstations used maintain up-to-date security, spyware, virus and malware protection.
- We use a third party service provider to house file information. This serve provider has a database that is fully encrypted and access to the software is password restricted. Their server is certified with Microsoft Azure and complies with the most stringent national and international norms. Data is backed up daily.
Physical Safeguards
- We avoid paper information and should we have to collect paper information, we limit the amount of paper information collected. Any paper information is either under supervision or secured in a locked filing cabinet with only assigned access.
- Any paper documents received are transcribed electronically (scanned and saved to the cloud) and then shredded with a cross-cut shredder by the Privacy Officer and/or Compliance Officer.
- We destroy paper files containing personal information by shredding.
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
WE Fund Mortgages Inc. needs to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for a minimum of seven years from the last day of interaction/transactions. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients, newsletters, seminars and marketing activities for about two years after the newsletter ceases publication or a seminar or marketing activity is over.
Providing Access to Your Information
With some exceptions (one of which is quite broad), you have the right to see what personal information we hold about you. Often all you have to do is ask. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. 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
- cannot be disclosed for any other legal reasons
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
We Fund Mortgages Inc.’s Privacy and Information Officer
Our Privacy and Information Officer, Wendy Singh, can be reached at: WE Fund Mortgages Inc., 200 – 2800 Skymark Ave., Mississauga, ON L4W 5A6 or by email at: info@wefundmtgs.com. She will attempt to answer any questions or concerns you might have.
Concern/Compliant Process
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy and Information Officer to the address above. Your formal compliant will be acknowledged, investigated promptly and you will be provided with a formal decision and reasons in writing by our Privacy and Information Officer.
This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
